Those of us working with Licensed Child Placing Agencies have been eagerly waiting to see a draft of the proposed new regulations. Our understanding has been that the process of developing new standards would be open and collaborative. I am concerned that since none of us has received a complete draft of the Standards, we have not been able to make meaningful comments on them before the end of the NOIRA stage. I hope this will not undermine the process of collaboration with the Division of Licensing nor create the impression among members of the State Board of Social Services that private service providers have been fully involved in the development of the most recent draft.

I believe the public agencies referring children for services, the children receiving those services, and the LCPAs who provide the services would all have been better served if the proposed standards for LCPAs had been made available, well before now,  to LCPAs for their consideration.  I am disappointed that as we near the end of the NOIRA process providers have not been included in a meaningful way in the important work of developing standards intended to protect the health, safety, and welfare of children.  In the past the private and public sectors have worked well together in this regard and I hope this will be the case in the future.  A number of "anticipated benefits" are identified in the NOIRA.  To increase the likelihood that such benefits will come to pass, providers who have a wealth of experience in and knowledge about foster care, adoption, and/or TFC should have the opportunity to review the proposed standards prior to their submission for public comment.