Mandating training for all prospective and on-going foster, adoptive and resource families is definitely a postive step towards increasing the protection of children placed in the care of local Departments of Social Services here in the Commonwealth of Virginia. While many of the local DSS agencies have already provided required training for their foster, adoptive and resource families for years, other local DSS agencies have not yet established training requirements for many reasons ... including the need for additional funding to support the provision of training.  Mandating training for families, who are asked to provide such important services to children, should document not only the Commonwealth's acknowledgement of the support and assistance needed by these very special families, but should also document the Commonwealth's acknowledgement of the support and assistance needed by the local DSS agencies and social workers who are tasked with providing services to children and their families. Increased training and strengthening of approval requirements should serve as an opportunity for local DSS agencies to enhance protection of the children in care, and to decrease the potential for multiple placements.  These steps should also serve as enhanced opportunities for the foster, adoptive and resource families to receive the knowledge, education and support needed to understand, prepare and meet the needs of the children placed in their homes. What better beginning to develop and sustain a team approach to serving the children of our Commonwealth?

My comment is more about how the changes in the policy will be implemented. What will be the transition process? Will additional training be provided?  For example, the requirement to check DMV records.  Staff will need time to receive training on the databases.  The regulations also mention having resource parents sign a confidentiality statement.  Will the State provide a form letter or are the jurisdictions responsible for creating these documents?  I just want to ensure that we have the resources and supports to effectively incorporate the changes into our programs.

A standard home study format should be formulated and adopted for use by DSS so that each LDSS is consistent -especially since the LDSS are being asked to dually license homes as foster and adoptive homes.  This would certainly ease the transition for a child into an adoptive home if their is a need to search for another home in the State.

There is no mention in the proposed regulations regarding children of the same sex not being able to share a bedroom - that is how it currently stands with the current standards.  I think this is necessary since providers will sometimes go with their own judgement unless instructed otherwise.

Here are some questions I have regarding the proposed regulations:

p 3 (B) Will there be a time frame in which the variance must be reviewed and either approved or denied by the regional office?

p 7 (B5) The current state approval certificate form does not have a space for both the worker who wrote the home study and the supervisor.  If the state is now going to require both signatures, are they planning on revising the form and getting it out to us?

p 8 (B) Will the state be mandating a specific number of hours for on-going training?

p 8  (D) Providers who meet all requirements and are considered fully approved but have not yet taken the pre-service class (but are enrolled), will they be eligible for IV-E placements?  The way it's written, I see this may happen in emergency relative placement situations.

p 10 (I) Will this statement also be true for same sex siblings in short term respite? Ex. a foster parent may have a full size bed and the respite is for 4 & 5 year old sisters for weekend respite.

p 14 (2) In the absence of the provider, is it now appropriate for them to leave the child with someone from their own family and not necessarily another approved agency provider?

Fairfax County Department of Family Services: 

Pg. 5  Clarify definition of "resource family".  Is it simply a dually approved family, or dually approved AND selected to adopt the child if needed?

Pg. 5  Definition of "infant" should remain birth to 24 months, not to 16 months.  The first two years of life are vital for healthy development.  Many infants come in to care in poor condition and with attachment issues.  They need a lot of attention.

Pg. 10  Criminal record checks of all adults in the home should be required every two years, not four, to assure the safety of children.

Pg. 9  "Environmental sensitivities"  - language is too vague.

Pg. 5  Requiring applicants to divulge child abuse and neglect "allegations" is incongruent with current CPS policy regarding the retention of information.  An allegation may prove to be unfounded, or it may not have been accepted for investigation.  Unfair to require this information from applicants.  Instead, ask about founded abuse and neglect complaints.

Pg. 7  It is an unnecessary burden to require a copy of the CPA provider license and family approval certificate/letter in the child's record (as well as the benefits record).  Allow for these documents to be "on file in the agency" or "filed in the foster/adoptive home record."

Pg. 10  It is an unfunded mandate to require semi-annual visits to homes of providers to "monitor their performance."  This would require 340 extra home visits per year for Fairfax County.  Policy requirements to visit children monthly in their placement more than suffices for this "monitoring" function, even without requiring semi-annual documentation in the provider record.

Pg. 7  "Comfortable sleeping or napping furnishings" - unnecessary to reference napping furnishings if the sleeping furnishings are comfortable.

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? 

A suggested change to 22 VAC 40-211-60.D is as follows, "Providers are considered fully approved if they meet all the other requirements for approval of this section and is enrolled in pre-service training.  The provider's approval shall be revoked if the provider does not complete the training in which he/she is currently enrolled."

The way the standard is currently written would allow a person to be approved even if he/she does not complete the training he/she is enrolled in as long as he/she signs a form stating the he/she would complete the next one offered.  If the "next pre-service training available" is a year later (a possibility in some localities), then that means a person could be "approved" for over a year without having been fully trained.  Having just been approved in 2006 by a Child Placing Agency as a resource/foster/adoptive parent and currently having a child in my home waiting to be adopted, I do NOT think it is a good idea to have a person approved unless they are currently enrolled in a pre-service training AND complete the training he/she is currently enrolled in.

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.