Kinship care families should not be expected to complete the same curriculum for pre-service training as non-relative families, but the state should provide standard, consistent guidelines for training, approving, and assessing such families. Will there be some type of waiver for these families within the regulations for pre-service training? Their situations are so different, and I believe that we would not be serving children well if we were to expect kinship families to complete 27 hours of training. I expect that we would lose placements for our children, for whom we are all working.

As I understand it, current foster families will not be required to complete the new training. DSS agencies would benefit from clear, consistent guidelines on how to incorporate current foster families into the regulations. If families are able to work with more than one locality as approved providers, the training requirements and assessments must be consistent across the state. Under our grant, we are recommending that our current foster families to be fully trained through the PRIDE curriculum also. Until now, our local foster parents were given little training before they were approved through the five New River Valley DSS agencies. This has huge implications because if they grandfathered in through the state’s regulations, they will never have the level of expertise we would like for them to have. It is recommended by the curriculum we use that they not attend the same pre-service training as new families, so their training presents another staffing problem. In our program we will not be able to offer current families any in-service training opportunities for several months because I am the only trainer for all five agencies, and we are soon starting pre-service training which will last for nine weeks. If the state created additional positions for trainers, it will be possible to offer in-service trainings for our NRV families on an ongoing basis.

In-service mandates are necessary, and I support the proposed 12-hour requirement. I strongly support consistent guidelines on what qualifies. For example, if some agencies are allowing community meetings to qualify and other agencies are only allowing DSS trainings/functions to qualify as in-service, there will be a problem. A question is what will happen if a family has not met the requirement for in-service? Will the child be removed from the home? The state must develop standards for such situations because policy states that children cannot be in unapproved homes. Another example follows: if a child has been with a family for over a year and is removed from the home because the family did not attend the last two hours of the twelve hours required, are we considering the best interest of the child? If the state does not develop specific guidelines for this, many placements may be terminated, lost, illegitimately used, or penalized through federal audit.

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.