Within the “Substance” Section of the proposed Regulation it states:

“The new regulation will include changes and updates that will ensure consistency between regulations for approval of local departments of social services and private child placing agency resource, foster and adoptive homes per the Program Improvement Plan of the Virginia Department of Social Services.”  I am concerned that our local DSS foster, adoptive, resource home parents will have to meet increased standards that will require increased costs for them (water testing and sewage inspection, childcare costs in order to attend training, physicals, fire extinguishers, possible time off from work for training and/or additional required interviews by agency staff). 

Although there may be “consistency between regulations” for approval of local DSS and private CPAs, the compensation in payment and staff attention to the homes and children will not be the same; CPA’s foster, adoptive, resource homes will receive a higher level of compensation and a higher level of staff support.  “The board proposes to require that providers be able to ensure that they can be responsive to special medical needs, including environmental sensitivities, of the child.”  I must ask why a person or couple would want to “sign on” as a local DSS foster parent, when they would receive higher monetary compensation and staff support with a private child placing agency.  Local DSS foster care social worker caseloads are high, with increasing mandates, not allowing the one-to-one time by the social worker to spend with the child/family.  On the other hand, part of what we are paying CPA’s when our children are placed in one of their homes, is for increased staff support for the child and family.

The new regulation seeks to update acceptable child sleeping arrangements.  The proposed regulations state that children over the age of 16 months shall not share a bed. In the section entitled:  Department of Planning and Budget’s Economic Impact it states that “this may increase costs for a very small number of providers.  The cost is likely exceeded by the benefit of increased rest for affected children.  Increased rest will improve affected children’s health and ability to learn.”  There are some children/siblings who will not sleep alone; they feel more comfortable sleeping with their sibling.  I think this should be left up to the discretion of the local agency based on the physical, medical, emotional, and developmental needs of the child/children.  Agency policy should encourage the best practice of each child having his/her own bed.  We put our foster parents in the predicament of violating policy/regulation when the foster children continue to sleep together, no matter what we/foster parents do to prevent it.

Our agency provides pre-service and in-service training for our foster/adoptive/resource parents; however, we do not currently require relative providers to attend training.  Our training is usually provided three times a year.  Usually, our relative providers have petitioned for custody of the child.  By the time the relative is approved, often-times as an emergency approval to begin with, the custody hearing is held and custody is awarded to that relative.  If the relative provider meets all of the requirements of this new regulation, except for the training, then IV-E funding would be lost.  Currently, if the relative provider meets all of the current regulation’s requirements, we would be able to draw down IV-E funding for the IV-E child.

Our agency, Campbell Co. DSS, provides pre-service and in-service training for our foster/adoptive/resource families, which is necessary for the foster parents who we ask to provide care to our abused and neglected children. Mandated training is necessary for the service that Virginia expects our foster/adoptive/resource families to provide.  We are doing a disservice to our children and our families if we do not provide training.  I believe that training has cut down on disruptions and multiple placements of our already traumatized children.

While the new regulation proposes to provide enhanced safety and protection for our foster children, the Commonwealth needs to support local agencies with additional funding to support the provision of recruitment and training of foster families.