Generally we realize that this was written to access Title IV-E funds.  If 22VAC40-211 is approved then it is clear that things will become "looser" for private agencies and "tighter" for public agencies.  Please exclude the brief statements below as it was hard for me to create bullet lists.   

Specific Items:

1.)the last part of page 3411 requiring DMV record checks is a good idea 2.)on page 3412, in the first paragraph, under number 7, annual training should be changed to at least quarterly. 3.)same page, at the end of the first paragraph, the last sentence allows for re-evaluations to be done every three years, that should be at least every 2 years or less.   4.)On 3412, the first sentence of the third paragraph states that 8 foster children shall be allowed in a home.  That number should be six or less, and the number should include the foster parent's biological children.  What if a foster parent has six kids of thier own, and then eight foster children are added?  5.) On page 3413, in the middle of the first complete paragraph, the sentence says"...DSS will provide opportunites for training on an annual basis at no charge."  Providing opportunities is not the same as mandating training.  Quarterly training should be free and mandatory.  6.)

Thanks for your consideration,

Eliot Faircloth

Carpe Diem Children's Services