At the beginning of May, 2019, we received a Facility Evaluation Report from Community Care Licensing Division (CCLD). This report repeats the previous claims that, based on their inspection of our school, they have determined that we are operating as an unlicensed facility.
This report claims that we have “not been cooperative” and have “consistently refused access to inspect” our campus. We think that it is incredibly ironic that they are accusing us of being uncooperative, considering how they have acted towards us over the years.
- We have met with CDSS on several occasions.
- Under no legal obligation, we allowed CCLD to return to our campus after their 2011 warrant expired to continue their investigation.
- We were confirmed in 2013 to be in compliance.
- We voluntarily met with CCLD in Sacramento in 2015 to address their concerns.
- We have repeatedly requested for CCLD to inform us of their specific concerns regarding anything RVCA is doing that they would consider to be a violation. They have never done so.
- We attempted on several occasions in 2018 to schedule meetings with CCLD, which they cancelled and refused to reschedule.
We feel that, as a private residential school outside of CCLD’s jurisdiction, we have been far more cooperative than required.
Our attorney has also expressed significant frustration with his dealing with them. They have refused to return his phone calls for unreasonable periods of time; provided incorrect phone numbers, email addresses, and fax numbers; refused to provide evidence that they are legally required to provide; and generally made the process of working with them incredibly difficult. In a phone call we had with our attorney, he said if he told us everything he’s had to deal with that we would “either laugh or throw our phone at the wall. Most likely the latter.”
We also requested an extension to file our appeal for the Administrative Review. Did CCLD respond to our request in a timely manner? Of course not! They waited until nearly the last day of our granted time period to respond. By this time we had already scrambled to get all of our paperwork and documents in order, assuming they were not going to grant our request. Also, during that time CCLD was refusing to respond to our attorney and giving him incorrect information, the $200 fine was accruing each day. By the time we received their report, the fine had reached $2,200. By the end of our administrative appeal deadline, the fines reached $6,000.
The report also claims that RVCA’s purpose is not “education only.” We believe that this is a biased and incorrect interpretation of the exemption for residential schools. Having the purpose of “education only” does not preclude our school from having a structured environment and rules based on biblical principles. Additionally, we believe it is inappropriate for CCLD investigators to make this claim, considering they did not fully review our student records. The room where we keep the educational records was locked. Not only did they not enter the room where all educational records are kept, they did not even ask to review them. The only files they reviewed were the student’s medical records.
The report also neglects to state that we do in fact have a valid affidavit from the California Department of Education. This further show their bias in not accurately representing our school and our due diligence to comply with the regulations.
The report also indicates that we are not exempt due to the students that we accept. As previously stated, we do not accept students who require community care services. We do not believe that a student on psychotropic medication, who has minor mental health issues, histories of behavioral problems, or histories of abuse is precluded from attending a residential school. We have a detailed profile to assist in disqualifying students who have severe issues who would require social services that we can not and do not provide. We also believe that a faith-based education is inherently beneficial for students with behavioral issues and/or past abuse or trauma. We do not accept students who are addicted to drugs or alcohol. If a parent indicates that their child may have a substance addiction, we require the child to receive rehabilitation before they are considered for enrollment. Health and Safety regulations do not stipulate that we cannot accept students with any of these issues. It only states that we cannot accept students who need social services. None of our students need or are provided social services.