Although many of these proposed changes go a long way toward the improved health and safety of the Commonwealth's foster children, I am concerned that these changes will result in more unfunded mandated to the local DSS offices. 

I hope there is a suggested standard format for the initial narrative home study and the reapproval narrative that allows for local adjustments, as necessary. (economic impact on local offices to hire staff to do these)

Requiring criminal history searches only every four years seems like a long time.  It may be better to make these searches every two years during the reapproval process.  (economic impact to localities that pay this for the foster parent)

Are criminal history searches still required to be national?  If so, the fee is $37 (not $20).  Who pays?

Requiring that the CPS license and/or the family's approval certificate be maintained in the provider's file,  and the child's file seems excessive as it is already a requirement to also keep this in the benefit file (on IV-E eligible children).  That's three copies of the same document in three places in the same building (for the smaller agencies).  

Increased visits in the provider's home, although a good idea, will have a significant economic impact on localities.  If the home has a child placed there, does the visit from the child's social worker count?  If so, and the provider is approved by another agency or a CPA--is that social worker responsible for notifying the other agency that a visit was made?

Who pays for the physical examination and will there be a standard form for the physician to complete?

3 face to face interviews prior to approval, again perhaps a great idea, WILL have local economic impact.

How is a social worker to determine the glass on the gun cabinet is shatterproof?

Define "environmental sensitivity"

Requiring provider training is very much needed but will require a GREAT DEAL more from already strained staff.  This one requirement, in my opinion, has the greatest potential for positive impact for our foster children.  A well trained and supported foster family will result in fewer placement disruptions and increased permanency for the traumatized child.  This must be carefully considered and not turned into an unfunded mandate which will, by necessity, make training an area that is "worked in" instead of "focused on".

A suggested standard file format from VDSS for the provider's to maintain for their foster child would be a good idea. To increase compliance, the social worker could provide a 3-ring binder to the family with the understanding that the binder goes with the child.  This will have an added benefit of the collection of material for a child's lifebook.  However, this will have an ECONOMIC IMPACT on the local DSS.

L.  "provider shall show documentation of an inspection of the home's private water supply and sewage disposal system by the local health dept."  Who pays for the water test?  I called my local health dept. who say that they have only kept records for inspected sewage systems since 1990 and the only way to ensure an operable system is to have a recent inspecation.  Our health dept. DOES NOT have a system in place to inspect sewage systems at will, they only respond to complaints.  The only way this could happen in my locality, unless there is a regulation change that requires the health dept to do this for us, is for a private septic contractor to inspect the system.  Who will pay for this?

We also need to be careful not to lay too many fees (physicals, criminal history searches, water testing, sewage inspection, daycare or missed work to attend training, etc.)at the feet of potential foster families.

Who, in the provider household, is required to attend training?  All adults, both parents (if a 2 parent home), one parent? What happens if one parent attends the required training but the other does not?