This procedure letter provides information to public children services agencies (PCSAs), private child placing agencies (PCPAs) and private non-custodial agencies (PNAs) regarding required training on the topic of the reasonable and prudent parent standard.

With the passage of Public Law 113-183, effective September 29, 2015 there are new Federal training requirements regarding the reasonable and prudent parent standard. All foster caregivers and a minimum of one staff member of a residential facility are required to receive training on the reasonable and prudent parent standard.

Ohio law has also changed. Division (C)(1) of section 5103.162 of the Revised Code states "a foster caregiver shall use a reasonable and prudent parent standard when considering whether to authorize a foster child who resides in the foster home to participate in extracurricular, enrichment, and social activities."

ODJFS has implemented a rule change for pre-placement training for foster caregivers in rule 5101:2-5-33 of the Administrative Code requiring the standard to be included in the pre-placement training. This change was effective August 1, 2015. Also, changes were made to rule 5101:2-9-03 of the Administrative Code regarding the training for residential staff as referenced above. This rule was effective December 1, 2015.

Even though there was no rule change regarding existing foster caregivers, they still must be trained in the standard. If the caregiver has already been trained in the standard, they have met compliance with the Federal requirements. If they have not been trained in the standard, they must be trained in order to be compliant with Public Law 113-183. Also, in accordance with division (C)(1) of section 5103.162 of the Revised Code, foster caregivers must use the standard when making decisions concerning extracurricular, enrichment, and social activities of the foster child. This is best accomplished in consultation with the custodial agency to ensure compliance with county policy.

INSTRUCTIONS: The following chart identifies the material that should be removed from the Family, Children and Adult Services Manual (FCASM) and the material that should be added.