> HOPE FOR CHILDREN, INC.
>
> 24 PERIMETER CENTER EAST
>
> SUITE 2400
>
> ATLANTA, GEORGIA 30346
>
> 770.391-1511
>
> 800.522-2913
>
> FAX 770 - 391-1566
>
> www.hopeforchildren.org
>
> Member:
>
> Joint Council on International Children\'s Services
>
> Georgia Assoc. of Licensed Adoption Agencies
>
> November 10, 2003
>
> U. S. Department of State, CA/OCS/PRI
>
> Adoption Regulations Docket Room SA-29
>
> 2201 C Street, N.W.
>
> Washington, DC 20520 -
>
> RE: Docket Number **State/AR-0l/96**
>
> Dear Hague Representatives:
>
> After further reviewing the regulations and seeing what a huge
> implication this could have to agencies around the country, I strongly
> urge you to change the regulations and let them be reviewed one more
> time before the final edition is published. Also, please initiate with
> all of the state governments to let them know what needs to be done to
> become an accrediting body.
>
> Again, thank you for all of your time and effort on this huge and
> important project for families and children.
>
> Sincerely for children,
>
> Kent Brand, MSW, ACSW, LCSW
>
> Director of Social Services
>
> Executive Director
>
> HOPE for Children, Inc.
>
> 24 Perimeter Center East
>
> Suite 2400
>
> Atlanta, GA 30346
>
> International and Domestic Adoptions
>
> Affiliated with HOPE*worldwide*
>
> HOPE FOR CHILDREN, INC.
>
> 24 PERIMETER CENTER EAST
>
> SUITE 2400
>
> ATLANTA, GEORGIA 30346
>
> 770.391-1511
>
> 800.522-2913
>
> FAX 770 - 391-1566
>
> www.hopeforchildren.org
>
> Member:
>
> Joint Council on International Children\'s Services
>
> Georgia Assoc. of Licensed Adoption Agencies
>
> October 13, 2003
>
> Dear Hague Representatives:
>
> Thank you for all of your incredible hard work in preparing
> regulations to protect the children of the world. You have worked very
> hard to ensure quality services to the children and families who are
> involved in international adoption.
>
> I deeply appreciate the appropriate quality control standards, since I
> believe this is very important to providing excellent services. Also,
> I appreciate the fact that your standards include families receiving
> timely and meaningful disclosures about fees, procedures and their
> child\'s medical well-being. This is an extremely important part of
> your work. In addition, I\'m glad to see that the families involved in
> the adoption process have official recourse when problems arise.
> Someone needs to be defending the children and the families. Your role
> is extremely important.
>
> I have one suggested change in 96.37. It currently reads as follows:
>
> Education and experience requirements for social service personnel.

a)  The agency or person uses employees with appropriate qualifications
    and credentials perform, in connection with a convention adoption -
    related social service functions that require application of
    clinical skills and judgment (home studies, child background
    studies, counseling, parent preparation, post placement, and other
    similar services).

b)  The agencies or persons employees meet any state licensing or
    regulatory requirements for the services they are provided.

c)  The agencies or persons, executive director, the supervisor
    overseeing a case, or the social services employee providing
    adoption related social services that require the application of
    clinical skills and judgment (home studies, child background
    studies, counseling, parent preparation, post placement, and other
    similar services) have experience in the professional delivery of
    intercountry adoptions.

d)  Supervisors. The agencies or persons social work supervisors have
    prior experience in family and children services, adoption, or
    intercountry adoption and either:

    1.  A Master\'s Degree from an Accredited program of social work
        education;

    2.  A Master\'s Degree (or doctorate) in a related human service
        field, including but not limited to, psychology, psychiatry,
        psychiatric nursing, counseling, rehabilitation counseling, or
        pastoral counseling; or

    3.  In the case of a social work supervisor who is or was an
        incumbent at the time of the convention enters into the force
        for the United States, the supervisor has significant skills and
        experience in intercountry adoption and has regular access to
        consultation (to an individual with the qualifications listed in
        paragraph (d.1) or paragraph (d.2) of this section

e)  Non-supervisory employees. The agencies or persons non supervisory
    employees providing adoption related social services that require
    application of clinical skills and judgment other than home studies
    or child background studies.

    1.  Have a Master\'s Degree from an Accredited program of social
        work education or another human services field, or

    2.  Have a Bachelor\'s Degree from an Accredited program of social
        work; a combination of a Bachelor\'s Degree in another human
        services field and prior experience in family and children
        services, adoption, or intercountry adoption; or a Bachelor\'s
        Degree in any field and extensive experience in intercountry
        adoption. Additionally, the non-supervisory employees are
        supervised by an employee of the Accredited agency or approved
        person who meets the requirements for supervisors in
        paragraph (d) of this section.

f)  Home Studies. The agencies or persons employee who conducts home
    studies:

    1.  Have a minimum of a Master\'s Degree from an Accredited program
        of social work education or Master\'s Degree (or Doctorate) in a
        related human service field including but not limited to,
        psychology, psychiatric, psychiatric nursing, counseling,
        rehabilitation counseling, or pastoral counseling;

    2.  Are authorized to complete home studies under the law of the
        state of the child\'s proposed residence; and

    3.  Meet the **INA** requirements for home study prepares in
        8CFR204-3(b) covering home studies in convention cases.

g)  Child Background Studies. The agencies or persons employee who
    prepare child background studies have a minimum of a Master\'s
    Degree in an Accredited program of social work education or a
    Master\'s Degree (or Doctorate) in a related human service field
    including but not limited to, psychology, psychiatric, psychiatric
    nursing, counseling, rehabilitation counseling, or pastoral
    counseling.

> I deeply appreciate the high standards that the Hague Regulations are
> holding for those who prepare home studies. However, I believe having
> an MSW is only one way to ensure quality home studies. I suggest that
> caseworkers who have at least four years of experience be able to
> qualify by showing examples of their work, documenting extensive
> training, taking a test to prove they are qualified to do
> international home studies, and absolutely be supervised by an MSW who
> is a licensed clinical social worker. I also suggest that in order to
> qualify a person who may have the experience that a quality control
> questionnaire be given to the adoptive parents who have received
> children to ascertain how well the home study preparer prepared them
> for adoption.
>
> I have employed people with their MSW as well as people without a
> degree to do home studies. Often I have seen the ones without a degree
> are more competent to train and teach during a home study than an MSW
> who simply asks the questions. The key is the life experience of the
> worker, the commitment to training and the attitude and heart to
> continue to learn from their supervisor.
>
> Therefore, I would like to change section (f.1) to read as follows:
>
> f\. Home Studies. The agencies or persons employee who conducts home
> studies:
>
> 1\. Have a minimum of a Master\'s Degree from an Accredited program of
> social work education or Master\'s Degree (or Doctorate) in a related
> human service field including but not limited to, psychology,
> psychiatric, psychiatric nursing, counseling, rehabilitation
> counseling, or pastoral counseling. Or, at least four years of
> experience under the supervision of a licensed clinical social worker
> with at least 100 hours of documented training in the field of
> adoption and social work and at least 20 documented quality control
> questionnaires from adoptive parents who have completed adoptions
> under the caseworker\'s home study supervision which demonstrate the
> skill to train and prepare adoptive families for international
> adoption.
>
> Again, thank you for your incredible hard work and concern for
> families and children. I hope these comments are helpful as you make
> final changes in the Hague Regulations.
>
> If you have any questions, please feel free to contact me.
>
> Sincerely for children and families,
>
> Kent Brand, MSW, ACSW, LCSW
>
> Director of Social Services
>
> Executive Director
>
> HOPE for Children, Inc.
>
> 24 Perimeter Center East
>
> Suite 2400
>
> Atlanta, GA 30346