1. OFFICE OF RESIDENTIAL CHILD CARE Department of Human Services Dave Statton, Director March 2011

2. Overview  The Office of Residential Child Care (ORCC) began publishing Interpretive Guidelines for Child Caring Institutions (CCI) and Child Placing Agencies (CPA) in 2008.  ORCC published Interpretive Guidelines for the Top Ten Most Cited Rule Violations in 2008; and the Top Twenty Most Cited Rule Violations in 2010.

3. 10 Most Cited CCI Rules Rules TAGProjected Ranking 2011 Times Cited 2011 Ranking 2010 Times Cited 2010 Ranking 2009 Times Cited 2009 Assessment & Planning 290-2-5-10(b) 100319011851187 Assessment & Planning 290-2-5 10 (c) 101025641113133 Referral & Admission 290-2-5-.09 (2) (b) 090735031202137 Physical plant & Safety 290-2-5.18(9) 182945021366111 Health Services 209-2-5.12 (3)(a)1.(i) 120954861065119 Assessment & Planning 290-2-5-.10(d)1011647NR60NR80 Health Services 290-2-5.12(3)(5)1224745990NR61 Staffing 290-2-5-.08(6)8408411085NR87 Staffing-2-5-.8(6)2.08599417967108 Referral and Admission 290-2-5.09(2) (d)1 091110408948103 * As of Dec 31, 2010 NR-Not Ranked

4. Dropping Out Of 2011. 10 Most Cited CCI Rules Rules TAGProjected Ranking 2011 Times Cited 2011 Ranking 2010 Times Cited 2010 Ranking 2009 Times Cited 2009 Assessment & Planning 290-2-5-5-.10 (a) 1001NR3751084127 Record Keeping Personnel Records 290-2-5-.08(5)(d)2 831NR37NR629101 Record Keeping Personnel Record 290-2-5.08(5) (d) 6 835NR32NR511091 * As of Dec 31, 2010NR-Not Ranked

5. Summary of Improvement- CCI 200920102011  The rule set was changed to accommodate the Room Board Watchful Oversight (RBWO) standards in 2008.  An increase in citations was identified as licensed entities adjusted to the RBWO standards.  Minimal changes occurred in the top ten from 2008 to 2009. In 2009, only one (1) rule dropped from the 2008 list of the most cited.  Licensed entities improved in the area of Recordkeeping from 2009 to 2010.  The two (2) Recordkeeping rules that were listed in the top ten most cited in 2009, were no longer on the list in 2010.  An additional Staffing rule appeared on the list.  Thus far, one (1) of the rules in the area of Assessment and Planning is not appearing on the list. (As of December 31, 2010)  Since 2008, licensed entities continue to be cited in the same areas of the rule set: Assessment and Planning, Health Services, Physical Plant and Safety, Referral and Admission, and Staffing.

6. 10 Most Cited CPA Rules Rules TAGProjected Ranking 2011 Times Cited 2011 Ranking 2010 Times Cited 2010 Ranking 2009 Times Cited 2009 Agency Record & Reports 290-9-2-.08(6)1005122NR19NR13 Agency Policies & Procedures For Services 290-9-2.05(7)0525216725NR14 Foster Care Services Min Requirements 290-9-2-.07(5)(a)708233146311025 Agency Records & Reports 290-9-2-.08(6)(a-f) 1006412NR9 9 Foster Care Svcs BEH Mgt & Emer, Safety 290-9-2-.07(8)(b) 0869512531239 Foster Care Services Prior To Placement 290-9-2-.07(6)(a)0837612825631 Agency Personnel 290-9-2-.04(14)(b)0463711NR13NR15 Foster Care Services Min Requirement 290-9-2.07(5)(a)30819811137338 Foster Care Services Minimum Requirements 290-9-2-.07(5)(a)9.(ii) 0826911235730 Foster Care Services Prior To Placement 290-9-2-.07(6)(d)08411011NR18434 * As of Dec 31, 2010 NR-Not Ranked

7. Adding To 10 Most Cited CPA Rules In 2011 Rules TAGProjected Ranking 2011 Times Cited 2011 Ranking 2010 Times Cited 2010 Ranking 2009 Times Cited 2009 Agency Records & Reports 290-9-2-.08 (6)1005122NR19NR13 Agency Records & Reports 290-9-2-.08(6)(a-f)1006412NR9 9 Agency Personnel 290-9-2-.04(14)(b)0463711NR13NR15 Foster Care Services Prior to Placement 290-9-2-.07-(6)(d) 08411011NR18434 * As of Dec 31, 2010NR-Not Ranked

8. Dropping Out Of 2011. 10 Most Cited CPA Rules Rules TAGProjected Ranking 2011 Times Cited 2011 Ranking 2010 Times Cited 2010 Ranking 2009 Times Cited 2009 Foster Care Services Min Requirements 290-9-2-.07(5)(a)6 0822NR9332140 Foster Care Services During Placement 290-9-2.07(7)(a) 2 0847NR5431532 Foster Care Services Min Requirements 290-9-2-.07(7)(b)4 0851NR8924NR14 Foster Care Services Min Requirement 290-9-2-.07 (5)(a)9.(iii) 0827NR81023NR23 * As of Dec 31, 2010 NR-Not Ranked

9. Summary of Improvement- CPA 200920102011  All of the rules in the top ten most cited rule violations were in the area of Foster Care Services in 2008 and 2009.  In 2009, two (2) rules dropped from the 2008 list of the most cited.  In 2010, three (3) rules dropped from the 2009 list of the top ten most cited.  A rule from the area of Agency Policies and Procedures appeared on the list replacing one (1) of the three (3) that dropped from the list; the other two (2) replacements were also in the area of Foster Care Services.  Thus far, four (4) of the rules have fallen from the 2010 list of the top ten most cited. (As of December 31, 2010)  Since 2008, licensed entities have moved from being cited in the area of Foster Care Services alone; to additional areas of the rule set including Agency Records and Reports, Agency Policies and Procedures, and Agency Personnel.