We are interested in the proposed standards as these changes will most likely be replicated for private agencies as well.  We recommend the following:

• 22VAC40-211-70 – D. – good idea to have a land line phone because if only cell phones are used and the parent takes the phone with them and a child is left at home (age appropriate), then they could not call out if there is an emergency
• Physical/health statement conducted by a licensed physician – too strict, could this be completed by a nurse practitioner or a registered nurse, many families go to a walk-in clinic such as Patient First or Redi Clinic. Additionally, does the TB test/screening have to be conducted by a physician, this could also be completed at a walk- in clinic or the local health department.
• Changing the length of time for renewal of home study dates from 24 months to 36 months – 36 months is too long to have a family waiting for a placement with no contact or monitoring, they could have many significant changes in their status during that time.  24 months is more reasonable.