Public Comments on Proposed Regulations

From Ron Stoddart – President of SaveAdoptions

Dear Colleagues,

I’m sure you are aware that the Department of State has published proposed new and revised regulations governing our accreditation and operations.  Save Adoptions has prepared comments to these proposed regulations during the Public Comment period which ends January 19th.

We have linked our comments in the green box below, and I would encourage you to also provide your perspective on the impact of these regulations on your agency.  We believe that these proposed changes would impact you in a number of different ways, including:


  1. Prevent agencies from choosing which AE, should there be more than 1 AE
  2. Prevent agencies from offering support to orphanages when a child will be in extended care for an unexpected period of time
  3. Require agencies not only to have 2 month’s assets, but 2 months LIQUID assets (cant count property)
  4. Create confusing and complicated fee schedules which require estimates and increased record keeping without any clear purpose
  5. Require agencies to comply with foreign law, even when the foreign authority has granted an exception in the interest of child welfare
  6. Prevent agencies from heling with relative adoptions if they have received a waiver to operate without accreditation in that country
  7. Expand the definition of complaint to include informal or vague instances

For Adoption Agencies and Professionals

If you’d like to use our comments and analysis to help you to formulate your response (specific to your agency) to these new regulations, please read our comments to each CFR linked in the green box below.

Comments By SaveAdoptions

How To Post Your Comments?

To post your comments, you can go to the direct link below:

For Adoptive Parents and General Public

Anyone Can Comment, You Can Help

You don’t have to be an adoption professional to want to have your voice heard. If you are an adoptive parent, a prospective adoptive parent, or just an adoption advocate, these changes will impact you as well.  If you’d like to make a difference, we recommend the following script that you can paste, or make any changes as you wish.

Public Comment For Adoptive Parents

I am an adoptive parent and an advocate for international adoption. I am not an adoption professional and as such I don’t have intimate knowledge of each proposed additional regulation. However, I can see the big picture, which is that international adoption has decreased over 87% in the last 15 years.  In the last 3 years alone, over-regulation has been the primary reason why 41 adoption agencies have decided to close their doors or have been forced to close down.  That is nearly 30% of all adoption agencies gone in 3 years. Having fewer agencies will result in fewer children finding the permanent, loving family they deserve.  At this rate, and with your newly proposed additional regulations, it won’t be long before all international adoption agencies are gone. Now is the time to work together and pursue policy that will increase adoptions. My view of this situation isn’t my alone. In fact, US Senator, Roger Wicker from Mississippi addressed these concerns almost verbatim from the Floor of Congress in this video.   I am hereby second his demand that my tax dollars are spent to transition the Central Authority from the Department of State to a more receptive and more understand home such as the Department of Health and Human Services.  Or if an entire transition is not possible, I ask that the proposed second Accrediting Entity is hosted at the Department of Health and Human Services and that agencies can choose to be accredited through this entity if they so wish.  I demand that my tax dollars are spent in ways which will implement policies that will reverse this horrific trend.  My heart is for adoption and orphans and I am their advocate as they cannot speak for themselves. Thank you!

How To Post Your Comments?

To post your comments, you can go to the direct link below:

Senator Wicker Wants AE Hosted at Dept. of Health

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