I don't put much faith in Federal Regs, but support any effort that might bring improvement. State licensing is another matter.
Here's something you could do with a group of committed people. Power in numbers. Preferably this would be parents, participants, advocates. You might even name your group and pick a rep who interacts with the state on the group's behalf.
Target one state at a time. Pick one that has a large number of residential programs and or a high number of deaths in programs.
Lists of deaths can be found at FICA and CAICA:
http://kathymoya.com/FICA/deaths.htmhttp://www.caica.org/NEWS%20Deaths%20Li ... mitted.htmLists of programs can be found at NATSAP and
at Bozak's site:
http://www.natsap.org/search.asphttp://www.school-placement.com/therapeuticlist.htmlResearch licensing in that state. This link is primarily for Daycare Licensing in all states, but when you click on a state you should be able to link to Licensing for Residential/Outdoor programs from there.
http://nrc.uchsc.edu/STATES/states.htmDoes that state have regs for RTCs/ TBSs/ Wilderness? Are the regulations adequate? Most have not kept up with the Industry. For instance, Ga has regs for RTCs, but they're lame in comparison to Utah's regs for TBSs. Utah's regs for Wilderness are also superior to Ga's. You can read more about that in the HLA forum:
http://wwf.fornits.com/viewtopic.php?t=19064We found that Ga had no idea so many programs were operating in their state. Don't assume they know.
Check to see if all the programs in that state are properly licensed. If not, demand that they become licensed. If previously 'exempted', why? Claim to be a 'boarding school'? Provide proof they aren't.
Licensing may drag their feet. If so, go up the chain of command until you get someone's attention.
Chain of command: Licensing -> Dept of Human Resources -> Governor
Resort to Guerilla Media if necessary.
There are many other agencies you can file complaints with.
Check the credentials of 'professional' staff. Do they possess the degrees and licenses they claim? If not, report them to the Board of Examiners.
Is the program refering to babysitters as "counselors" and having them lead group therapy? Report it.
Known and documented abuses and negligence? Involve CPS.
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Many advocates have given up on state licensing for good reason. The regs are useless if not enforced, but there are numerous other reasons it's important for programs to be licensed, given that they aren't going to go away.
*They are requried to report incidences of assault, rape, injury, death. And the info becomes public. We need this data if we ever hope to show ineffectiveness.
*Until a program is licensed, it is difficult for Licensing or CPS to gain access to investigate abuse/neglect because they are a private corporation with all the rights that entails. It's a huge rigamaroll.
*Once licensed, all complaints lodged against the program can be requested by potential parents.
*All violations of regs then become public as well.
Licensing is not insurance that kids will be treated with respect and dignity, or that they'll be much safer, but they are important for the reasons stated.
And, if licensing isn't your bag, start a campaign in your state advocating for a Wraparound program similar to Milwaukee's-
http://wwf.fornits.com/viewtopic.php?t=19038While this program appears to target low-income families, it would be easy to include all families and those with the ability to pay would do so.