Regulatory Advocacy

Children and youth are impacted by several broad laws enacted at both the federal and state levels — laws which Congress and state legislatures entrust regulatory agencies to implement, oversee, and enforce. Regrettably, state and federal regulatory agencies do not consistently engage in appropriate implementation, oversight, and enforcement of these laws.  It is not enough for child advocates to win enactment of important statutory changes for children and youth. They must also be able to effectively advocate to ensure that those laws are implemented and enforced in a manner that ensures they have their intended impact. The devil is in the details, and a single phrase in a rule can mean that either one thousand or a hundred thousand children will receive public investment when needed. For that reason, one of CAI’s core activities involves advocacy before state and federal agencies that are charged with the implementation, interpretation, oversight and enforcement of laws that directly impact children and youth, particularly those foster care. Such regulatory advocacy, focusing on the rulemaking and related authority of such agencies, is an often ignored but very critical area of law.

The following are examples of some of CAI's efforts to ensure that state and federal agencies fulfill their mandates to implement and enforce laws, policies, and programs meant to serve and promote the interests of children and youth:

• CAI Issues Press Release on Final Report of Commission to Eliminate Child Abuse and Neglect Fatalities (Mar. 17, 2016)
• CAI Releases Statement on DHHS' Administration for Children and Family's Current Child Welfare Policy Manual’s Public Disclosure Provisions and the Impact on Future Issues of State Secrecy and Child Deaths in the U.S. (Nov. 19, 2015)
• CAI Coalition submits comments on regulations aimed at protecting the interests of private postsecondary students (including foster youth) (July 20, 2015)
• CAI Testifies Before National Commission to End Child Abuse and Neglect Fatalities: Testimony / Slides (July 15, 2015)
• CAI comments on ACF's revised policy interpretations of CAPTA's public disclosure mandate (June 26, 2015)
• CAI joins coalition in urging Secretary of Education to develop proactive, risk-based, student-centered strategy to prevent private for-profit educational institutions from putting students and taxpayers in jeopardy (June 3, 2015)
• CAI submits letter to Children's Bureau Associate Commissioner JooYeun Chang re CAPTA implementation (May 14, 2015)
• CAI submits comments to ACF's proposed AFCARS rules (Apr. 10, 2015)
• CAI Submits Comments to U.S. Department of Education's Proposed Rule on Gainful Employment (May 23, 2014)
• CAI Submits Comments to Children's Bureau on Proposed Changes to CFSR Process (May 22, 2014)
• CAI Comments on DHHS Proposed Regulations for Ensuring Medicaid to Age 26 for Eligible Former Foster Youth (Feb. 20, 2013)
• CAI joins new Step Up campaign, aimed at better supporting foster youth placed with relatives. (Feb. 19, 2014)
• CAI Comments on DHHS Proposed Regulations for Ensuring Medicaid to Age 26 for Eligible Former Foster Youth (Feb. 20, 2013)
• CAI Comments on Department of Social Services' Regulations Adding “Reasonable and Prudent Parent Standard” in Group Homes and Foster Parent Training Regulations (May 12, 2010)
• CAI Comments on Department of Social Services' Proposed Regulations on Foster Family Homes (June 15, 2009)
• CAI Comments on Victim Compensation Program Regulations (March20, 2009)
• CAI, the National Center for Youth Law, and the California Newspaper Publishers Association Submit Joint Comments on DSS' Proposed Rules Implementing SB 39 (Mar. 13, 2009)
• CAI Urges DHCS to Issue Reports (pdf) on Improving the CHDP Gateway and Creating the Prenatal and Newborn Hospital Gateways Without Further Delay (June 17, 2008)
• CAI Comments on Judicial Council's Proposed Juvenile Dependency Court Performance Measures (June 2008)
• CAI Comments on Judicial Council's Proposed California Rule of Court Implementing Portions of SB 39 (Migden) (June 2008)
• CAI Comments on California Blue Ribbon Commission on Children in Foster Care Draft Recommendations (May 2008) (BROKEN LINK)
• Children's Regulatory Law Reporter
• Links to Regulatory Advocacy Resources