22VAC40-211-31

A. The minimum age to become a resource parent should be 21 not 18.  I have never known an 18 yr. old responsible enough to successfully parent the types of kids we get into foster care.

D. T.B. tests should only be done on the adults in the home.  Subjecting all the household children to T.B. tests is unnecessary and costly.

22VAC40-211-40

B. UPON SUBMISSION OF AN APPLICATION THE DHS IS RESPONSIBLE TO COMPLETE THE STUDY.  I understand this to mean that we have to proceed with the home study (and not just a denial letter) even if the applicant has an obvious violation of the standards (i.e. barrier crime, Founded CPS,etc.).  Moral of this story...get lots of info on the applicant BEFORE they complete the application!

F.6. The CONFIDENTIALITY FORM should only be kept in the Resource Parents' record NOT in the child's file.  It makes sense to keep it with the Resource record as they are the ones to sign it.  This form is NOT "child-specific" & would add unnecessarily to the bulk of the child's file and if the child was adopted, the form would be purged with the record anyway.

G. SIGNIFICANT CHANGES WITH THE PROVIDER REQUIRE AN UPDATED STUDY. Wouldn't any changes with the providers be documented in our contacts and visits documentation which should be found in their record?  Why write an updated study also? If the significant change effects their certification, we would need to take action accordingly regarding the appropriateness of continuing their certification and document this in the record as well, but not necessarily write an updated study.

22VAC40-211-50

A. The approval period needs to be 24 months not 36 months.  Too much can happen in 3 years. 

22VAC40-211-70

F. CHILDREN OVER THE AGE OF 16 MOS. SHALL NOT SHARE A BED. Shouldn't this read "Children under the age of 16 mos. shall not share a bed"?  A baby sharing a bed, especially with adults, is extremely dangerous.  We've had several fatalities involving infants who have suffocated while sleeping with adults. On the other hand, why couldn't two school-age sisters or brothers who have no sexual acting out issues share a full or queen-size bed??

22VAC70-211-100

A. THE LOCAL DEPT.'S REP. SHALL VISIT THE HOME AT LEAST QUARTERLY.  Semi-annual visits (every 6 mos.) by the foster home staff is enough especially with the new policy requiring monthly visits by the foster care workers.  For our agency, visiting 100+ foster homes every 3 months would be quite time consuming.  If the foster care worker has concerns re: a foster home, we would definitely visit that particular home more often. 

B.3. THE RE-APPROVAL PROCESS SHALL INCLUDE COMPLETING STATE CRIMINAL CHECKS & CPS BACKGROUND CHECKS.  State criminal checks should be done, however CPS checks seem unnecessary as the approving agency should always be made aware of and be involved in any CPS complaint made on one of their foster families.

B.3. THE RE-APPROVAL PROCESS SHALL INCLUDE OBTAINING THE RESULTS OF A NEW TUBERCULOSIS SCREENING. I think this is not only unnecessary, but is an additional financial burden on our foster families. (Our local health dept. charges $13 per individual for a TB screening & an additional $7 if a skin test is deemed necessary.)  In my 16 years of doing studies on foster parents, I've never seen a result of an active case of communicable TB on any foster parent.  Wouldn't it make more sense to require a physical exam be done in the past 12 months on all adults in the home at the time of renewal??  Why is TB the only targeted disease?  How about HIV?