**A Red Thread Adoption Services, Inc.**

681 Washington Street, Suite 12, Norwood, Massachusetts 02062

333 Westminster Street, Providence, Rhode Island 02903

781-762-2428 • 888-871-9699 • FAX: 781-762-2561

RedThreadAdopt@aol.com

December 15, 2003

Gentlemen:

I am enclosing my comments on the draft regulations for IAA:

**IV The Intercountry Adoption Act of 2000 (IAA)**

***B Overview of Substantive Provisions and E. Economic Impact/Effect on
Small Entitles***

**Concerns:** I agree with moving toward mandatory accreditation, but,
as a small agency, we are very concerned about increased costs for
agencies of the accreditation process, as well as insurance costs. We
are concerned about the impact on small agencies, as well as the
possibility of all agencies having to pass on additional costs,
resulting already expensive adoptions further costly.

**4. Subpart F\--Standards for Convention Accreditation and Approval**

**Section 96.35: Suitability of Agencies and Persons to Provide
Adoption**

**Section 96.43 Case Tracking, Data Management, and Reporting:**

**(Also appropriate for Ethical Practices and Responsibilities, 96.35**

**Comments**: The regulations should make it a requirement that agencies
disclose if they have ever operated under a different name or if the
principals in that agency ever worked with other agencies. There have
been cases of unethical agencies relocating and setting up under a
different name and/or agency personnel opening up new
businesses\--sometimes in the same town\--under a different name. Hague
requirements should expose a paper trail, not only of the agency but of
the key names associated with it. This tracking of agencies, personnel,
and overseas facilitators should be included.

**\-- Application Procedures for Accreditation and Approval**

**Section 96.40 Fee Policies and Procedures:**

**Comments:** Hague regs should prohibit direct cash transactions by
adoptive parents to birth parents.

**Section 96.49 Provision of Medical and Social Information in Incoming
Cases:**

**Comments:** It would be very helpful for the regulations to stipulate
a standardized health and social history data collection and information
sharing to guide the process for children and adoptive parents and to
assist in better matching of children with appropriate adoptive parent
resources best able to meet the needs of children.

**13. Subpart M \-- Dissemination and Reporting of Information by
Accrediting Entities:**

**Comments**: Whenever the Department or accrediting agency takes action
against an agency (suspension, cancellation, refusal to renew,
corrective action, etc.) this action should be made public on the State
Department website.

**Financial Risk and Management**

**96.34 Compensation**

**Comments**

d\. A provision should be added to ensure that fees, wages or salaries
be commensurate with the cost of living in sending country.

Agencies should also disclose to adoptive parents how the agency
determines that a child is a genuine orphan and are appropriate for
placement with a family in another country.

**96.36 Prohibition on child buying**

**Comments**: Direct cash transactions by adoptive parents to birth
parents should not be allowed.

**96.40 (3) Foreign country program expenses:**

**Comments:** These expenses should be detailed. Foreign program fees
vary wildly and it is not clear why. The need for transparency here is
critical.

Thank you very much for considering these comments as you complete the
regulations process.

Sincerely,

Leah C. O'Leary, LICSW, Executive Director

A Red Thread Adoption Services, Inc.