33. in 96.32 (a) ALL agencies AND individuals need to have the
    education, experience and mgmt credentials, not just for agencies.
    These standards need to be in place to protect all 3 parties in the
    adoption triad. (Birthparent/Adoptee/A-parent.) This standard not
    applying to individuals is wrong. I know of people that were working
    as individuals in both Cambodia and Viet Nam and they should have
    been held to these standards.

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34. I would suggest that in addition to normal and customary wages for
    employees, there be no bonus money awarded for work done, children
    placed, etc. Do the fees for service not constitute incentive fees?
    This needs to be clearly defined. Otherwise, it will end up being
    manipulated into fees per child brought in, etc.

> 96.34 d and e are good and need to be left in. Wages/fess/salaries
> should be somewhat uniform. If all are providing like services, are
> non-profit and working in the same counties, countries, etc., they
> should be paying employees and issuing fees that are reasonably alike.

35. This is good. There should be a central location to check real
    references on an agency/facilitator. As a prospective adoptive
    parent, there is nowhere to look to find out if a given agency is on
    the up and up. We had to search through the internet for hours. We
    checked with the BBB, but most agencies have a main office in one
    state and different country programs in other states. Most unhappy
    adoptive parents do not report the services to the better business
    bureau.

> Also, we have a right to know who the in country representative is for
> a given agency. It should not be considered a secret. Too many
> agencies hide behind this cloak when they have a less than ethical
> representative in country.

96.36 a) This seems awfully vague. I would like to see tighter controls.
Possibly a central organizing authority to verify relinquishments before
a child is placed in an adoption related orphanage. The non-uniformity
of the "reasonable payments" by countries opens a can of worms to what
can constitute these reasonable payments. Why is medical care and food
considered reasonable in one country when a bag of rice in another is
considered a payoff?

> b\) This will not work. Training employees not to move into "gray"
> areas is akin to handing teenager keys to the car and telling them not
> to speed. That is not to say that all representatives are unethical,
> rather is allows an unethical agency to do what they want to do.

38. This is good. It needs to be implemented. Too many agencies feel
    they have completed they job when a child arrives on U.S. soil. The
    training provided needs to be uniform and consistent throughout the
    adoption community. Too many agencies do what they can to get a
    child home and do not have further contact with the child/family.
    Counseling/education needs to be extended past the time the child
    gets off of an airplane. All children go through a grieving process
    and it is the job of the social workers, agencies and families to
    address and deal with these issues.

39. A)3) Clients have a right to know who is working on their behalf in
    country. Do not take this part out!

40. (a)(1) Disclosure of fees needs to be broken down and the agency
    needs to be fully accountable for any fees over the usual and
    customary fees for the given country.

41. Again, there are wide variations between agencies and in country
    fees for the same country. These need to be itemized. Why should one
    non-profit agency charge \$16000 for an adoption when another
    charges \$10500? This type of thing raises a red flag with me.

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41. Complaints should be made to the complaint center and then referred
    to the agency. Too many agencies blame unhappy outcomes on emotional
    parents.

42. Records should be kept for a reasonable life expectancy. They should
    always be available to the child, and both adoptive parents and
    birth parents.

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45. The agency needs to held somewhat accountable to the actions of the
    facilitator. If the agency does not trust the facilitator, they
    should not work with her/him. There needs to be some accountability
    on the agency's part.

46. a)4) Does this cover a facilitator losing the right to practice in
    one country then moving to another country to set up shop?

> b)3) Who decides what reasonable payment for activities related to
> adoption proceedings are?
>
> c)1) agencies need to have enough trust in the facilitator that they
> assume responsibility