New requirements could mean that the Council on Accreditation (COA) will no longer accredit adoption agencies to do international adoptions. That could have a devastating effect on programs around the world.
Anyone following international adoption knows that the numbers of adoptions have declined sharply in recent years. The reasons are many. The adoption agencies which are still operating must be accredited under The Hague Convention on Intercountry Adoption and in accordance with the Universal Accreditation Act (UAA). COA has for years been the only accrediting entity.
On October 6, 2017, COA sent the following letter to adoption service providers (ASPs):
As you know, the Department of State (the Department) is requiring COA to make significant changes in the nature and scope of our work in ways which will fundamentally change our responsibilities and role as an accrediting entity and which are inconsistent with COA’s philosophy and mission.
Additionally, we have serious concerns regarding the impact of these changes in terms of (a) the potential further reduction in the number of children who are afforded the opportunity of finding permanent homes in the United States by virtue of their countries of origin having found the activities underlying those changes to be an infringement of their sovereign rights or unduly burdensome; (b) the sustainability of small ASPs given the anticipated significantly increased accreditation fees and costs; and, (c) the capacity of prospective adoptive parents to pursue intercountry adoptions due to the pass through of these costs.
For more than 40 years, COA has been the leading accreditor of agencies providing child welfare services, including domestic and international adoption. We take these responsibilities very seriously. Accordingly, we have advised Assistant Secretary for Consular Affairs, Carl Risch, that these and other changed circumstances will render COA unable to perform its duties as an Accrediting Entity.
The next step will be for COA to meet with the Department to discuss a resolution. If one is not reached, we will continue to provide accreditation services during a 14 month transitional period after which our designation as an accrediting entity will end.
What does this mean for you? For now, please know that it is “business as usual”. COA will continue to perform all of its accreditation and monitoring and oversight activities.
Given our long relationship with the Department and the adoption community and our commitment to supporting intercountry adoption, this has been a very difficult decision. It was taken only after lengthy consultations with members of the COA board, our senior staff and most especially with Jayne and her team. She and they have been and are nothing short of amazing.
Thank you and have a great weekend.
President & CEO, Council on Accreditation
In July, the US State Department authorized a new accrediting entity for Hague Convention adoptions. This new entity does not have the years of experience that COA does, and COA has not been without its controversies and stumbling blocks. There are currently no other accrediting entities. If (and it’s a big if) COA no longer accredits adoption agencies, international adoption will be severely impacted.
The COA letter refers to increased costs and significant changes being required by the State Department. Among them could be this one: On October 5, 2017, the US State Department posted a “Foreign Supervised Provider Update.” The FAQ goes through the requirements that adoption service providers (ASPs) must adhere to in regard to their staff working in country. Agencies generally hire, for example, Ethiopians who speak English and Amharic (as well as perhaps other languages) to locate children who may need adoption, to translate documents, to file government forms, to assist adoptive parents, and other tasks involved in the adoption process in Ethiopia. The ASP is responsible for the behavior of their “foreign supervised providers,” (FSPs) who to my understanding are the people who help or facilitate the adoptions as opposed to those who are couriers, guards, or drivers, for example. To maintain accreditation, the ASPs must provide documentation to COA of their oversight of the foreign supervised providers.
If you read through the FAQ, it’s clear that the oversight isn’t always easy. Some FSPs are reluctant to disclose their fees or to sign documents about their services. My guess is that the requirements (which are not new) for FSPs have been difficult to implement, but may sometimes be part of the cause for fraud in adoptions; hence, the reason for the State Department to be ramping up the urgency that agencies comply.
I have no doubts that there are many other conversations occurring in regard to how to properly regulate international adoptions. It is an astonishingly complex task, one that has grown in complexity astronomically in the last decade or so. Adult adoptees are voicing concerns. Some advocate an end to intercountry adoption; many want to see much better accountability and transparency in the process. Adoptive and prospective adoptive parents are watching the global developments closely. Adoption agencies are contemplating and speculating on next steps. Child welfare experts in the US and in other sending and receiving countries are no doubt considering many options. There are growing movements to end orphanages. It’s quite the perfect storm for international adoption. Here’s hoping the voices of adopted people and of birth/first parents will be clearly sought out and heard.
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I filed a complaint with the COA about our adoption agency early 2011. It took them two years to respond, at which time they told me that my “allegations are unsubstantiated.” Several weeks ago, one of the heads of our adoption agency landed in Pensacola Federal Prison without parole until August 2018. The COA, as far as I am concerned, is worthless.