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