REFUGE HOUSE, INC.

PURPOSE:

To establish Refuge House's commitment to recruiting, developing, and retaining a diverse group of trauma-informed foster families capable of providing quality care for children awaiting placement, with specialized focus on T3C Basic Foster Family Home Support Services and applicable Add-On Services through comprehensive credentialing, ongoing support, and evidence-based retention strategies.

POLICY:

Believing a home is in the heart of every child, Refuge House strives to recruit, support, and retain a diverse group of foster parents to provide quality care for the vast needs of children awaiting placement. Our approach integrates recruitment with T3C credentialing requirements, ensuring that families we recruit can be successfully credentialed for T3C Basic Foster Family Home Support Services and applicable Add-On Services.

Refuge House does not work with biological parents; therefore, the Agency does not assist in identifying kin that can be a resource. Refuge House does not work with kinship unless they are licensed caregivers through our Agency. Refuge House does not offer aftercare services due to contract limitations, except as required for T3C Service Packages.

CORE REQUIREMENTS:

1. Recruitment Philosophy and Approach

Refuge House utilizes multiple recruitment strategies to identify and engage prospective foster families from diverse socioeconomic, ethnic, and cultural backgrounds. Our recruitment efforts focus on families who can provide trauma-informed care using TBRI® principles and who have the capacity to be credentialed for T3C service delivery.

Recruitment Methods:

1. Collaborative Regional Recruitment Meetings – consortium of agencies within a region working together with the State to recruit foster families

2. Church Recruitment Efforts – through engaging our faith-based community, Refuge House works at developing partnerships through speaking to congregations, small groups, and Sunday school classes

3. Community Engagement Efforts – through educating our community on the vast needs of foster children, Refuge House works at making presentations to Home Owner Associations, Fitness Associations, and engaging community leaders and other local groups while using compelling and engaging presentations that give a true call to action

4. Relationship Based Recruitment – through word of mouth of our existing foster families, personnel, foster care workers, alumni, donors, along with friends and families

5. Target Specific Recruitment – through understanding the needs of the children, Refuge House works to recruit for children who are difficult children to place such as teenagers, infants, and those with challenging behaviors and medical needs. Refuge House accomplishes this by speaking to Nursing Organizations, Police and Detention Center Staff and Stay at Home Mom groups. Target specific recruitment also attempts to recruit families associated with tribes in case an Indian child is placed within our Agency. Refuge House wants every child to feel comfortable and free to be themselves while in care

6. Inbound Marketing – through strategic Internet placement and search-engine presence, Refuge House draws its virtual community to our website, with a social-media presence carrying trauma-informed-care messaging

7. Joint Information Meetings (JIMs) and Public Orientations – Refuge House hosts or participates in JIMs and public orientations conducted in a culturally responsive and accessible manner; all are listed on TARE, the Heart Gallery, and the Refuge House website, with ASL/interpretation services and accessible materials provided on request

T3C Integration: Whatever method of recruitment used, Refuge House incorporates information about T3C service requirements, TBRI® training expectations, and the enhanced support available to families providing T3C services. Recruitment materials and presentations include clear information about T3C credentialing requirements and the specialized nature of trauma-informed care.

Annual Recruitment Plan (DFPS-required): Home Development and the Executive Director develop, review, and update a written Annual Recruitment Plan addressing the nine required components: (1) faith-based outreach; (2) targeted/child-specific recruitment for hard-to-place children (teens, infants, sibling groups, challenging behaviors, complex medical needs, IDD/Autism Spectrum Disorder, pregnant/parenting youth); (3) tribal recruitment for ICWA-eligible children; (4) geographic and ethnic diversity targeting (rural counties identified by DFPS removal data); (5) LGBTQIA+-supportive home recruitment; (6) bilingual (including Spanish-speaking) home recruitment; (7) compliance with MEPA, IEPA, ICWA, ASFA, and the Adam Walsh Act; (8) review of the Foster Care Needs Assessment Report and SSCC capacity-gap data; and (9) outcome data tracked by zip code/county. The Plan is submitted to the contracting SSCC and DFPS as required, and recruitment outcomes are presented to the Board at least annually.

Recruitment prohibition — no solicitation of other CPAs' verified families (RCC §1220): Refuge House ensures that "its staff, volunteers, subcontractors, authorized agents, or any affiliated entities will not contact the verified family of another CPA for the purpose of recruitment or transfer of a foster home" (RCC §1220). This prohibition sits alongside — and does not conflict with — Refuge House's acceptance of transfer families (see Definitions): a transfer family who approaches Refuge House on their own initiative may be accepted and processed, but Refuge House does not initiate contact with, target, or solicit another CPA's verified families through any recruitment method above.

Nondiscrimination & federal compliance: Recruitment, screening, and selection comply with the Multiethnic Placement Act (MEPA), the Interethnic Adoption Provisions (IEPA), the Indian Child Welfare Act (ICWA), the Adoption and Safe Families Act (ASFA), and the Adam Walsh Child Protection and Safety Act.

Geographic proximity: Refuge House tracks the proximity of each placement to the child's removal address against a 50-mile geographic-proximity goal (Refuge House goal; to be re-cited to the strictest applicable SSCC standard upon verification — the prior TFCN attribution was removed as prospective/no executed contract).

2. Initial Contact and Engagement Process

Upon initial contact from prospective foster families, Refuge House provides comprehensive information about foster care requirements, T3C service expectations, and begins the assessment process that will ultimately lead to both DFPS licensing and T3C credentialing. Inquiry intake operates 24 hours per day, 7 days per week, 365 days per year (OCOK strictest standard); a designated Recruitment Team Member (or on-call equivalent) responds to every inquiry, provides culturally responsive written information at first contact, forwards initial paperwork immediately, and completes follow-up contact within 72 hours of initial contact.

Information Sharing: Refuge House calls upon current families, emancipated youth, personnel, stakeholders, and partners to speak, answer questions, and train those we are attempting to recruit, providing them with a physical connection to our Agency. This personal approach helps prospective families understand both the challenges and rewards of providing T3C-level care.

Initial Paperwork and Assessment: The process begins with comprehensive paperwork that serves both DFPS licensing requirements and T3C credentialing assessment, including:

1. Welcome letter from the CEO
2. Application
3. Request for Criminal History/FBI
4. Release of Information from current/previous agency (if applicable)
5. Family Profile
6. Physical Exam form and instructions
7. Notarized affidavit
8. Summary of foster family home requirements
9. Schedule of all Pre-Service Training Required
10. All required pre-assessments

Assessment Tools for T3C Readiness: The following assessments help evaluate both DFPS licensing requirements and T3C credentialing potential:

1. Available Time Scale
2. Personal Dedication to Fostering Scale
3. Reasons for Fostering Checklist
4. Cultural Competence Scale
5. Foster Parent Role Performance Scale
6. Parenting Acceptance Scale
7. Receptivity to Birth Family Connections Scale
8. Willingness to Foster Scale

3. Pre-Service Training Integration

Refuge House conducts comprehensive pre-service training that meets both DFPS requirements and T3C credentialing expectations. Training includes foundational foster care education as well as specialized trauma-informed care components.

Core Training Components:

1. RH 101 - Orientation (2 hours) - Agency-specific orientation including T3C service overview
2. Mini-PRIDE (12 hours) - Core foster care training
3. SAMA (Behavioral Management) (16 hours initial, 8 hours annual) - De-escalation and behavior management
4. Psychotropic Medications (2 hours) - Medication management for children in care
5. Transportation Training (2 hours) - Safety and legal requirements
6. First Aid/CPR (2-4 hours) - Emergency response certification
7. Water Safety (1 hour minimum, if necessary) - Pool and water safety
8. Developmental Milestones (2 hours) - Child development education
9. On-Line Medical Consent (1 hour) - Medical decision-making training
10. Medical and Rehabilitation Intervention Training (1 hour, if necessary) - Specialized medical care

T3C-Specific Training Requirements: All prospective families must complete additional training to support T3C credentialing:

1. TBRI® Training - Evidence-informed treatment model training
2. Universal Human Trafficking Prevention - Required for all T3C families
3. T3C Orientation and Vision - Understanding T3C transformation and benefits

4. Support and Retention Services

Refuge House was founded on the idea that the Agency works to be family advocates and in turn our families serve as child advocates. To maintain an adequate number of families to meet the needs of children placed within Refuge House, special attention is made to support our families through multiple retention strategies.

Support Strategies:

1. How a placement starts is how a placement will end - Refuge House believes that the more time our case managers spend placing a child and reviewing all the documentation with the family results in stability throughout the span of the placement

2. Availability - Refuge House ensures that four levels of personnel including Case Manager, Treatment Manager, Treatment Director, and CEO are available 24/7 to all caregivers for emergencies and non-emergency calls. Multiple contact methods are provided including office & cell phone, text messaging, e-mail, instant messenger, community page, and Face Time or Skype

3. On-going training - Required by the state and key to long-term success of caregivers. Knowledge is power, and understanding this, Refuge House created the RHU training model to streamline training and create something the families would consider important and feel a part of

4. Events and socials - One or two events per year for all caregivers, personnel, and children to get together. Examples include Blueberry and Blackberry picking, roller-skating, minor league baseball games, etc. A family who plays together stays together

5. Holiday support - Christmas support through gift provision ($150 to $500 spent per child), allowing families to give these gifts to children as if they are from them or from "Santa"

6. Community room on website - Secure space for caregivers to create profiles, share information, read blogs from the Agency, support each other through chat room discussions, and share photos

7. Resource links on Website - Additional support beyond traditional case management

8. Regular and Frequent visitation - Case managers provide twice monthly home visits, assistance with transportation to and from visits, court and other appointments, and attend all psychiatric appointments

9. Radius - Secure access to child's record through remote desktop services, providing security and accessibility

10. Teamwork - Foster parent involvement in treatment and service planning, empowering them and encouraging focus on child's goals and permanency plan

11. Staff Training - Retention of caregivers comes through staff development, ensuring knowledge and up-to-date information on trends and interventions

12. Peer mentoring - New foster parents are matched with tenured foster parents for support during the initial process, typically spending 40 hours with a tenured family before verification

13. Regular and routine breaks - Mini-Break reimbursement and Intermittent Alternative Care, providing paid breaks, weekenders, in-home substitute care, and babysitting for toddlers and infants

14. Caregiver detox sessions - Time for foster parents to vent and receive support without fear of judgment and retaliation

15. Community and Extended Family Support - Reaching out to support systems including family, church, and other organizations they may be involved in, including tribal representatives when applicable

16. Recreation - Family activities that require time together such as walks, biking, hiking, camping, etc.

17. Responsiveness - All missed phone calls returned within 24 hours to all caregivers if not an emergency, with same standards for e-mails

18. Emergency Responsiveness - 24/7 availability during emergencies, with protocols for runaways, sexually acting out behavior, physical altercations, theft, property damage, communicable disease, serious illness, death, divorce, etc.

19. Annual Evaluation - Feedback and quality control process including annual home study updates, standard requirements compliance review, investigations and citations review, and documenting trends and patterns for strengthening support

T3C-Specific Retention Elements: Enhanced support recognizes the additional requirements and complexity of T3C service delivery:

1. T3C Credentialing Support - Ongoing assistance with maintaining T3C credentials and competencies
2. TBRI® Coaching and Consultation - Regular support for implementing trauma-informed practices
3. Specialized Training Opportunities - Advanced training in trauma-informed care and specialized populations
4. Enhanced Case Management - Additional support for complex service coordination and documentation requirements

Written Foster Family Communication Plan (RCC §2110): Refuge House develops and implements a written foster family communication plan for disseminating information to its foster families; the communication practices described in this policy (Support Strategies 2, 6, 7, and 17 above) and in FC-RR-01.1 constitute the plan's delivery machinery. Per RCC §2110, the plan is available to CPS upon request and includes, at a minimum, the specific type of information provided, including but not limited to:

1. Updates to the Minimum Standards and residential contracts (RCC §2110) — distributed via RHU training updates and agency notices;
2. Notices from DFPS (RCC §2110) — relayed on receipt through the communication methods below;
3. Available training opportunities (RCC §2110) — the RHU training calendar and specialized/T3C training announcements;
4. How often the information will be provided, including routine and emergency notices (RCC §2110) — routine information at least monthly (case-manager visits, community page, e-mail) and emergency notices immediately via the 24/7 contact channels (phone, text/SMS, e-mail);
5. Methods for providing the information through Telecommunication or other appropriate means (RCC §2110) — office and cell phone, text messaging, e-mail, the secure website community room, the Foster Parent Portal, and Pulse notifications; and
6. Processes for evaluating the implementation of any required actions that must be taken in accordance with communication-plan notices (RCC §2110) — follow-up at the next home visit and the annual evaluation (Support Strategy 19), with completion documented in Radius.

Materials Provided to Foster Families (RCC §§2210–2220):

1. Texas Health Steps (RCC §2210): Refuge House distributes Texas Health Steps materials (from the Texas Health Steps Resource Catalog website) to verified foster homes, sending the following items to each foster home at least annually: Don't Miss a Beat brochure EPSDT-05; Checkups Help Children Stay Healthy EPSDT-08; Good Health Takes More Than an Apple a Day EPSDT-16; and Case Management CM1-182. (RCC §2210)
2. Medicaid Medical Transportation Program (RCC §2220): Refuge House distributes information about the Medicaid Medical Transportation program (Medical Transportation Brochure, English/Spanish, from the Texas Health Steps Resource Catalog website) to its foster homes. (RCC §2220)

Implementation guidance. The annual Texas Health Steps brochure set and the Medical Transportation brochure are planned as a dated annual Pulse task per home; until built, Home Development sends the set with the annual home-study update packet and documents the send date in Radius.

5. ☑ Kinship Caregiver Support Services - Recruitment and Retention

For families providing Kinship Caregiver Support Services, specialized recruitment and retention approaches recognize the unique dynamics of relative caregiving relationships.

Kinship-Specific Recruitment:

1. Relationship-Based Outreach - Targeting existing family networks and relative connections
2. Benefit Education - Information about state and federal benefits available to kinship caregivers
3. Verification Support - Enhanced assistance with expedited licensing processes
4. Cultural Competency - Understanding of family dynamics and cultural considerations

Kinship Retention Support:

1. 24/7 Availability - Immediate response capability for kinship caregiver crises
2. Flexible Service Delivery - Weekend and after-hours support as needed
3. Benefit Assistance - Ongoing support with TANF, Kinship Care payments, and other programs
4. Family Mediation - Support for complex family relationship dynamics

6. ☑ Transition Support Services - Recruitment and Retention

For families supporting youth receiving Transition Support Services, recruitment focuses on families capable of supporting independence preparation and post-secondary planning.

Transition-Focused Recruitment:

1. Experience-Based Targeting - Recruiting families with experience supporting transitioning youth
2. PAL Program Integration - Families willing to participate in Preparation for Adult Living activities
3. Independence Preparation - Families committed to life skills development and transition planning

Transition Retention Support:

1. PAL Program Coordination - Enhanced case management for transition activities
2. Life Skills Training - Additional training for families on independence preparation
3. Extended Relationship Building - Support for maintaining connections beyond placement

7. ☑ Pregnant & Parenting Youth Support Services - Recruitment and Retention

For families supporting pregnant and parenting youth, specialized recruitment targets families capable of dual-generation support.

Dual-Generation Recruitment:

1. Parenting Experience - Targeting families with infant and child care experience
2. Resource Coordination - Families willing to coordinate multiple services for two generations
3. Parenting Support - Families committed to supporting young parent development

Dual-Generation Retention:

1. Parenting Education - Enhanced training in supporting young parents
2. Resource Coordination - Additional case management for dual-generation needs
3. Extended Support - Recognition of the complexity of dual-generation care

8. ☑ Mental & Behavioral Health Support Services - Recruitment and Retention

For families providing Mental & Behavioral Health Support Services, recruitment focuses on therapeutic parenting capabilities and crisis management skills.

Mental Health-Focused Recruitment:

1. Therapeutic Experience - Targeting families with mental health, counseling, or therapeutic foster care backgrounds
2. Crisis Management Skills - Families demonstrating calm under pressure and de-escalation abilities
3. 24/7 Availability - Families committed to round-the-clock availability for mental health crises
4. Professional Boundaries - Understanding of therapeutic relationships and maintaining appropriate boundaries

Enhanced Mental Health Retention Support:

1. Clinical Supervision - Monthly clinical consultation with licensed mental health professionals
2. Crisis Support Line - 24/7 access to clinical backup for behavioral emergencies
3. Respite Priority - Enhanced respite services recognizing the intensity of mental health placements
4. Trauma-Informed Training - Ongoing advanced training in trauma responses and therapeutic interventions
5. Secondary Trauma Support - Regular debriefing and self-care resources for caregivers
6. Behavioral Documentation Support - Training and tools for maintaining detailed behavioral records

9. ☑ Intellectual or Developmental Disability (IDD)/Autism Spectrum Disorder - Recruitment and Retention

For families supporting children with IDD/Autism, recruitment targets those with developmental disability experience and structured caregiving approaches.

IDD/Autism-Focused Recruitment:

1. Developmental Experience - Targeting families with special education, therapy, or disability services backgrounds
2. Communication Flexibility - Families comfortable with non-verbal communication and alternative methods
3. Structured Approach - Families who thrive with routines, visual schedules, and predictability
4. Medical Comfort - Families willing to manage complex medical needs and equipment

Specialized IDD/Autism Retention Support:

1. Behavioral Consultation - Monthly behavioral specialist support for plan development and adjustment
2. Educational Advocacy - Intensive support for IEP/ARD meetings and school coordination
3. Therapy Coordination - Assistance with OT, PT, speech, and ABA therapy scheduling
4. Medical Support - RN consultation for complex medical needs and equipment training
5. Sensory Resources - Access to sensory tools, weighted blankets, and environmental modifications
6. Parent Networking - Connections with other IDD/Autism foster families for peer support

ADDITIONAL INFORMATION:

Foster Family Home Credentialing Integration: The recruitment and retention process serves as the foundation for T3C Foster Family Home credentialing as detailed in FC-T3C-01 T3C Basic Foster Family Home Support Services Policy. Families recruited through this process will be assessed for T3C credentialing capability, ensuring seamless transition from recruitment to service delivery.

Quality Assurance: Regular evaluation of recruitment effectiveness and retention rates ensures continuous improvement in both attracting appropriate families and supporting their long-term success. Annual retention analysis includes placement stability, family satisfaction, and T3C credentialing success rates.

Documentation: All recruitment activities, family assessments, and retention support services are documented in Radius to support both DFPS licensing requirements and T3C credentialing processes.

DEFINITIONS:

Caregiver – A person counted in the child/caregiver ratio, including employees, foster parents, foster home staff, contract service providers, volunteers, and others whose duties include direct care, supervision, guidance, and protection of a child in care. This includes any person that is solely responsible for a child.

Mini-Break Provider – A person or couple who provides temporary relief through breaks to other foster families. A mini-break provider must be a verified foster parent current and up to date on all training. During mini-breaks, foster child(ren) are cared for in or out of the home of the mini-break provider. If care to a child is provided in the home of the mini-break provider, the home must meet all the same requirements as a verified Refuge House foster home, including home study, etc.

In-Home Substitute Caregiver – A person who provides substitute care in another Refuge House foster home. Must be 21 years of age and meet specific qualifications including valid driver's license, good driving record, cleared background checks, doctor approved physical health release, completed application, clear TB screening, 3 references, notarized affidavit, no major life change within the last 12 months, valid driver's license and auto liability insurance, signed and approved Substitute Caregiver Agreement and Job description, and successful completion of all required training.

Intermittent Alternative Care Provider – A verified Refuge House foster care provider who may or may not have children in the home. Intermittent child care placement lasts more than 72 hours and up to 14 days.

Transfer family – A transfer family is considered a foster parent(s) who is currently verified with another organization providing the same service that are looking to become part of Refuge House. A foster parent(s) must be currently active to qualify as a transfer family. A transfer family is accepted only when the family initiates the contact; Refuge House staff, volunteers, subcontractors, authorized agents, and affiliated entities do not contact the verified family of another CPA for the purpose of recruitment or transfer of a foster home (RCC §1220).

Foster Home Staff – Home staff is considered an employee not of Refuge House but that of the foster parent(s).

Babysitter – A babysitter is not considered a caregiver unless the babysitter is a verified foster parent or Refuge House employee. A babysitter cannot care for any child(ren) or young adult longer than 8 hours nor overnight.

T3C Credentialing – Process to assess and approve individual foster homes to provide specific T3C Service Package services beyond basic DFPS licensing.

TBRI® – Trust-Based Relational Intervention®, the evidence-informed treatment model used for T3C services.

Mental & Behavioral Health Support Services – Specialized T3C service package for children with significant mental health needs requiring therapeutic parenting, crisis intervention, and intensive behavioral support.

IDD/Autism Spectrum Disorder Support Services – Specialized T3C service package for children with intellectual or developmental disabilities and/or autism requiring specialized communication strategies, behavioral supports, and developmental interventions.

REFERENCES:

• T3C Blueprint Standards: Pages 47-55 (T3C Basic Foster Family Home); Pages 78-93 (Mental & Behavioral Health); Pages 123-135 (IDD/Autism); Pages 149-151 (Transition Support); Pages 154-158 (Kinship Support); Pages 159-161 (Pregnant & Parenting Support)
• TAC Chapter 749: Foster Family Home Minimum Standards
• DFPS 24-Hour RCC Requirements (FY26) — §1220 (recruitment prohibitions), §2110 (communication plan), §2210 (Texas Health Steps materials), §2220 (Medicaid Medical Transportation Program)
• FC-T3C-01 T3C Basic Foster Family Home Support Services Policy
• Enhancement Requests for Credentialing Application

SSCC alignment (FY-26): Reviewed against the 2INgage Provider Manual Rev. 1.2026; aligned — 2INgage provider-specific provisions were captured in the prior reconciliation pass; no further changes required. Cross-reference: FC-CQI-01 Continuous Quality Improvement Policy; FY-26 SSCC coverage tracker (temporary-reference/fy26-sscc-joint-monitoring/sscc-alignment/).

SSCC alignment (FY-26) — EMPOWER: EMPOWER Provider Manual Rev. 1.2026 — aligned (parallel template to 2INgage); EMPOWER provider-specific provisions captured in the EMPOWER pass; no additional changes required. Cross-reference: FC-CQI-01 Continuous Quality Improvement Policy; FY-26 SSCC variance matrix.

SSCC alignment (FY-26) — OCOK: OCOK Network Management Operations Manual Rev. 7-1-2025 — reviewed; OCOK provider-specific provisions are carried in the companion procedure/policy (see the FY-26 SSCC variance matrix). Cross-reference: FC-CQI-01 Continuous Quality Improvement Policy; FY-26 SSCC variance matrix.

SSCC alignment (FY-26) — 4Kids: 4Kids4Families Joint Operations Manual (Dec 2025) / Subcontractor Agreement — reviewed; 4Kids provider-specific provisions carried in the companion procedure/policy (see the FY-26 SSCC variance matrix). Cross-reference: FC-CQI-01 Continuous Quality Improvement Policy; FY-26 SSCC variance matrix.

SSCC alignment (FY-26) — Belong: Belong Stage I & II Provider Manual (Aug 2025) / Provider Services Agreement — reviewed; Belong provider-specific provisions carried in the companion procedure/policy (see the FY-26 SSCC variance matrix). Cross-reference: FC-CQI-01 Continuous Quality Improvement Policy; FY-26 SSCC variance matrix.

SSCC alignment (FY-26) — SFCS: SFCS Placement Provider Manual (July 2020, publicly-sourced) / 2019 Affiliate Provider Agreement — reviewed; SFCS provider-specific provisions carried in the companion procedure/policy (see the FY-26 SSCC variance matrix). Cross-reference: FC-CQI-01 Continuous Quality Improvement Policy; FY-26 SSCC variance matrix.

RELATED PROCEDURES:

• FC-RR-01.1 Recruitment and Retention of Foster Families Procedure
• FC-T3C-01 T3C Basic Foster Family Home Support Services (Comprehensive Snapshot — canonical; standalone procedure consolidated)
• FC-CRED-01.1 Foster Family Home Credentialing Procedure
• FC-17.1 Home Studies Procedure
• RH Training and Development Procedures

FORMS/ATTACHMENTS:

• List of Required Pre-Service and On-Going Training
• RH Discipline Policy & Agreement
• RH Protocols for Responding to Emergencies
• Foster Family Home Credentialing Assessment (FC-CRED-01)
• Initial paperwork package (welcome letter, application, background check forms, etc.)
• Assessment tools (Available Time Scale, Personal Dedication to Fostering Scale, etc.)
• Training certificates and documentation
• Retention support documentation
• Mental Health First Aid certification requirements
• IDD/Autism-specific training documentation

This policy document establishes the governing principles for Recruitment and Retention of Foster Families. The corresponding procedure document (FC-16.1) operationalizes these principles by providing specific implementation details (who, when, where, and how). While policies require Board approval and remain relatively stable, procedures may be updated by the Executive Director to adapt to regulatory changes, technological advancements, or operational improvements without requiring Board approval, provided such changes maintain alignment with the policy's intent.