I just read the proposed regulatory changes to international adoption accreditation within the United States and I have two thoughts:

  1. Working for the actual Secretary of State is SO much less exciting than working for Tea Leoni on Madame Secretary.
  2. Everything is easier if you never read the comments.

Here’s a quick rundown of the proposed changes:

  • More financial transparency within fees, salaries, and overhead costs. One of the hot buttons within this rule comes from the new exclusion prohibiting prospective parents from paying for pre-adoptive care before the adoption has been finalized. Some comments made to the official documents fear that by eliminating fees in pre-adoption care their future children will be denied treatment and help within orphanages. According to the state department, however, this change has been made to specifically make long-term treatment within orphanages a thing of the past:

“Where institutions can collect large fees for the care of a particular child, an incentive may be created to recruit children into institutions, while also providing a disincentive for expeditious processing of an adoption. These practices substantially increase the costs of adoption for prospective adoptive parents, and may result in a situation where an adoptive family pays for long-term care of a child who is not in fact eligible for intercountry adoption.”

  • Increased standards in obtaining medical and social histories for children waiting for adoption. This one seems pretty straightforward—and, shockingly, no comments seemed to have a problem with it.
  • Increased required education for prospective parents including training in trauma, characteristics of children who leave a home country for a new life, and for agencies to supply specific, direct points of contact for families in crisis after adoptions have been finalized. All of this training would be done before monies were paid to international agencies. Many, many of the comments submitted to the State Department were concerned with this item, citing fears that they would have to wait even longer for adoption success, and that they would just have to essentially go to a foster care class. My (jaded, cranky) point of view is more along the lines of “I’d rather you take an extra 20 hours of a lecture than you ‘rehome’ a kid that suffered trauma for which you were not prepared.”
  • (I saved the most complicated for last) Allowing for the DOS, in connection with the Department of Homeland Security, to require agencies wishing to work in (certain, unspecified) countries to have additional certifications that would “enhance existing protections in the intercountry adoption process.” The way I read this, it appears that DOS acknowledges that some countries can be, well, shady in their international adoption practices. And when dealing with a shady country, prospective parents may be forced to use an agency that has received extra certifications and has been recognized as legitimate in both America and said shady country. This does not appear to be a willy-nilly sort of recognition, and the responsibility to obtain said certifications would be solely the job of the agency. Here is where the comments go INSANE: Some agencies, possibly fearing a drop in fees and legitimacy, have sent their clients to comment in bulk that “what if you de-legitimize my agency and then my baby never comes?” (I am making this observation on the many comments using the same verbiage and referencing the same agencies) Again, my (cranky, jaded) POV has less sympathy for an agency and more sympathy for the parents being told that they might not get their forever family.

All in all, I think that the proposed regulatory changes are a step in the right direction toward ethical, informed, native-family-first adoption practices. And I think that government regulatory writers need a raise and a gift basket.



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