As a provider committed to trauma-informed, person-centered care across both adult and children’s services, I respectfully urge DBHDS to reconsider the decision to merge regulatory oversight for these distinct populations under a single Residential Services chapter.
While I appreciate the intent to streamline and clarify licensing expectations, combining children’s and adult regulations introduces unnecessary complexity and operational risk. These populations differ significantly in developmental needs, legal protections, supervision requirements, and therapeutic approaches. Merging them into one chapter—however well-intentioned—creates ambiguity for providers, especially those serving both groups.
Key concerns include:
• Policy Clarity: Providers must now parse which provisions apply to children, adults, or both—without the benefit of separate chapters. This increases the risk of misinterpretation and noncompliance.
• Staff Training Burden: Training must now be bifurcated internally, with staff needing to distinguish between overlapping but divergent standards within a single regulatory document.
• Audit Vulnerability: Licensing specialists may interpret provisions differently depending on population served, creating inconsistency and confusion during audits.
• ISP and Service Planning: Children’s services often require more intensive coordination with guardians, schools, and legal systems. Adult services emphasize autonomy and recovery. These distinctions deserve regulatory separation.
• Trauma-Informed Practice: Children and adults experience and respond to trauma differently. Regulatory language should reflect these nuances explicitly, not implicitly.
I strongly recommend reinstating separate chapters for Children’s Residential Services and Adult Residential Services, or at minimum, embedding clearly demarcated subsections within the Residential chapter that distinctly address each population. Doing so would preserve clarity, reduce administrative burden, and better support providers in delivering safe, dignified, and developmentally appropriate care.
Thank you for your consideration.