Have you read the definition of RCF?
Which part(s) of the definition do you feel aren't applicable to HLA?
You can argue that they are not an RCF all day, but standard practice is: when any facility cares for children 24/7/365, controls contact with parents/relatives, provides a diagnosis at enrollment and ongoing therapy, dispenses drugs, etc... they should be licensed.
Many states that have regs are largely in the dark. As the Dir of Utah licensing admitted, "We are reactive, not proactive." Whose interest does that serve? Utah DHS promotes programs on their website.
They should be looking at 'services provided' and if they don't have an appropriate 'classification' then create one. In this case, it wouldn't matter if they advertised as a TBS or EGS or PBS, they still meet the definition of an RCF based on services provided.
RCF is the catch-all catagory for all such programs.
What we all know, is that HLA is not/was never a traditional boarding school and that the accreditation organizations they are members of do not provide the same oversight and protection that the state would.
Until parents and Ed Cons refuse to place children in programs that avoid state oversight, hitting them in the pocketbook, this will continue to be a problem. HLA is not the first, or last, to avoid state oversight.
The question remains...Why?
