**ADOPTION CENTER**

** **

**JEWISH FAMILY SERVICE OF GREATER HARTFORD**

740 NORTH MAIN STREET, SECOND FLOOR, WEST HARTFORD, CT 06117

-           Phone (860) 236-1927, • Facsimile (860) 236-6483 • E-mail
    [Helish@jfshartford.org](mailto:Harriet_Elish@jfshtfd.org)

Domestic and International Adoption . Home Studies . Home Licensing .
Counseling . Workshops. Referrals

 

To the U.S. State Department in reference to State/AR-01/96,

 

Jewish Family Service of Greater Hartford, Connecticut has a number of
concerns in regards to the proposed regulations on intercountry
adoption. We are a non-profit organization and have been providing
adoption services for nearly ninety years. Our agency has a small
adoption program currently providing only around twenty homestudies a
year. We have an international adoption program with Guatemala. Our
concerns are as follow:

 

Subpart C states that all agencies providing adoption services will need
to be accredited. We are concerned about the costs of accreditation. We
are currently accredited by the COA. The initial process of this
accreditation cost our agency around five thousand dollars. Depending on
who is chosen as the accrediting organization the cost of the new
accreditation process could be significantly more. We fear that these
costs will be prohibitive to small adoption programs like ours.

Subpart F, 96.33 states that an adoption agency needs to carry at least
one million dollars of liability insurance and possibly more depending
on the assessment of our legal risk. We currently have a policy that
insures us for a million dollars but it does not cover persons that we
work with outside of the country. We have contacted our insurance
provider who has indicated to us that at the present time no such
insurance is available. We can only assume that this insurance will be
more costly than what we currently carry. We are unsure how the
assessment of legal risk will be handled and would like some explanation
about this.

 

Subpart F, 96.33 also states that an adoption agency must maintain cash
reserves to meet operating expenses for at least three months. It is
unclear to us exactly what is meant by operating expenses and we are
unsure how much money we will be required to have in reserve. We are
concerned that we will not be able to meet this requirement with the
limited income from our adoption program.

 

Subpart F, 96.45 and 96.46 states that an accredited agency will be
responsible for the acts of any agency or person in the United States or
abroad that they choose to work with. We are not able to directly
supervise most agencies and persons that we work with in the U.S. and
certainly have a very limited ability to do this with those that we work
with abroad. It will be very difficult to obtain complete information
about a provider's history of practice especially in a developing
country. Entering into a written agreement with a person in another
country may also be difficult because of the difference in legal
systems. We do not understand how we can be held responsible for the
acts of those who are not employed by our agency and are unsure how our
agency will be able to protect itself.

 

Overall our concern about these proposed regulations is that they will
raise costs and make it more difficult for us to provide adoption
services to our clients. The increase in costs will be passed on to our
clients making it more difficult or impossible for them to adopt. We
fear that the proposed regulations will have negative effects on
children waiting to be adopted, families wanting to adopt children, and
agencies and their employees. Small agencies will likely be the most
effected by these changes and many will probably be forced out of
business. We take pride in the professional and personalized services
that we are able to offer our clients. Our concern is that these
regulations will limit our ability to provide the excellent adoption
services that clients have come to expect from us.

 

Respectfully,

 

Stacy E. Cutler

MSW Student Intern

at Jewish Family Service

of Greater Hartford