RCPA, in partnership with children’s residential provider members, has
submitted public comments to the Independent Regulatory Review Commission (IRRC) in regard to the Office of Children, Youth, & Families (OCYF) proposed §3900, §3910, and §3920 Residential Services for Children and Youth regulations.
RCPA commends OCYF’s efforts to modernize the previous children’s residential regulations to ensure that children, adolescents, and young adults receive safe and effective treatment. RCPA’s public comments outline potential concerns with the proposed regulations, specifically regarding administrative burden, workforce shortages, training, and potential costs.
RCPA strongly recommends that the Department reconvene stakeholder groups after the public comment period to review the provisions that have the most significant impacts on providers, youth, and families, including but not limited to:
- Staff ratios, training, and required documentation that take into consideration current facility capacity;
- A cost analysis that accurately reflects the cost projection for implementation of the regulations;
- A clearly defined budgeting process that details how funding for implementation will be sourced both in the short- and long-term; and
- The 18-month implementation timeline and potential barriers given the enormity of the regulatory package.
Please contact RCPA Children’s Services Policy Specialist
Emma Sharp with any questions.
