Thank you for the opportunity to provide public comment regarding the Virginia Juvenile Community Crime Control (VJCCCA) User Manual.  We very much appreciate the financial support and value the partnership we have with the Virginia Department of Juvenile Justice (DJJ) in providing a range of community-based, alternatives to detention, and prevention programs for children in our community.  We regularly engage with our stakeholders to review our programs, utilizing data, to determine if we are meeting the varying needs of children before the courts or at-risk of court involvement, so we appreciate and also understand the need for the biennial planning process, the annual evaluation, and the monthly data and financial tracking.

Our team has reviewed the draft VJCCCA User Manual, and we would like to offer the following comments or pose the following questions for further consideration:

1. Overall, did you solicit input and feedback from stakeholders and those who are currently operating VJCCCA plans and programs?  It is our experience that DJJ partners with detention centers and other impacted programs when reviewing and proposing changes to regulations, guidance documents, etc.  We were only made aware that the manual had been updated when we received the Town Hall notice.
2. Allowable VJCCCA Funded Programs and Services (page 9) – “This list is subject to updates”.  What is the process for determining if a program is allowable, and who is involved in that decision-making process?
3. Please specify what a “Department directive” (page 12) may include and how those are determined and communicated to those in the field.  It is hard to adjust to changes in rules, guidelines, and interpretations mid-fiscal year or even mid-plan which has been our experience in the past.
4. For the section on “Vehicles” (page 16), for programs that depend on the use of vehicles – Home Incarceration, Community Service, why can’t maintenance of the vehicle be covered by the MOE or state funds?  Is this provision only allowing for fuel? Many of our families don’t have access to transportation, so one of the reasons our Community Service Program is so successful is because of the transportation piece, ensuring equitable access to this program and providing every opportunity for our participants to complete their required community service hours, thereby preventing violation of court orders and unnecessary time in detention.  Why wouldn’t the state want to support safe and reliable vehicles for those programs that rely on them?
5. For “Equipment may be replaced every 5 years…”  (page 17), this duration seems arbitrary.  Would you consider language such as “no longer serviceable” with support documentation?
6. Can there be some sort of streamline provision for the biennial planning process for core services and programs that have been in place for 20 or more years in a locality (i.e., Home Incarceration, Community Service) that are meeting the intent of VJCCCA funding and meeting or exceeding performance objectives?  Just a review of service units and projected expenditures rather than having to re-write the entire plan?
7. Under “Plan Components” (page 21), why is it an Excel spreadsheet?  The plan requires quite a bit of narrative, and Excel is not conducive nor is it the best format to record many of the plan requirements.  There have been issues over the years with its user-interface, requiring that plan contacts start over with the entire process which is time-consuming and frustrating.

Again, on behalf of the entire Chesterfield VJCCCA Plan Team, thank you for the opportunity to provide feedback and for considering our comments.