My comments are directed specifically to the portion of the proposed Local Department Approved Provider Standards that address foster, resource, and adoptive home providers. These regulations directly affect me, as I the staff person in my agency in charge of Resource Home Provider training and approval for five DSS agencies.

The resources that are necessary to appropriately provide pre-service training are vast. Office space is a problem at most DSS agencies, and as a recruiter and trainer, I can personally testify that the space needed to accommodate such things as all training supplies, mailings, giveaways, computer, desk, and multiple filing cabinets requires more than a cubicle or standard office. Additional office and storage space are essential for staff persons in charge of training, which would be a cost for the state. Each trainer and assessor should be provided with a cellular phone for travel during the evenings and weekends. These specifics might seem insignificant to some, but I currently have seven boxes piled high of training supplies in my small cubicle because there is no storage space. The office space and cellular phone situations do directly impact the fiscal impact of the proposed regulations. Localities are not in a position to pay for regulations imposed by the state. There must be no new regulatory mandates that are not fully funded by the state.

There is a benefit to collaboration between smaller localities for the purpose of recruitment and training; however, that means that the travel time for some families to attend training is significant. One of our families must drive over one hour each way to participate in training, which ends at 9pm on a weeknight, even though the training site is centrally located.

We will soon be offering as many pre-service and in-service training hours as several child-placing agencies. With equal training, how/why are our resource families being paid significantly less money than child-placing agency families? DSS agencies would benefit from carefully defined differences between therapeutic, specialized, and local foster homes. There should be consistency between child-placing agencies’ and DSS agencies’ approved families and in rates paid for care.

Since agencies are reimbursed through Title IV-E only for training and not for recruiting, the local agencies cannot sufficiently and effectively recruit in their locality without funding from the state. Please consider taking responsibility for funding staff positions within agencies for recruitment purposes. I have spent over eight hours at four PTA meetings in an attempt to educate the community on our program and to recruit. These hours are spent after I have worked a full day. I have also had numerous other opportunities to speak at other community events. Unfortunately, continuing the after-hours time commitment is now unrealistic as we prepare to begin our pre-service training. My position is necessary, valuable, and virtually costless for the state due to the grant, but there are not enough grant funds available to staff training programs in the entire state. If the state cannot provide the resources to fund permanent positions like mine, the agencies will fail miserably at implementing the regulations. Localities are not in a position to pay for regulations imposed by the state. There must be no new regulatory mandates that are not fully funded by the state.