Rules and Regulations of the Rhode Island Training School (214-RICR-60-00-1)

This is not about minimizing public safety or excusing harm. It is about naming the purpose clearly: to ensure that every young person entrusted to the State’s care leaves better educated, healthier, and more prepared to contribute to community life. A development centered name affirms that purpose and holds the system accountable to it. On behalf of my organizations and as a professional committed to improving outcomes for young people and families, I respectfully urge your office to approve the name change and help Rhode Island continue to model a modern, developmentally appropriate approach to youth services. I am confident this action will strengthen stakeholder trust, reinforce staff professionalism, and, most importantly, honor the promise we make to the youth we serve.

I fully support the proposed rule change. Changing the name from the Division of Correctional Services to the Division of Youth Development is better aligned with Section 1.1 of the Rules and Regulations of the RI Training School, which states that youth are to “receive suitable treatment, rehabilitation and care in the least restrictive environment.” To fulfill this purpose, the name of the division should reflect that focus. This change is also consistent with modern scholarship on the justice system and youth development. Research shows that when justice systems align with adolescents’ developmental stages and ongoing brain development, youth are more likely to experience positive growth and better long-term outcomes that benefit both young people and the community (1). Emphasizing development rather than correction reinforces this evidence-based approach. Please implement this proposed rule change. 1. Cavanagh, C. (2022). Healthy adolescent development and the juvenile justice system: Challenges and solutions. Child Development Perspectives, 16(3), 172–178.

Please see my letter for the Youth Development Center name change.

• Youth Development Center Public Hearing.docx

Elise Wills Warwick, Rhode Island [email protected] February 18, 2026 Office of the Secretary of State State of Rhode Island Re: Public Comment Regarding Proposed Name Change to “Juvenile Corrections” Dear Secretary of State and Honorable Decision Makers, I am writing as a Rhode Island resident and a member of the Providence Alumnae Chapter of Delta Sigma Theta Sorority, Inc. to express my opposition to the proposed name change from the Division of Youth Development to Juvenile Corrections. This issue matters to me being a former worker at DCYF because names communicate values. They influence how systems operate and how young people understand their place within them. The term “Youth Development” reflects an approach centered on guidance, accountability, education, and growth. The term “Juvenile Corrections” reflects a framework rooted in punishment and control. These are not the same, and the difference has real consequences. Rhode Island’s decision to adopt a youth development model signaled progress toward a system that recognizes young people as capable of learning from mistakes and moving toward productive futures. Returning to correctional language risks reversing that progress and sending a message that punishment, rather than rehabilitation, is the primary goal. Many young people involved in the juvenile legal system have faced challenges such as trauma, unstable housing, unmet mental health needs, and limited access to educational supports. Addressing these challenges requires care, structure, and opportunity, not labels that reinforce stigma at a formative stage of life. This proposed change also raises concerns about fairness and equity. Across the country and here in Rhode Island, youth of color are more likely to be involved in the juvenile legal system. Language that emphasizes “corrections” rather than development risks deepening existing disparities and undermining efforts to create more just and equitable systems. As a member of Delta Sigma Theta Sorority, Inc., an organization committed to public service and the well-being of children and families, I believe Rhode Island should continue moving forward rather than returning to outdated terminology. Maintaining the Division of Youth Development name reflects a commitment to accountability, dignity, and the belief that young people can and do change. I respectfully urge you to reject the proposed name change and to preserve a system identity that prioritizes growth, responsibility, and hope. Thank you for your time and for considering my perspective. Sincerely, Elise Wills Member, Providence Alumnae Chapter Delta Sigma Theta Sorority, Inc.

Comments Regarding Proposed Changes to Rules and Regulations of the Rhode Island Training School (214-RICR-60-00-1) February 19, 2026 Kelsey Bala, Senior Policy Associate Rhode Island KIDS COUNT Thank you for the opportunity to review and provide comments on the proposed revisions to the Rules and Regulations of the Rhode Island Training School. We believe the proposed revisions are an important step to maintain the dignity of the youth served by this division. We strongly support this amendment that updates the division title referenced throughout the regulation from “Division of Juvenile Correctional Services” to “Division of Youth Development.” We recognize the purpose of the amendment is to align the name with their established mission. In recent years, we have seen many other partners make the important decision to update outdated language. In 2024, the National Juvenile Justice Network updated their name to the National Youth Justice Network and cited a similar rationale – the term juvenile is regressive and does not reflect their work to empower youth. In the 2025 Rhode Island KIDS COUNT Factbook, we changed the name of our youth justice indicator from “Youth in the Juvenile Justice System” to “Youth in the Justice System.” It may seem like a small change, but the language we use to talk about our children matters, and our words carry immense weight. There are negative connotations attached to the word “juvenile”, and while the term stems from a legal distinction, its current subtext strips away the dignity of our youth, and disproportionately Youth of Color. We want the words we use to empower youth who are caught up in different systems. When we use the word youth or child, or address someone by their name, it is humanizing. The last thing we would want is for kids who are caught up in these systems not to have that part of them centered. Rhode Island KIDS COUNT is in strong support of this name change for the Division of Youth Development. We advocate for the best interest of children using data and research. It is our job to review proposed regulations and legislation and advocate to prevent changes that could harm children and to encourage changes that would support children’s health, safety, and development. Thank you for your commitment to updating and improving this regulation. Please do not hesitate to contact us with any questions.

• Statement In Support of RITS Regulatory Change_Feb 19, 2026_RIKC.docx

To Whom It May Concern, I submit this public comment in strong opposition to the proposed return to the term “Juvenile Correctional Services” and in full support of maintaining the name Division of Youth Development. As a superintendent who works daily with young people facing significant barriers, trauma, and systemic inequities, I know firsthand that language is not symbolic, it is structural. The words we use shape policy, practice, expectations, and outcomes. The transition to “Youth Development” reflected an intentional shift toward rehabilitation, education, accountability with support, and belief in young people’s capacity to grow. It aligned Rhode Island with evidence-based approaches that recognize adolescents as developing individuals, not fixed identities defined by mistakes. Returning to “correctional” language sends the wrong message. It reinforces stigma. It centers punishment over possibility. It risks undermining years of progress toward a more humane, effective, and responsible system. Young people in state care are students. They are learners. They are future workers, parents, and community members. They deserve systems that reflect that reality. As an educator and public servant, I am deeply concerned that reverting to outdated terminology will weaken our commitment to rehabilitation and long-term public safety. Developmental, restorative, and educational approaches work. Correctional framing does not. This is not about political correctness. It is about outcomes, dignity, and responsibility. I urge decision-makers to reject this proposed change and to affirm Rhode Island’s commitment to youth development, growth, and opportunity. Our young people deserve nothing less. Respectfully, Simona Simpson-Thomas Superintendent Highlander Charter School

Submitted by: Jon Morel Date: February 13, 2026 Council 94 Local 314 Member Juvenile Program Worker at the RI Training School Division of Juvenile Correctional Services ____________________________________________________________________________________ To the Rhode Island Secretary of State and Decision-Makers: As a proud member of Council 94 Local 314—the union representing workers in the Division of Juvenile Correctional Services (DJCS) at the Rhode Island Department of Children, Youth & Families (DCYF)—I strongly OPPOSE the proposed change of our division's name to "Division of Youth Development" (DYD). This change is unnecessary and would seriously harm our daily work, our ability to recruit and retain dedicated staff, and overall public safety. Why the Change Is Not Needed: The current name, "Division of Juvenile Correctional Services," accurately and clearly reflects our mission: providing secure correctional care and rehabilitation services for youth involved in the juvenile justice system. It aligns with Rhode Island statutes and the reality of our responsibilities, which center on safety, structure, accountability, and evidence-based rehabilitation. DCYF has provided no evidence that the existing name creates any problems or that a new name would produce better outcomes for youth. This appears to be a cosmetic change with no meaningful benefit. Harm to Our Facilities and Operations: Renaming our division would undermine the focus and effectiveness of our secure facilities. Our work requires managing controlled, structured environments with firm rules to ensure safety and behavioral accountability. The current name reinforces that correctional mission for staff, youth, and the public. Switching to "Youth Development" makes our facilities sound like typical community-based youth programs, which could dilute our emphasis on security, create confusion, and increase risks to both staff and the youth in our care. Harm to Hiring and Retaining Staff: This name change would make it significantly harder to attract and keep qualified employees—something we are already struggling with. Hiring — The current name clearly signals that we are seeking professionals with training and experience in corrections, crisis intervention, de-escalation, and juvenile justice. It attracts candidates prepared for the demands of secure settings. A "Youth Development" title would likely draw applicants expecting softer, non-correctional roles (such as after-school programs or community outreach), resulting in poor job fits, high turnover, and persistent vacancies. Retention — As frontline correctional professionals, we take pride in balancing rehabilitation with firm safety and accountability measures. Changing the name could make us feel our specialized skills and hard work are being devalued or erased, damaging morale and pushing more colleagues to leave. In the middle of ongoing staffing shortages, this would worsen an already critical situation. Legal and Procedural Violations: DCYF began using "Division of Youth Development" without following required state procedures. In December 2025, our union issued a formal "Cease and Desist" letter demanding they stop the unauthorized use and restore the correct name across all documents. We cited the Rhode Island General Laws § 42-35 (Administrative Procedures Act), which mandates a formal rulemaking process for such changes. DCYF disregarded this requirement. Our union has filed an Unfair Labor Practice charge because the agency made this unilateral change without bargaining with us. We are also pursuing legal action for violations of state law, preparing an ethics complaint, and advocating for a legislative hearing. These steps demonstrate that the process was improper from the beginning. Risk to Public Safety: Our current name highlights our critical role in protecting public safety through secure management of justice-involved youth. Diluting that emphasis could mislead the public, community partners, and policymakers about the nature of our work. It risks reducing support for the resources and standards we need to maintain safety—putting communities at greater risk in the long run. We have always prioritized strong public safety; this change undermines that commitment. In Summary: This proposed name change is unnecessary, damaging, and procedurally improper. It would weaken our operations, exacerbate staffing challenges, and erode focus on safety—all with no demonstrated benefit for the youth we serve. I urge you to reject this proposal and preserve the current name, "Division of Juvenile Correctional Services." Jon Morel Council 94 Local 314 Member Juvenile Program Worker

To Whom It May Concern, My name is De’Nara Polk, and I currently serve as a Juvenile Program Worker (JPW) at the Rhode Island Training School. I am a proud graduate of the 31st JPW Academy. I mention this to emphasize that, as someone new to the field who has recently completed the application process, I found the job title and description somewhat misleading. The description presents the JPW role as being more aligned with social work, when in reality, the position demands a much broader scope of responsibility. Despite this initial misunderstanding, I chose to continue through the academy and accept the position and I am truly grateful for the opportunity to hold this title and to play a role in correcting and guiding the behavior of our youth. That said, I feel very strongly about maintaining the integrity of the JPW title and our placement under the Division of Juvenile Corrections. The youth at the Rhode Island Training School benefit greatly from the structure, discipline, and accountability our division provides. These are essential elements in fostering genuine behavioral change. A rebranding to the “Division of Youth Development” would not accurately reflect the responsibilities we uphold in providing care, custody, control, and rehabilitation. In conclusion, the current job description for Juvenile Program Worker already minimizes the full scope of what we do. Changing the division’s name would further dilute the significance of our work. I respectfully ask that you reconsider any name change and preserve the identity and purpose of the Division of Juvenile Correctional Services. Sincerely, De’Nara Polk Juvenile Program Worker Rhode Island Training School Division of Juvenile Correctional Services

To whom it may concern, My name is Pride Clark, I am currently a Juvenile Program worker at the Rhode Island Training School and an Airman First Class in the Rhode Island Air National Guard. In regards to the division title change from Division of Juvenile Correctional Services, I am highly opposed to a change in the division title! As a correctional facility, The Rhode Island Training School is the most secure, safest, rehabilitative option in the judiciary system for juvenile offenders of the law. This being the reality of the population in this facility, we deal with the highest profile cases and residents in the state of Rhode Island. Every youth deemed a danger to the public by the court of law is housed in the RITS, this danger is evident in our daily operations as JPW’s. Changing the title of our division title is portraying a narrative that is not consistent with the reality of Rhode Island’s only secure facility for adjudicating and/or holding accountable youth offenders of the law. As a Juvenile Program worker and the only representation of Juvenile corrections in the state, I feel as though this false identification of our division is the start to a major threat on the safety of the youth and staff in this facility- that would turn to a greater safety endangerment to the public as the correctional aspect for youth offenders seems to be under attack. Eradicating the Division of Juvenile Corrections will only harm our great state and create even more confusion within our Juvenile Justice System that I am sworn to defend. I strongly urge you to reject this proposed division title change and restore the current title, Division of Juvenile Correctional Services. Best regards, Pride Clark Juvenile Program Worker Division of Juvenile Correctional Services - R.I. Training School (RITS)

Dear Secretary of State & All Decision Makers Involved, Rhode Island Council 94 opposes the proposal to change DCYF’s division of juvenile correctional services to the division of youth development. It is a proposal that focuses on public perception that does not impact the rehabilitation that is going on at the RITS. Changing the division’s name, only confuses and dissuades potential job applicants from applying for the job of juvenile program worker at the Training School. When people hear Division of Youth Development, they do not understand where they will be working. There are group homes for kids who are not being treated for serious violent offenses and their needs are different. The kids who come to the Rhode Island training school are there for violent offenses. A lot of people do not want to work in a correctional environment. We need to attract people who are comfortable working with kids in a correctional environment. The specific type of workers we need are extremely dynamic. They have the soft personal skills to work with kids and rehabilitate them, but they also have to be skilled at safely physically managing violent kids. The number one reason why workers at the Rhode Island training school have to physically engage with kids is to stop fights amongst the youth that reside at the RITS. A lot of people are not comfortable, putting hands on kids, even when it is to protect them. If kids at the Rhode Island training school are not safe then there can be no rehabilitation. The juveniles who come to the RITS require a secure environment where they can take advantage of all of the programs the training school has to offer kids. I would like to acknowledge the elephant in the room that there have been allegations and reports in the national media that there have been abuses happening in some juvenile correctional facilities. I can confidently say that this is not happening at the RITS because there are over 200 cameras all over the training school and there are multiple levels of external review every time there is any physical incident involving a kid. There are no secret abuses happening at the Rhode Island training school. If a staff does use inappropriate physical force, they are out of a job. DCYF is inaccurate when they say that there is no financial cost to the State with the proposed name change. All of the required Division uniforms have the division title, “Division of Juvenile Corrections” on them. All recruitment materials also have the title “Division of Juvenile Corrections”, including flyers, table banners, placards, guidons, training materials, and the newly purchased 30 ft X 30 ft Grappling Mats with the “Division of Juvenile Corrections” patch in the middle of it, for the Defensive Tactics Training Program and JPW Academy. DCYF started using this different title without following the legal procedures(RIGL 42-35-APA) required for changing the division‘s title. The reason DCYF wants to change the division’s title is to give public perception that they are putting juveniles rehabilitation first. However, this title change would actually prevent rehabilitation from happening, because the number one reason Juvenile Program Workers(JPW’s) have to physically intervene and go “hands on” is to stop a fight between juveniles. Without safety and security at the Rhode Island Training School(RITS)l, there can be no rehabilitation for the youth there. Frontline staff at the Rhode Island Training School STRONGLY OPPOSE the proposed title change due to the resulting increase in short staffing and reduction in safety that it would create. The front line staff working at the Rhode Island Training School, implore the State to keep the division title the same, “Division of Juvenile Correctional Services”, to prevent increasing the short staffing crisis, and to maintain the safety and security for both staff and youth at the Rhode Island Training School. Thank you, Nicole Barnard AFSCME Council 94 Attorney/Business Representative February 17, 2026

To Whom It May Concern: The language we use has a profound impact on how young people see themselves and how society treats them. Names are never just labels—they carry meanings, histories, and assumptions that can either empower or stigmatize. As a registered nurse and nursing professor whose work centers on children and youth with special health care needs (CYSHCN), I have seen firsthand how terminology can contribute to harmful stereotypes, implicit bias, and reduced opportunities. Many of these young people already navigate complex medical, social, and emotional challenges. Adding the weight of a “correctional” identity reinforces stigma and can unintentionally frame them through a lens of deficit rather than potential. The shift toward the Division of Youth Development represented more than rebranding—it represented a commitment to approaching our youth with care, non bias, and empathy. Reverting to the term “Juvenile Correctional Services” risks undoing that progress. It narrows our understanding of these young people to their most difficult moments, rather than acknowledging their strengths, developmental needs, and capacity for growth. Names and narratives matter. They signal whether we see them as individuals worthy of investment, support, and dignity, or as problems to be managed. Maintaining language rooted in development, rehabilitation, and reinforces a culture that truly believes in our youth. I fully support the continued use of “Division of Youth Development” and believe protecting this identity is essential to ensuring programs remain aligned with best practices, human dignity, and the supportive environments our young people deserve. Respectfully, Regine P. Reaves, PhD, MSN, RN, MPH

February 18, 2026 Dear Secretary of State and Decision Makers, My name is Beth Jordan, I am a Cottage Manager at the RI Training School. I am also a licensed independent clinical social worker (LICSW), I hold two associates degrees, a bachelor’s in social work and a master’s in social work. I have been employed at DCYF since July 2000. I began my career at DCYF in Family Service (FSU), then transferred to the Training School as a Clinical School Worker and was ultimately promoted to the position of Cottage Manager. As a Cottage Manager I wear many hats; head of a treatment team for the youth, trainer, supervisor, oversee interview panels, and the list goes on. I have had the opportunity to counsel many people into this job and unfortunately counsel some out of the job. As someone that has sat on interview panels and overseen interview panels it takes a special person to work in a Juvenile Correction facility and that person must have an idea about what they are getting into from the time they see the listing or from our facilities name on the internet. I have sat at countless interviews in the last couple of years where people have had no idea that this was a juvenile correction facility, and we had to explain it to them. There is perception of what a Juvenile Program Worker (JPW) or Social Worker would or could do in this facility that is flawed by the descriptive of “Division of Youth Development” vs the clear descriptive that our current title gives “Division of Juvenile Correctional Services. We have had question such as: Are the kids locked up, Will I have to restrain anyone, Are there any kids here with serious crimes, etc.? We have had applicant show up for interviews looking for teaching jobs at a daycare when it was a JPW job, people with severe mental illness that had to be dismissed from the interview due to inappropriate disclosures, people who lacked the correct education/credentials, and those who thought it was a group home job, etc. As a manager who often oversees the interview process, after the panel has made its recommendation, the decision is often overridden by the Administration (these are the type of candidates that often do not succeed). The facility has had to dismiss candidates from the academy that couldn’t read/comprehend or write adequately once in the academy. Moreover, some were dismissed at some point during the academy due to the inability to perform certain basic tasks that are required for the position. This trend has become more prevalent since this facility has changed the name from Division of Juvenile Correctional Services to “Division of Youth Development.” Another disadvantage of the name change to Division of Youth Development, centers on the misconception many prospective candidates have about this facility that this is the type of a job similar to youth in residential settings. Many, in fact, think the job will be like coaching youth in the community, when the positions primary responsibility is care/custody/control for a population of youth that present with a series of behavioral health issues, are crisis driven and present with multifaceted criminogenic needs. It is important they have the other skills, but it will not be the primary task. On the clinical side, there also can be a break down in communication and understanding with the Social Worker, in a private setting Social Workers meet a youth one hour per week vs Juvenile Corrections Services where a social worker must respond to the needs of the youth who are often in crisis and often meet a youth several times daily as well fulfilling case management duties. Understanding the goals of both Juvenile Corrections and Youth Development is clear having worked at DCYF for almost 26 years! There is no need to make a name change, the last couple of years has shown that the change has weaken our status of who we are and cause somewhat of an “identity crisis.” We have always been a strength-based facility who put our youth first and look to programming, reducing recidivism (with very good numbers according to the last data), clinical staff with great credentials, staff that are multi-lingual, and worked to keep youth safe that could not be maintained in the community, as well as the community safe. Respectfully submitted, Beth Jordan, MSW, LICSW Cottage Manager- RI Training School Division of Juvenile Correctional Services

• Beth Jordan.docx

Dear Secretary of State and Decision makers, My name is Dennis Lassiter, and I am currently a Shift Coordinator at the RI Training School, and prior to that I was a Juvenile Program Worker for almost 20 years. I strongly OPPOSE the proposed division title change, that would change the current title from “Division of Juvenile Correctional Services” to “Division of Youth Development”. While the rebranding of juvenile correctional facilities to "Youth Development Centers" (YDCs) is generally intended to signal a shift from punishment to rehabilitation, critics and researchers highlight several reasons why such a change can be problematic or "bad" if not accompanied by systemic reform. In Rhode Island, the debate often centers on whether a name change is merely cosmetic or if it addresses the underlying issues of the Rhode Island Training School(RITS). The RITS is and has been for over 40 years, mandated by the Family Court to provide rehabilitation services for all juveniles. That mandate has not changed, and therefor proves that this proposed amendment to the divisional title is simply cosmetic. Changing the title to DYD will have a huge negative impact on our recruitment efforts, specifically for the 2 fully uniformed classifications at the RITS that where a full utility belt equipped with mechanical handcuffs, tri-fold flex-cuffs, Motorola Portable Radios and correctional grade keys with handcuff keys on every key ring. Some advocates will argue that changing a name without changing the "corrections-like" culture is misleading. If the facility still relies on security, secured/locked housing of juveniles and an accountability atmosphere focused on an incentive-based system, then proposing to change the division title to DYD is actually creating more of an identity crisis problem. The DYD title does not accurately reflect the actual facility and all of its safety and security measures, not only for those youth and staff in the facility, but also for the Public’s safety as well. Risk of "Net Widening": Using a more therapeutic-sounding name like "Youth Development" can unintentionally make judges and prosecutors more comfortable sentencing youth to these facilities, thinking they are providing "help". This can lead to more children being incarcerated for minor offenses that could have been handled through community-based programs. High Costs for Poor Outcomes: Despite the "developmental" label, secure facilities remain the most expensive and least effective way to reduce crime. In Rhode Island, nearly 75% of youth remanded to juvenile prisons return to the corrections system within five years, regardless of the facility's name. Trauma and Ineffectiveness: Research indicates that removing youth from their homes and communities is inherently traumatic and often produces worse outcomes for low-risk youth compared to home-based services. However, those high-risk youth that are repeatedly getting arrested for serious, violent offenses will benefit most from a secured, structured and rehabilitative facility. I strongly urge you to deny this proposal and preserve the current division title, "Division of Juvenile Correctional Services." Respectfully, Dennis Lassiter Shift Coordinator RI Training School 2/18/26

Kelsey Rice—President of Juvenile Law Society RWU School of Law You are going to do big things one day. You’ve got a good head on your shoulders. Those words were said to me by a young man at Ferris School, a secure facility for youth I interned at. I remember that day so clearly. I had told him I was planning to go to law school, and he stopped and gave me a motivational speech. It caught me off guard. He was two or three years younger than me, yet he was speaking life into my future with so much certainty. Me, a young college student he didn’t know. And as I walked away, I couldn’t stop thinking about the contrast: he had so much faith in me, but so little in himself. I think about that day often . During my time there, I met young men with real dreams and real ambition. They wanted to be doctors. Accountants. Business owners. Athletes. Their goals were no different from the goals of students sitting in classrooms across this country. But many of them shared those dreams in a whisper, glancing around to make sure no one else heard. Because somewhere along the way, they learned that their ambitions did not match the label they had been given. “Juvenile delinquent.” “Inmate.” “Offender.” “Correction.” That is the power of labeling. When we call a place “juvenile corrections,” what are we really communicating? We are saying these children are something that needs to be corrected. The language itself centers punishment, not potential. It defines young people by their worst mistake and attaches identity to behavior. But if we believe in youth development, then our language should reflect growth, not guilt. Development means we expect change. It means we see capacity. It means we believe a mistake is not a life sentence. Labels matter. Words matter. Language shapes identity. It shapes expectations. It shapes policy. It shapes the way young people see themselves, and the way the world sees them. Do we really think their peers don’t know what “juvenile corrections” means? Do we think families and communities don’t understand what those labels imply? Of course they do. And the youth know it too. When a child internalizes the label “offender,” it becomes harder for them to picture themselves as a scholar, a leader, or a professional, even when they are intelligent, determined, and fully capable. The label narrows their vision of who they are allowed to become. I watched young men earn their diplomas at Ferris School. I attended their football games to show them that someone was proud of them. And every time I visited, I saw growth, maturity, discipline, humor, and leadership. I saw boys becoming young men. But I also saw how deeply the label followed them. In some cases, it followed them so heavily that they preferred returning to the facility, the one place where everyone already knew their story, rather than facing the judgment waiting outside. If you truly believe in rehabilitation, in restoration, in second chances, then your language must reflect that belief. A facility for youth should not be branded as a correctional institution first. It should be framed as a place of growth, development, and opportunity. Because when we label children as problems to be fixed rather than potential to be nurtured, we limit them before they even have the chance to redefine themselves. That young man who told me I was going to do big things? He was insightful. He was compassionate. He was thoughtful. He was not his charge. He was not his worst decision. He was not a label. And neither are any of the other young people we so easily categorize. If we want different outcomes for our youth, we must start with different language. Because the way we speak about children becomes the way they speak about themselves. And that is why words matter.

Stephen Cooper RI Training School Shift Coordinator Re: RI Department of Children, Youth, and Families rule change (214-RICR-60-00-1) I OPPOSE the title name change FROM: The Division of Juvenile Correctional Services TO: The Division of Youth Development I started my career with DCYF at the RI Training School (RITS) in 2018 as a Juvenile Program Worker. Previously, I worked for 4 years as a Case Manager for people aged 18-21, who had ‘aged out’ of the care of DCYF but were still involved in their voluntary extension of care program. It was a vastly rewarding job trying to help young adults navigate the myriads of challenges that come up in life. I helped these teenagers and young adults secure housing, understand rental leases, communicate with landlords appropriately, fill out federal financial aid forms for college, find and maintain employment, obtain local food source and medical benefits, achieve reliable and safe transportation, and a variety of other life skills. While the specific tasks we worked on were all incredibly important foundational experiences for young adults to have, in hindsight the most crucial lesson I tried to instill was the importance of developing healthy, positive interpersonal relationships. In summary, if you treat others the way you want to be treated, with respect and kindness, you are well on your way to fulfilling the second part of the Vision Statement of DCYF; “…through collaboration, we effectively engage with families and communities, working together to ensure the safety and well-being of the children and youth we serve.” In this job capacity, I would whole-heartedly say that I was working under the premise of ‘Youth Development’ although it was more specifically, ‘Adolescent Development’. Starting at the RI Training School in 2018, I quickly saw that the scope of my job duties as well as environment had changed drastically. I was now thrust into a secure, locked facility. The use of mantrap doors, key card badge readers, over 200 cameras, security gates with razor ribbon, and an intake Sally Port. The only facilities I have seen that utilize these correctional based tools for safety are prisons, jails, and detention centers. There was new leadership in both administration and our union’s local. The new mantra was “change the culture”. This was more than just a pull-string catchphrase. It was in reference to the collective identity of our facility becoming more professional. Many JPWs, including myself, were working 16-hour shifts 3 to 5 days a week. Sacrificing birthdays, holidays, and time with our own families to help maintain care, custody, control, and safety of the people at the RITS. Line staff were newly outfitted in full duty uniforms and utility belts to help safely manage the Resident population. This all aligns directly with the identity of a Juvenile Correctional Officer. U.S. Legal defines Juvenile Corrections as: “Juvenile corrections refer to the systems and facilities designed to rehabilitate young offenders who have been convicted of crimes. Unlike the adult correctional system, which focuses more on punishment, juvenile corrections emphasize rehabilitation to help youth avoid a future life of crime. This system includes various professionals, such as probation officers and social workers, who work together to provide support and guidance to juvenile offenders.” Youth Development is not the antithesis of Juvenile Corrections. In fact, they do both aim for healthy independence and positive outcomes. There are, however, stark contrasts that differentiate between the two titles. The Aspen Institute defines Youth Development as: “Positive Youth Development is an intentional, prosocial approach that engages youth within their communities, schools, organizations, peer groups, and families in a manner that is productive and constructive; recognizes, utilizes, and enhances young people’s strengths; and promotes positive outcomes for young people by providing opportunities, fostering positive relationships, and furnishing the support needed to build on their leadership strengths.” – Interagency Working Group on Youth Programs. Many people that work at the RITS take great pride each day in staying steadfast and consistent with the juveniles we work with. It is understood that there is a negative stigma and potential future consequences in labeling any youth as ‘a criminal’ but it is important to recognize mistakes of the past, address, and then correct misconduct and malfeasant behavior. This brings me back to the first part of the Vision Statement of DCYF which is covered by the work done here at the RITS. “The Rhode Island Department of Children, Youth & Families leads excellence in service delivery by strengthening PREVENTION, ensuring ACCOUNTABILITY, and respecting the dignity and diversity of every individual and family.” Juvenile Program Workers, teachers, nurses, probation workers, social workers, and many other professionals all work congruently with youth to help prevent future actions that would get them in trouble with the law. The RI Family Court also teaches juveniles to be accountable for their actions by having them serve time at the RITS for their offense and receive rehabilitative services while there. Of all these professions however, only the JPW job class stays with the juveniles 24 hours a day, 7 days a week, 365 days a year. It takes a village to create lasting change, but I would be hard pressed to argue that there is a more influential group of people than the ones always present. In summary, we all have personal and professional identities and the titles we have are important. Even accidentally calling someone by the wrong pronoun can be deeply offensive to them. The title of the division being ‘Juvenile Correctional Services” resonates with myself and many others at the RITS because we fundamentally believe in our identity. It helps maintain camaraderie, leads to a sense of belonging, guides choices while on the job, and can help determine goals. An accurate division title also generates potentially better applicants for the job, and helps to root out people who may be better fit in other professions. Thank you for your time and consideration in regards to this very important matter. Respectfully, Stephen Cooper Shift Coordinator, R.I Training School Local 314

• Steve Cooper Testimony on Proposed Division Title Change 3.4.26.docx

Stephen Shears Cranston, RI 02920 Date: 02/17/26 Re: RI Department of Children, Youth and Families rule change (214-RICR-60-00-1) Opposition to rule change; (214-RICR-60-00-1) As a thirty-eight-year state employee and thirty-six-year employee of the Department of Children Youth and Families, Division of Juvenile Correctional Services, I stand in opposition to the proposed rule change. The Department states it is basing said requested change on the premise that it will align the division title to better fit into the values of the Department and current divisions mission statement, which includes its mandate to provide rehabilitative services to the youth incarcerated at the Rhode Island Training School for Youth; services that it has been providing for my entire thirty-eight year tenure as a then classified Youth Correctional Officer when I was first hired in 1989. This rehabilitative mandate continued when we reclassified as Juvenile Program Workers in 1992, as well as in 1994, when I was again reclassified as a Shift Coordinator, where I continue to serve currently. In the thirty-eight years of my state service career, I have worked in many capacities and roles. I have been involved in many recruitment drives and activities, served as an instructor in many training academy evolutions, and been an active physical agility test administrator. I have additionally served as a sitting interview panel member for the classification of Juvenile Program Worker. The classification that is responsible for providing the mandated care, custody, and control is the cornerstone that facilitates a safe and secure environment, allowing the last mission statement mandate, otherwise known as the rehabilitation process, to function smoothly. The Department, through this proposed rule change, which would rename the current title of the Division from the Division of Juvenile Correctional Services to the proposed Division of Youth Development. This will have you believe that rehabilitation cannot take place because the word ‘correctional’ simply does not fit in with the narrative, purely because it is a word that they believe connotates negativity. Therefore, by simply changing the title through removing the word ‘correctional,’ and replacing it with ‘Youth Development,’ the department believes that it will make our current rehabilitation efforts for the youth at the Rhode Island Training School more effective. In my thirty-eight-year service, I have been witnessed to these types of unnecessary terminology changes, which often unintentionally cause more harm than good. They provide no increases in funding for educational or rehabilitative programming, and they do not make facilities any safer for either the youth or the staff. Juveniles are sentenced to the Rhode Island Training School for Youth for a variety of crimes committed in their communities, under the jurisdiction of the Rhode Island Family Court. The facility in and of itself is a secure, locked facility, it utilizes mantrap doors, secure sallyport garage areas for intakes, and Southern Folger Adams series electrical locks. These types of correctional-based security items and areas are not located in any other types of facilities besides jails, detention centers, and prisons. For many years prior to 2018, we heard administration after administration tell us that if we went over to a fully uniformed staff, that it would have a negative effect on the rehabilitation that we are mandated to provide. Yet in 2018 after two RIOTS, and at the direction of the RI State Police, we changed rom a casually dressed line staff, to fully uniformed and public safety related equipped division. The term ‘Youth Development’ connotates to the public a non-secure, residential treatment program designed for youth that require a less restrictive environment. Our care, custody, and control staff wear full duty uniforms, with uniform shoulder patches that are embroidered with the official Division title as prescribed under RI General Law 42-72 (Chapter 248) that has been in existence since 1979. These patches with the title were agreed upon and authorized through a signed Special Purpose Agreement between the State of Rhode Island and the Union that represents the line staff at the Training School, Local 314 RI Boys and Girls Training School, AFSCME RI Council 94. This agreement was signed into existence in 2018. The language in the agreement states that any and all items in the said agreement can only be changed with the consent of both the state and the Union. No request of the department for a change to that patch can be made other than through that instrument. Changing the title of the division via the Administrative Procedures Act (Public Hearing) would not change the fact that the patch will always have the words Division of Juvenile Corrections on it. This Special Purpose Agreement came into existence after years of request by the staff to go over to a uniformed agency and was met by the same rhetoric that Uniforms would be stigmatizing to the youth at the facility, thus preventing staff from participating in the rehabilitative process. After not one but two RIOTS occurred in 2017, only two months apart. The Rhode Island State Police after conducting a sixty-day review, made the formal recommendation that a uniform be developed in cooperation between the then DCYF Administration and the Union, that being Local 314. Such a Uniformed was designed and signed off on, and policy was created at that tike as to how it would be worn. It has been nine years since that agreement was signed and the staff’s wearing of formal law Enforcement style uniforms has had no discernable and or detrimental effect on our ability to interact positively with youth while engaged in the rehabilitative process. As a matter of fact, our most recent Recidivism report clearly shows that once again our Facility and division, under the still official title of Juvenile Correctional Services does a better job in all areas to rehabilitate youth and ensure that they do not return to the facility than does the non-secure facilities that the state and department contract within the community. Another major issue that consistently plagues the agency occurs when we are recruiting for the position of Juvenile Program Worker, otherwise known as the line staff classification job title. The classification job title is misleading at best, but to add the misconception that this is not a correctional related job leads to many prospective applicants deciding that they would be better served career-wise to apply for Adult Department of Corrections or a local Police Department. Many new applicants are surprised to see uniformed staff administering the agility test when they arrive. The department which is currently using the incorrect and illegal title of Youth Development, has the aforementioned recruits believing that they are applying for a job at a residential treatment facility rather than the states’ only secure juvenile facility. That confusion leads many to either fail the agility test or simply not continue with the application process. New applicants are required to undergo the same physical agility test and are furthermore required by law to pass the same psychological exam (MMPI) as all the thirty-nine municipal and state law enforcement agencies. Our new applicants must attend and pass a forty hours per week / eight weeklong formal training academy. Our uniformed staff are equipped with Handcuffs as well a Flex-Cuffs (A zip type of restraint device). They are authorized to use leg irons when required. Are any of the non-secure facilities equipped with such mechanical restraint type tools of the Law Enforcement and or Correctional profession. The question sounds rhetorical as the answer is no, not in the State Of Rhode Island. Our facility is authorized to utilize prone restraint as a means of securing a youth when necessary under RIGL 42-158.3, this statute only applies to Law Enforcement, The RI Department of Corrections and the Elanor Slater Hospital (Benton Center). There are very few secure juvenile detention agencies in the United States that allow and or require these same standards be met for newly hired staff. These RI General laws and requirements fit with the title Juvenile Correctional Services, not Youth Development. The line staff are legislated into the same Rhode Island retirement system as law enforcement officers, and there is pending legislation in both the Rhode Island House of Representatives and the Rhode Island Senate that will upon passage give them full powers of arrest and add the classifications of Juvenile Program Worker and Shift Coordinator, being the two fully uniformed and equipped employees of the Department and Divisions as ‘Peace Officers.’ That legislation will make them the only fully sworn law enforcement officers in the department. The title change that the department is requesting goes against all logic and factual information that has been presented here in this letter. It will only continue to lower morale, erode the confidence the line staff have in both the Departments and the Divisions leadership as well as negatively impacting the already dismal recruiting efforts, and it will present yet another unintended and misguided roadblock to hiring quality care, custody, and control staff. The word ‘correctional’ is not a term that means that the facility is only punitive, as the departments’ submitted analysis may have you believe. It has been a part of the official title by law as well as their own admission since 1979. A title that our line staff have served under proudly for the last 47 years. Our mission has not changed in all those years, nor has it in my thirty-six as a department employee. To change negative and clinically diagnosed deviant behavior leading to criminality, that behavior must be corrected, through the rehabilitative process which has been the norm during my tenure here at the Division of Juvenile Correctional Services. Changing the name will not make a difference in the daily efforts of staff in conducting the mission of care, custody, control, and rehabilitation as well as the outcomes, as it did not adversely affect the rehabilitative mission when we changed over to full uniforms. It will only let the staff know that their leadership cares very little for what they perceive to be their identity in the Law Enforcement community at large, and signal that the job that they signed up for as Juvenile Correctional uniformed staff is being blatantly disrespected. Changing the Division Title through this proposed rule change, will only serve to lower staff moral and hinder the division and department’s ability to recruit quality staff members for a job that few people can do successfully. Respectfully submitted, Stephen Shears Member Local 314 RITS RI Council 94 AFSCME

• Steve Shears Opposition letter to proposed rule change DCYF 3.4.26.docx

March 5, 2026 Dear Secretary of State and Decision Makers, I am writing in support of the position expressed by Ms. Beth Jordan regarding the proposed name change of the Division of Juvenile Correctional Services at the Rhode Island Training School. As President of the Rhode Island Brotherhood of Correctional Officers, I represent the correctional professionals who work throughout Rhode Island’s correctional system, including the Cottage Managers and Social Workers assigned to the Rhode Island Training School. While I do not work at the Training School facility myself, I represent many of the dedicated professionals who do, and I fully support their concerns regarding the proposed name change. Ms. Jordan’s letter clearly outlines the operational realities of the facility and the unintended consequences that have already resulted from shifting the name away from its clear identification as a juvenile correctional facility. Her experience, along with that of other staff members, demonstrates that the current terminology used to describe the division has created confusion among prospective applicants and has contributed to misunderstandings about the nature of the work performed at the Training School. As someone who has served as a correctional officer in Rhode Island for nearly forty-two years, I can attest that clarity about the mission and function of a correctional facility is critical. The professionals who work at the Training School perform an extremely difficult and important job that involves care, custody, and control of youth offenders who often present with significant behavioral, mental health, and criminogenic needs. These responsibilities require highly qualified staff who fully understand the environment in which they will be working. When the name of the division minimizes or obscures the correctional nature of the facility, it can lead to confusion among applicants, unrealistic expectations about the job, and ultimately challenges in recruiting and retaining the right individuals for these critical positions. As Ms. Jordan noted, staff responsible for interviewing candidates have already experienced situations where applicants did not understand that they were applying for positions within a secure juvenile correctional facility. The men and women working at the Training School take great pride in their mission. They are committed to protecting the youth placed in their care, providing meaningful programming and treatment opportunities, and maintaining a safe environment for both the youth and the surrounding community. The existing name, Division of Juvenile Correctional Services, accurately reflects the important role the facility plays within Rhode Island’s juvenile justice system. For these reasons, the Rhode Island Brotherhood of Correctional Officers supports Ms. Jordan and the other staff members who have voiced opposition to the proposed name change. We believe that maintaining clear and accurate terminology for the division helps preserve the identity of the facility, supports appropriate recruitment, and reflects the true nature of the work performed by the professionals who serve there. Thank you for your time and consideration. Respectfully, Richard Ferruccio President Rhode Island Brotherhood of Correctional Officers

• Training School letter.docx

Louis Como 3/5/26 Shift Coordinator – RI Training School OPPOSITION / OBJECTION to the proposed rule change; (214-RICR-60-00-1) To Secretary of State and Decision-Makers, My name is Louis Como, a 39 year employee for DCYF - Division of Juvenile Correctional Services. I am strongly OPPOSED and OBJECT to the proposal to change the name/title from “Division of Juvenile Correctional Services”(DJCS) to “Division of Youth Development”(DYD). In my opinion the proposed change in title has and will have a direct negative impact on the Recruitment Efforts for the RI Training School, causing an Identity Crisis for the division. This Identity Crisis leads to confusion of potential candidates for employment, as to what a Juvenile Program Worker(JPW) really is responsible for, and the role they play here at the RITS. Along with being a Shift Coordinator, I am also a certified trainer for the Physical Agility Testing that takes place for applicants wanting to become a JPW. Every person interested in becoming a JPW must successfully pass the physical testing portion of the hiring process, even before getting their 1st interview. So with me being at these initial testing days, I have seen and heard first hand from many individuals that show up at these testing days, and they say that they had no clue as to what a JPW’s job really is, and they will often ask why is the physical testing necessary to become a JPW? It's based off of real life instances like this, as to why I am saying that changing the division title has and will have a direct negative impact on our recruitment and retention. The proposed “Division of Youth Development” title has already been implemented in some areas, which has already shown a negative impact on our recruitment efforts, and trying to reach the appropriate demographic for this line of work, proves to be extremely difficult when our division is being called 2 different names/titles. This identity crisis has resulted in very confused applicants, as well as confused DCYF/State employees’, because of the unilateral change in division title prior to going through the required Rulemaking-Process(RIGL 42-35- Administrative Procedures). Again, in my opinion this change is already impacting the amount of candidates we get interested working in Juvenile Corrections, and that is a direct result from when DCYF began using the “DYD” title pre-maturely, before even proposing the title/name change. Trying to remedy the misuse of the “DYD” title by backtracking and proposing the change in division title after the fact, does not mean that is the correct approach to try and fix an ongoing issue. As a 39 year Veteran State Employee, I feel in part to the lack of consistency in what we really do as a facility, and what the title depicts. We are and always will be a Juvenile Correctional Facility, that incarcerated and/or detained juveniles, both male and female, adjudicated and non-adjudicated, all by way of the Family Courts. A JPW’s role will always be “Care, Custody, and Control”, and it’s because of these 3 responsibilities/duties, that make it even possible for the Rehabilitation Services to actually take place. In a correctional facility, Safety is the MOST important aspect. There are some that will try to make the argument that the words, “Corrections/Correctional and Juvenile” are negative words that only mean “Punishment”, and will have a negative impact on the outcome or results of the youth at the RITS. However, I can say with complete confidence that 99% of the youth we are responsible for at the RITS are here for very serious and violent crimes, and how the word “Corrections/Correctional” is perceived (by some) has no bearing on the outcome of the youth. While "Corrections" and "Punishment" are often used interchangeably in the juvenile justice system, they have different primary goals: “Punishment” focuses on penalizing past actions, while “Corrections” aims to modify future behavior, often through rehabilitation and education. Ultimately, while Corrections can often involve accountability and some disciplinary measures, it is broader and ideally aimed at positive, long-term change. The accountability and/or disciplinary measures will only occur if a youth becomes continuously non-compliant and/or becomes violent towards others, creating an unsafe environment for everyone. In summary, this proposed amendment to change the division title is not only unnecessary, but it serves no meaningful benefit or purpose, making it purely a cosmetic change. The current division title, “Division of Juvenile Correctional Services”(DJCS) is a clear and accurate title that already aligns DCYF’s mission and statutory focus on the rehabilitation services. Our mission and statutory rehabilitative services at the RI Training School have been the same for the last 47 years. We take pride in the fact that we have such a strong focus on the youth rehabilitation process while at the RITS. We also take pride in the fact that other law enforcement agencies/professionals, such as RI State Police, all 39 municipalities (City and Town police departments), Deputy Sheriffs and the Adult Department of Corrections in RI, ALL treat and give us the respect of being a fellow Law Enforcement Professional working in Juvenile Corrections. It really hurts staff morale, when our own department is essentially the only one in this State that does not show us the same respect that all of the other Law Enforcement Agencies do. I respectfully urge you, the decision-makers and Secretary of State, to please DENY / REJECT this proposal for changing the division title, and preserve our current title, “Division of Juvenile Correctional Services”. Thank you, Louis Como Shift Coordinator – RI Training School Division of Juvenile Correctional Services

• Lou Como OPPOSITION statement for proposed division title change.docx

Joseph A. DeLuca 3/5/26 Juvenile Program Worker Council 94 Local 314 President Re: RI Department of Children, Youth and Families Proposed Rule Change (214-RICR-60-00-1) OPPOSITION / OBJECTION to rule change; (214-RICR-60-00-1) As the current Council 94 Local 314 President, Juvenile Program Worker and a nearly 10 year employee of the Department of Children, Youth and Families, Division of Juvenile Correctional Services, I stand in strong opposition to the proposed rule change. DCYF states that they are basing this proposed change on the idea that it will better align DCYF’s mission and improve clarity for the rehabilitative framework that our division has always done. The Division of Juvenile Correctional Services(DJCS) is mandated to provide rehabilitative services to the youth incarcerated at the RI Training School(RITS), and this mandate has been in place for over 47 years. In my nearly 10 year career here at the RITS I have been a part of recruitment drives, served as an Academy Instructor for the Division’s JPW Pre-Service Training Academy, and also served as a panel member for the Juvenile Program Worker(JPW’s) and Shift Coordinator’s interviews here at the RITS. JPW’s are responsible for creating and maintaining a safe and secure environment, so that the mandated rehabilitative services can safely and effectively take place. Without having a safe and secure environment the rehabilitation process is nearly impossible to achieve. JPW’s and Shift Coordinator’s are the 2 classifications that are a fully uniformed position, including a full duty belt equipped with mechanical handcuffs, ASP Tri-Fold Flex Cuffs, correctional grade keys and some other tools to help create and maintain a safe environment for all. Additionally, the 2 uniformed classifications require the successful completion of the JPW Pre-Service Training Academy. This required academy is 8 weeks(320 hours) in duration and must be successfully completed in order to work as a frontline staff member. At the end of this academy another requirement is in accordance with RIGL 42-28.3-1 Test to be given. Each candidate is given an Aptitude and Psychological Tests for Law Enforcement Candidates(Title 42-Chapter 28.3-subsection 1). Any candidate who receives an unsatisfactory rating shall be ineligible for any of the above specified positions. The proposed rule change would amend the current division title from, Division of Juvenile Correctional Services to “Division of Youth Development”. This change is not only unnecessary, but it will in fact create more confusion and mislead applicants because of the misinterpretation that the “Youth Development” name reflects. The current name, "Division of Juvenile Correctional Services," accurately and clearly reflects our mission: providing secure correctional care and rehabilitation services for youth involved in the juvenile justice system. It aligns with Rhode Island statutes and the reality of our responsibilities, which center on safety, security, structure, accountability, and evidence-based rehabilitation. DCYF has provided no evidence that the existing name(DJCS) creates any problems or that a new name would produce better outcomes for youth. This proposed title change appears to be a cosmetic change with no meaningful benefit. Renaming our division would undermine the focus and effectiveness of our secure facilities. Our work requires managing controlled, structured environments with firm rules to ensure safety and behavioral accountability. The current name reinforces that correctional mission for staff, youth, and the public. Switching to "Youth Development" makes our facilities sound like typical community-based youth programs, which would dilute our emphasis on security, create confusion, and increase risks to both staff and the youth in our care. This title change would make it significantly harder to attract and keep qualified employees—something we are already struggling with. The current name clearly signals that we are seeking professionals with training and experience in corrections, crisis intervention, de-escalation, and juvenile justice. It attracts candidates prepared for the demands of secure settings. A "Youth Development" title would likely draw applicants expecting softer, non-correctional roles (such as after- school programs, community outreach, and community based/not secure group homes), resulting in high risk injury situations, poor job fits, high turnover, and persistent vacancies. As frontline correctional professionals, we take pride in balancing rehabilitation with safety, security and accountability measures. Changing the name would make us feel our specialized skills and hard work are being devalued or minimized, damaging morale and pushing more staff to leave. In the middle of ongoing staffing shortages, this would worsen an already critical situation, putting the youth and staff at the RITS in a high-risk/unsafe environment. DCYF began using "Division of Youth Development" without following required state procedures. In December 2025, Council 94 Local 314 requested that DCYF "Cease and Desist", from continuing to use the unauthorized use of “DYD”, and restore the correct name across all documents, websites, etc. Council 94 cited the RIGL § 42-35 (Administrative Procedures Act), which mandates a formal rulemaking process for such changes. DCYF disregarded this requirement and continued to use the wrong/illegal division title. In RIGL 42-35-4- Administrative Procedures- Filing and taking effect of rules, it clearly states that under sub-section (e), # (4) “A final rule shall not be effective or enforceable until properly submitted and accepted by the secretary of state.” So the fact that DCYF has already started enforcing and implementing this proposed change means that they are already in violation of this process. Also, in RIGL 42-35-6.2 – Compliance, it clearly states that “an action taken under this chapter is not valid unless taken in substantial compliance with this chapter.” Once again, this action is not and has never been in “substantial compliance” with this chapter, because DCYF has already started using the “proposed” DYD title on EVERYTHING. The proposed DYD title has not yet been accepted by the Secretary of State, and has not yet gone through the entirety of the required Rulemaking Process. If these violations are allowed to happen, then what is that saying to our youth and staff within this agency and State? It will send a message that depending on what your job title is and who you are, you don’t have to follow RI General Law and/or policy. In my opinion, that is not the message that a State Agency wants to portray. Our current name highlights our critical role in protecting public safety through secure management of justice-involved youth. Diluting that emphasis could mislead the public, community partners, and policymakers about the nature of our work. It risks reducing support for the resources and standards we need to maintain safety—putting communities at greater risk in the long run. We have always prioritized strong public safety; this change undermines that commitment. Also, just to point out, within DCYF there is already a “Youth Development Services” which is separate from “Juvenile Correctional Services”. For clarity, the RI Training School within the “Division of Juvenile Correctional Services” is a secure facility under the RI DCYF, and the RITS focuses on Safety and youth rehabilitation within this secure facility. “Youth Development Services” focuses on providing community-based support, life skills training, mentoring, mentorship, and promoting positive outcomes within the community. “Juvenile Correctional Services” is viewed as a secure and locked facility focusing on youth rehabilitation while adjudicated/detained at the RITS by the Family Courts. “Youth Development Services” is viewed as more of a community-based Preventative support system, often for youth in foster care/DCYF care or at risk youth. In conclusion, this proposed name change is unnecessary, damaging, and procedurally improper with several RIGL violations. It would weaken our operations, increase staffing challenges, and completely disregard the focus on safety and security within our facility and throughout our division. DCYF proposes this change with no demonstrated benefit to the youth we serve or any form of supporting documentation to prove that this change is necessary. Myself along with the 63 Local 314 Members strongly urge you to REJECT / DENY this proposal and preserve the current name, "Division of Juvenile Correctional Services." I have also attached a “Petition” signed by 65 individuals(all DCYF staff), and 63 of them are currently working at the RI Training School, in several different classifications, some from other Bargaining Units. *Please be advised. This statement and Signature Petition are to serve as a Formal OBJECTION to this proposed rule. *FORMAL OBJECTION to rule change; (214-RICR-60-00-1) Thank you, Joseph A DeLuca President Local 314 – Council 94 AFSCME Juvenile Program Worker RI Training School Division of Juvenile Correctional Services

• Updated JAD Testimony 3.5.26.docx