FOREIGN CHILD PLACING SERVICES AGREEMENT

THIS FOREIGN CHILD PLACING SERVICES AGREEMENT (the “Agreement”) is entered into
as of the _____ day of _______, 20___ by and between FRANK ADOPTION CENTER, INC., a non-profit,
international child placement agency licensed in the State of North Carolina, with an address of 2000 South
Main Street, Wake Forest, North Carolina 27587, (“Frank”) and
___________________________________and____________________________________,
(Adoptive Parent) (Adoptive Parent)
residing at _________________________________________________________________.

RECITALS:

A. Frank is a non-profit international child placement agency licensed in the State of North Carolina. Frank
works in conjunction with other organizations to identify and place eligible foreign children with adoptive
families.

B. The Adoptive Parents desire to adopt one or more children.

C. The Adoptive Parents desire to utilize the services of Frank as hereinafter set forth and Frank desires to
perform such services for the Adoptive Parents.

D. There are many risks and uncertainties associated with the foreign adoption process and Frank cannot assure
the outcome desired by the Adoptive Parents.

E. Frank and the Adoptive Parents are entering into this Agreement in order to set forth the terms and conditions
of the relationship.
AGREEMENT:

NOW, THEREFORE, in consideration of the mutual promises set forth herein, the sufficiency of which is
hereby acknowledged, Frank and the Adoptive Parents agree as follows:
1. Exclusive Arrangement. The Adoptive Parents hereby agree to retain Frank exclusively to provide,
and Frank hereby agrees to provide foreign child placing services to the Adoptive Parents upon the terms and
conditions of this Agreement.

2. The Adoptive Parents Responsibilities.

a. Information. The Adoptive Parents agree to provide complete, accurate, and truthful information as
may be requested from time to time by Frank or its agents. The Adoptive Parents hereby grant permission to
Frank and its agents to disclose to third parties such information provided by the Adoptive Parents that Frank or
its agents deem necessary for the performance of services for the Adoptive Parents (permission will be obtained
in writing prior to third parties being contacted).
b. Payment of Fees. The Adoptive Parents agree to pay all fees and expenses incident to the adoption
of a child. There are a variety of service fees and expenses that the Adoptive Parents will incur, including but not
limited to: application fee, agency fee, foreign service fees, service and support fee, travel-related expenses and
immigration-related expenses. Attached as Exhibit B is an estimate, description and time of payment of the costs
that the Adoptive Parents are likely to incur (titled “Fee Agreement.”) The actual fees and expenses may exceed
the estimates provided and, in all events, will be the sole responsibility of the Adoptive Parents. Other than may
be disclosed in the Adoptive Parent’s Fee Schedule, there are no other circumstances under which any fees will
be waived, reduced or refunded.
c. Compliance with Legal Requirements. The Adoptive Parents agree to comply with all requirements
of the United States Citizenship and Immigration Services (USCIS) and any such similar legal requirements
governing adoption both domestically and internationally.
2000 South Main Street, Wake Forest, North Carolina 27587
 d. Refunds. Frank or the Adoptive Parents may terminate this Agreement for any reason whatsoever,
by written notice to the other party. If for any reason either party prior to the child referral process terminates its
working relationship within 45 days of Frank receiving the prospective adoptive family’s Application to Adopt
and Foreign Child Placing Services Agreement, a refund from the agency fee of $1000 will be returned. If the
termination occurs 45 days after the receipt of the prospective adoptive family’s Application to Adopt and Child
Foreign Placing Services Agreement no refund will be given. In addition, a dossier translation fee up to $250
may also be applicable. The application fee and travel-related costs and other In-Country expenses shall not be
refundable or reimbursable by Frank Adoption Center, North Carolina. If the adoptive parents have paid the
Service & Support fee for their impending adoption and the adoption is not finalized in the child’s country of
origin or placement is not made, Frank will refund the entire Service & Support amount paid. The same rule
applies to the registration and post-placement/post-adoption deposits. If the family’s visas have already been
processed for their impending trip, the fee charged will not be refunded, due to the service being rendered.
Should Frank terminate its working relationship with the Adoptive Parent(s) the refund will be issued at
the same time as the termination letter is sent. Should the Adoptive Parent(s) choose to terminate their working
relationship with Frank the refund will be processed and distributed 90 days after receiving the written notice
from the Adoptive Parent(s).
e. Cooperation. The Adoptive Parents agree to cooperate fully with Frank in the adoption process.
i. Home study. The Adoptive Parent(s), upon separate agreement and the payment of any costs
associated therewith, will authorize and cooperate in any home study required by United States or
Foreign country laws and regulations. The home study is to be performed by a qualified licensed agency
that meets the licensing standards for the Adoptive Parent(s)’ state. Frank will assist the Adoptive
Parent(s), as requested, in identifying a licensed agency or other provider for the conduct of the home
study.
ii. Current, accurate information. The Adoptive Parent(s) will furnish Frank truthful, complete,
accurate, and current information.
The Adoptive Parent(s) acknowledge that Frank will rely upon a current home study. Further, the
Adoptive Parent(s) acknowledge that Frank will also evaluate the Adoptive Parent(s) for child
placement on the basis of information provided by the Adoptive Parent(s) and others and upon
interaction with the Frank staff.
The Adoptive Parent(s) affirm that all information supplied by the Adoptive Parent(s) to Frank has been
and will be truthful and accurate. Beginning with the execution of this Agreement, as required by the
Foreign country or the United States, or by Frank and continuing through the post-placement
supervision period required by Foreign country, the Adoptive Parent(s) will notify Frank immediately
of any change in the Adoptive Parent(s)’ situation, including but not limited to, working with another
adoption agency, separation or divorce in a marital relationship, change of address, another child
permanently located in the home, pregnancy of the adoptive mother, criminal changes brought against
adopting parent(s) in regard to spousal abuse, child abuse or endangerment, and substance abuse.
iii. Timely execution of adoption process steps and required documentation. The Adoptive
Parent(s) will promptly and timely perform all legal procedures and execute or obtain all legal
documents required for international adoption as may be directed, required, or requested by Frank or the
foreign country or the US government. The Adoptive Parent(s) acknowledge that such procedures and
forms will be multiple in both the United States and Foreign country and subject to changes in form or
requirement that may necessitate re-completion. Frank in Exhibit B will apprise the Adoptive Parent(s)
of the approximate cost of procedures and documentation and whether their cost is to be paid by the
Adoptive Parent(s) directly or to Frank or Foreign Facilitators for transmission to the appropriate
organization or entity.
iv. Post-Placement/ Post-Adoption report requirements. At the Adoptive Parent(s)’ separate
expense, they agree and will provide, in the time requested, any post-placement/ post-adoption
documentation required by the Foreign country or the United States, or by Frank in order to maintain its
licensing and accreditation both abroad and in the United States. The Adoptive Parent(s) will provide
all required information for these reports. Such requirements may include, but not be limited to, post-
placement/post-adoption reports, registration of adoption with foreign embassy or consulate, provision
of a copy of child’s Certificate of Citizenship once obtained, and provision of a copy of any United
States re-adoption undertaken. Frank shall apprise the Adoptive Parent(s) of such requirements and
facilitate the provision of these documents. To the extent that Frank is providing the post-placement/
post-adoption reports specifically, Frank will include their costs in the Exhibit B to this Agreement.
[See Section 2(e) for another option]

2000 South Main Street, Wake Forest, North Carolina 27587

 v. Required travel. The Adoptive Parent(s) will arrange for and make all visits to Foreign
country as may be required for purposes of adoption, at the Adoptive Parent(s)’ expense. Frank will
facilitate such travel by providing information and itineraries.
vi. Adoption permanence. The Adoptive Parent(s) acknowledge that the adoption of a child or
children when enacted is permanent. At such time as the adoption of a child is made final, the Adoptive
Parent(s) will be legal parent of the child or children and will have the same responsibilities and rights
regarding the child as biological parents have.
Prior to the finalization of adoption, from the time the Referred Child is given into the Adoptive
Parent(s)’ custody, the Adoptive Parent(s) will assume full responsibility and financial accountability
for meeting the child’s needs, including the provision of medical services provided for the benefit of the
child.

3. Description of Services to be Provided by Frank.

a. Information. Subject to the disclaimers contained in this Agreement, Frank shall provide to the
Adoptive Parents medical and social information about a potential adoption, as available. Frank shall not
independently confirm the accuracy or completeness of such information. Where no such information is made
available to Frank, the Adoptive Parents shall be so informed.
Frank does not guarantee the accuracy or completeness of any information, including medical
information, so provided through third party vendors or foreign providers and Frank cannot independently verify
such information. Frank states that the adoption process is largely determined by independent operators such as
government officials, i.e., judges, prosecutors, USA Immigration consular officers and local state employees,
i.e., chief doctors and heads of orphanages, of the child’s country of origin. Frank does not warrant liability for
such independent parties. In accepting such risks, the Adoptive Parent(s) will assume full responsibility for the
care of the adopted child including financial responsibility for health-related services obtained for and provided
to child. Frank itself does not guarantee the physical, mental or psychological good health of the Referred Child
nor the future development nor appearance of the Referred Child. Frank will make no representation concerning
such matters, and the Adoptive Parent(s) will not rely upon any such representation, if believed to be made, in
the Adoptive Parent(s) decision-making concerning the adoption of any Referred Child. Frank requires that all
families, upon receiving medical information on a child from the child’s country of origin, contact a U. S.
medical professional regarding the information provided on the child for an independent assessment. The
prospective adoptive family shall provide Frank with a copy of said assessment before completing their final
adoption or bringing the child to the United States.
b. Facilitate Process of Adoption. Frank and its agents shall facilitate the adoption process, including
but not limited to: verifying with foreign country officials that biological parental rights have been terminated;
assisting with the translation of documents; arranging for any necessary housing, food, translators and inland
transportation in the foreign country for the Adoptive Parents though the Adoptive Parents will bear
responsibility for all costs associated with such arrangements; maintaining contact with foreign country
representatives as needed to facilitate the adoption and completion of the adoption process.
c. No Guarantee of Assignment. Frank will use its best efforts to arrange for an assignment, but
Adoptive Parents understand and acknowledge that Frank can neither provide final confirmation of such
assignment nor guarantee a placement. Any arrangement by Frank of an assignment is contingent on the final
approval by the court. Final confirmation occurs in response to the Adoptive Parents Petition to the foreign court
and is within the sole discretion of the petitioned court.
d. Post-Placement Review. Frank shall have the right to obtain and the Adoptive Parents shall be
required to provide any and all information concerning any child adopted through Frank from the Adoptive
Parents until the child reaches the age of majority including but not limited to medical, psychological and
educational records. Attached as Exhibit C is an agreement to provide post placement reports.

4. Representations and Warranties by the Adoptive Parents. The Adoptive Parents represent and
warrant as follows:
a. No Reliance. The Adoptive Parents have made their decision to enter into this Agreement based
upon their own independent review and any other documents or information deemed relevant by the Adoptive
Parents, and have not relied on any representation or warranty by Frank or anyone acting for or on behalf of
Frank, other than as expressly set forth in this Agreement.
b. No Other Agency. The Adoptive Parents agree to work exclusively with Frank and have not
requested that another agency simultaneously pursue an assignment of a child for them, or to the extent they had
previously requested such services from another agency, such agreement has been terminated in writing. Failure
to comply will result in the forfeit of the eligible $1000 refund of the agency fee.
2000 South Main Street, Wake Forest, North Carolina 27587
 c. Understanding of Uncertainty. The Adoptive Parents understand that the amount of fees and
expenses ultimately paid may be more than the estimates provided by Frank, that the health and social condition
of a child is uncertain and that a successful outcome is not guaranteed.

5. Waivers
a. Assumption of Risk. The Adoptive Parents understand that there is a risk in foreign adoption and
Frank and its agents cannot control all aspects of the process, nor assure a successful outcome. The Adoptive
Parents understand that Frank and its agents do not guarantee the accuracy or completeness of information
provided regarding the medical or social condition of a child. Accordingly, the Adoptive Parents acknowledge
the possibility of and assume the risk of a child arriving with physical, emotional and/or developmental problems
which have not been diagnosed, have been diagnosed but not disclosed by the foreign orphanage or have been
misdiagnosed. If the Adoptive Parents desire additional information concerning a prospective adoptive child,
they may seek additional medical advice, at the Adoptive Parents sole expense, from the foreign orphanage or
medical or other professionals as deemed necessary by the Adoptive Parents. If the Adoptive Parents are not
satisfied with the health condition of a particular child for any reason, the Adoptive Parents do not have to
proceed to adopt such child.
b. Waiver of Claims. The Adoptive Parents hereby waive any and all claims which they may have
now or in the future against Frank and its agents and each of their respective directors, officers, employees and
agents (including but not limited to doctors or other medical professionals), arising out of the application for
child placing services, receipt of information or services from or adoption through Frank and its agents.
c. Indemnification. The Adoptive Parents agree to and do hereby indemnify, save and hold harmless
Frank and its agents and each of their respective directors, officers, employees and agents (including but not
limited to doctors and other medical professionals) from any and all claims, liabilities, actions, demands,
judgments, losses and/or damages (including reasonable attorney’s fees and costs) arising out of or relating to
acts or omissions in connection with the services provided hereunder, except for acts of willful misconduct.
d. Travel. Frank is not responsible for any accidents or injuries sustained by the prospective adoptive
parent(s) while traveling to, from or in the Foreign Country, and the Client is encouraged to purchase
independent travel insurance from any company providing such coverage for any potential claims related thereto.
Frank does not purport to be a travel agency or travel insurance provider in the USA or any foreign country, and
any suggestions made by Frank, its agents, employees, independent contractors, representatives or foreign
service providers or agents is made strictly without warranty of safety. The prospective adoptive parent(s) accept
the risk related to any travel or transportation related to this Agreement, and understands that any tour or travel
arrangement in the foreign country is the sole responsibility of the prospective adoptive parent(s).

The prospective adoptive parent(s) expressly waive(s) any and all claims against Frank (including
its employees, agents, foreign representatives, and independent contractors) as related to any travel, theft, hotel,
transportation incident on any automobile, motorcycle, taxi, bus, airplane, bicycle, etc., act of terrorism, accident
causing injury or death, Act of God, forces of nature, etc. while traveling to, within or from the Foreign Country
as related to the adoption referenced in this Agreement.

Frank may recommend convenient airlines, airport transfer individuals or companies, but does not take part in
the fee exchange of these companies or individuals and is not responsible for any acts of potential negligence
made on their behalf. The prospective adoptive parent(s) agrees to accept the risk for any transportation, hotel or
travel decision related to this Contract and to purchase independent travel insurance to protect their interests
thereby, thus understanding that they waive claims herein and accept the risk related to international travel.

6. Disclaimer. Frank and its agents, make no warranty or representation regarding the availability of a
child for adoption, the length of time of the adoption process, the health or social development of the child, the
completeness or accuracy of medical or other information provided, the costs associated with the process of
adoption, the actions of foreign governments, or the actions of United States immigration authorities. The
Adoptive Parents are encouraged to conduct their own investigations and studies or to have individuals of their
choice conduct such investigations or studies.

7. Term. The initial term of this Agreement shall be for the earlier of (i) completion of a successful
adoption or (ii) one (1) year period commencing at the date of signature or (iii) (the Initial Term), unless sooner
terminated in accordance with the terms of this Agreement. This Agreement shall automatically be renewed for
successive one-year terms after the completion of the Initial Term unless (a) a successful adoption has been
completed, (b) either party elects not to renew by giving written notice to the other party no later than 60 days
2000 South Main Street, Wake Forest, North Carolina 27587
 prior to the beginning of the proposed renewal term or (c) either party terminates by written notice to the other
party. The parties expressly understand and agree that either party may terminate the relationship at any time,
subject to the written notice requirements, with or without cause, for any reason or for no reason at all.

8. Termination. Frank or the Adoptive Parents may terminate this Agreement for any reason whatsoever,
by written notice to the other party. If for any reason either party terminates the working relationship within 45
days of Frank’s initial receipt of your Application to Adopt and the Foreign Child Placing Services Agreement a
refund of $1000, of the agency fee, will be returned. After 45 days of Frank’s receipt of your Application to
Adopt and the Foreign Child Placing Services Agreement no refund will be issued. Furthermore, if the
termination occurs after the child referral process has begun a fee of $250 per child referral will be charged to
the family. The application fee is always non-refundable. In addition, a dossier translation fee up to $250 may
also be applicable.
The application fee and travel-related costs and other In-Country expenses shall not be refundable or
reimbursable by Frank Adoption Center, North Carolina. If the adoptive parents have paid the Escrow fee for
their impending adoption and the adoption is not finalized in the child’s country of origin or placement is not
made, Frank will refund the entire Service & Support amount paid. The same rule applies to the registration and
post-placement/post-adoption deposits. If the family’s visas have already been processed for their impending
trip, the fee charged will not be refunded, due to the service being rendered.
Should Frank terminate its working relationship with the Adoptive Parent(s) the refund will be issued at
the same time as the termination letter is sent. Should the Adoptive Parent(s) choose to terminate their working
relationship with Frank the refund will be processed and distributed 90 days after receiving the written notice
from the Adoptive Parent(s).

9. Opportunity to Consult Counsel. The Adoptive Parents acknowledge and agree that they have had
adequate opportunity to consult with independent counsel of their choosing with respect to the terms of this
Agreement and that they have made their own decision, without any influence by Frank, or any of its agents with
respect to such consultation.

10. Complaints and Grievances. Frank Adoption Center, NC has provided to the client information about
its complaint and grievance policy and procedures as set forth in Exhibit E to this Agreement and the Client
acknowledges receipt of same.

11. Entire Agreement, Modification. This Agreement contains the entire agreement between Frank and
the Adoptive Parents and supersedes all prior agreements between the parties. The parties acknowledge that no
oral or written statement, inducement or representation has been made by any party that is not a part of this
Agreement. This Agreement can be modified at any time only by a supplemental agreement in writing signed by
Frank and the Adoptive Parents.

12. Assignment. This Agreement may not be assigned by the Adoptive Parents at any time.

13. Governing Law. This Agreement shall be governed, construed and enforced in accordance with the
laws of the State of North Carolina, without regard to any conflicts of law provisions. The Adoptive Parents and
Frank hereby consent to the jurisdiction of the state and federal courts of the State of North Carolina over any
disputes arising from, or in connection with, this Agreement.

14. Binding Arbitration. Any dispute arising out of or relating to Adoptive Parents’ adoption shall be
governed by or controlled by the Agreement including any supplements thereto, and subject to binding
arbitration, including the validity of this Arbitration provision. Any dispute will be resolved by arbitration in
accordance with the North Carolina Rules for Alternative Dispute Resolution (Arbitration Rules) with the
exception of Paragraph 2(f) of the Agreement which permits Frank to use all legal processes, including litigation,
to force compliance with post-adoption requirements as identified in Paragraph 2(f) of the Agreement.
The Arbitrator shall apply the substantive law of the State of North Carolina, exclusive of any conflict
of law rules. Arbitration shall be before a sole Arbitrator and shall be in Raleigh, Wake County, North Carolina.
The Arbitrator is not empowered to award damages in excess of the lesser of compensatory damages or
the fees actually paid to Frank as agency fees $4200. The award/decision rendered by the Arbitrator shall be
final and binding, and judgment upon the award/decision may be entered by any court having jurisdiction of
either party. Each party is required to continue to perform its obligation under this Agreement pending final
arbitration award/decision of any dispute arising out of or relating to your adoption or this Agreement, unless
2000 South Main Street, Wake Forest, North Carolina 27587
 either party chooses to terminate this Agreement as permitted by the terms of the Agreement.
Any claim by either party shall be time-barred unless the asserting party commences an arbitration
proceeding according to the Arbitration Rules with respect to such claim within one (1) year from the latter date
of the termination of this Agreement by either party or the completion of your Adoption according to the laws of
the foreign country.

Notwithstanding the completion of your Adoption or the termination of this Agreement, the Arbitration
provision survives the Agreement as the agreed upon method to resolve any conflict arising out of your Adoption
or this Agreement by either party, with the exception of Paragraph 2(e) in the Agreement. All issues relating to
the timeliness of claims shall be resolved by the Arbitrator.

15. No Preferential Treatment. Frank Adoption Center, NC will not show preferential treatment to its
Board Members, contributors, volunteers, employees, agents, consultants, or independent contractors with
respect to the placement of children for adoption from a Convention or a Non-Convention country.

16. Severability. Should any provision of this Agreement be deemed illegal or unenforceable in any
respect, such illegality or unenforceability shall not affect the other provisions of this Agreement, all of which
shall remain in accordance with their terms.

17. Headings. The headings contained in this Agreement are for the convenience of reference only, and
shall not affect the meaning or construction of the provisions of this Agreement.

18. Waiver. The failure of either party to insist in any one or more instances upon performance of any of
the terms or conditions of this Agreement shall not be construed as a waiver of future performance of any of the
terms or conditions contained herein.

19. Recitals. The recitals of this Agreement are intended by the parties to be a material part of this
Agreement and shall be deemed as such.

20. Counterparts. This Agreement may be signed in any number of counterparts, each of which shall be
considered an original and all of which shall constitute one and the same Agreement.

PLEASE CONSULT WITH YOUR OWN ATTORNEY IF YOU HAVE ANY QUESTIONS ABOUT
BINDING ARBITRATION OR ANY OTHER PARAGRAPH IN THIS AGREEMENT.

IN WITNESS WHEREOF, the parties have caused this Agreement to be executed as of the day and date first
above written.

__________________________ ___________________________
Applicant’s Signature Applicant’s Signature

State of ______________________________

County of_____________________________

I _____________________________, Notary Public in and for ______________________

hereby certify that _______________________________________ have personally appeared

before me and signed the fore-going Document this ________ day of _______________, 20____

Notary Public: ______________________________ My Commission Expires: _________________

2000 South Main Street, Wake Forest, North Carolina 27587

 Commitment to the Provision of Post-Placement Reports (96.50(g)(1)(2))

I/We _______________________________ and ______________________________ pledge that I/we

will provide the Government of __________________ with Post-Placement Reports as requested at
____________________________ months after issuing of US visa. These reports will be generated by a
licensed social worker, following a minimum of one visit to our home. I/We will provide a full report
describing the child’s development, achievements, schooling, living conditions and relationships with us
and our extended family, as well as contact information for our family should any questions or concerns
arise.
I/We authorize Frank Adoption Center to share these reports with any relevant parties in the country of
__________________________, along with representatives of the US State Department, North Carolina
DHHS and the US Embassy, should they be requested.

____________________________________ ___________________________________
Signature Signature

____________________________________ ___________________________________
Printed Name Printed Name

_________________________ ________________________
Date Date
 Adoption Service Agreement Supplement: Disruption Plan

In the unlikely event of a disruption during the post-placement phase, Frank will execute the following plans as may be
necessary in the adoption case.

I. If placing a child who has been removed from placement becomes necessary, it is the policy and practice of
Frank to do the following. (96.50(d))
Policy: It is the policy and practice of Frank Adoption Center (“Frank”) that if counseling does not succeed in resolving the
crisis and the placement is disrupted, the agency or person assuming custody of the child assumes responsibility for making
another placement of the child. Frank makes every effort to advocate for children and find children loving and permanent
homes in the United States following a disruption in the United States.
Procedure for placing a child who has been removed from a placement

Step 1: Advocating for Child

Frank’s Executive Director (“ED”) is responsible for placing a child with a second adoptive family following a disruption.
Frank’s ED or her designee with create an implement an advocacy plan for the child in need of a family. The plan and
implementation will depend on the age and needs of the child. The ED may reach out to colleagues regarding the child,
share information about the child in the National Council for Adoption list serv, may share information about the child to
Frank’s currently waiting adoptive families, and advocate with outside websites that maintain a high level of privacy and
confidentiality of the child’s image and information.
Step 2: Locating Qualified Family
Advocacy efforts for the child will direct any interested families to contact Frank. Frank’s ED or her designee may interview
families and review their home studies. Once an interested and qualified family (with a successful home study) is found,
Frank will advise the family to seek legal advice to assist them with the U.S. adoption procedure. Frank will remain in
regular contact with the family to determine that the family is moving forward with the legal process of adoption.
Step 3: Educating and Supporting Family
Frank’s ED is responsible for educating the second adoptive family. The ED will schedule an educational/training call
regarding caring for the child. The ED may also provide applicable resources and ensure that the prospective adoptive
family met the educational and training requirements of their respective state of residence, and any other educational
requirement that need be met prior to placement.
Step 4: Supporting Legal Adoption by Second Family
Frank will remain in regular communication with the second adoptive family for support. Frank will also seek confirmation
that a legal adoption occurred. Frank will report this information as required by both the US Department of State and
IAAME.
II. If removing a child from placement becomes necessary, it is the policy and practice of Frank do the following.
(96.50(e))
Policy: It is the policy and practice of Frank Adoption Center (“Frank”) to act promptly and in accord with any applicable
legal requirements to remove the child when the placement may no longer be in the child's best interests, to provide

Revised 10.2020
temporary care, to find an eventual adoptive placement for the child, and, in consultation with the Secretary, to inform the
Central Authority of the child's country of origin about any new prospective adoptive parent(s).
1. In all cases where removal of a child from a placement is considered, Frank considers the child's views when
appropriate in light of the child's age and maturity and, when required by State law, obtains the consent of the child prior to
removal.
2. Frank does not return from the United States a child placed for adoption in the United States unless the Central
Authority of the country of origin and the Secretary have approved the return in writing.

As is Frank policy and as per Hague Technical Guidance G.12, Frank may use a supervised provider for the responsibilities
outlined in 96.50(d) and (e), including foster care pending a new placement. Thus, in accordance with the requirements of
State law, Frank may use its own licensed foster homes in the case of needed temporary care or may work with a supervised
provider who has licensed foster homes. In either case, Frank policy is to retain the responsibility to ensure that the transfer
and care of the child, even temporary care, are performed in a manner consistent with the Hague regulations.
Procedure for removing a child from placement

Step 1: Identify Placement is in Crisis

Any and all information provided to any Frank team member or supervised provider regarding the instability of a placement
for adoption shall be immediately communicated to Frank’s Executive Director (“ED”). The ED may investigate the issue
further and may make a determination that a placement is in crisis and begin to plan and execute a plan for supporting the
family, if appropriate. Frank may provide or arrange for counseling and support to avoid the disruption, provided that the
continued placement is safe and in the best interests of the child.
Step 2: Assessment of Child’s Safety
Upon a determination that a placement is in crisis, the first thing that the ED will do is ensure that the child is safe. This may
require an investigation. Any allegations of abuse or neglect will be appropriately reported. Frank’s ED acts promptly to
assess the safety and needs of the child. If it is safe and in the child’s best interests to remain in the care of the prospective
adoptive family, Frank may encourage the family to continue caring for the child until a new arrangement can be planned
and made. If the child must be removed from the home for safety, Frank may engage the local Department of Child Services
or other entity for assistance in the child’s removal if the child is in the United States. If the child is in the foreign country,
Frank’s ED may work directly with authorities in the country or with the child’s orphanage or foster home so as not to have
additional new placements for the child. Frank will consult applicable laws, policies and attorneys as may be necessary.
Step 3: Contact Supervised Provider (if applicable)
If the family is in the United States and a supervised provider is involved in the case, Frank’s ED will reach out to the
provider and seek their support and/or involvement in the disruption plan. Frank will make efforts to exhaust counseling
efforts prior to removing a child. The ED will discuss the relevant state laws that may be involved and how to provide
temporary care in the child’s current state of residence and which individual or entity may be most appropriate to take
custody of the child. If a supervised provider is involved, the ED will may efforts to work collaboratively with this
provider to best support the family. This step is inapplicable if there is no supervised provider on the case.
Step 4: Report Disruption to IAAME
Withing two (2) business days of Frank having knowledge of the disruption, Frank’s ED will report the disruption to
IAAME following its instruction from IAAME’s Policy 004.
Step 5: Determine Removal is Necessary
The determination regarding whether removal is necessary is made by Frank’s ED. In cases where removal of a child
from placement is considered, and maturity, age and need allow, the ED will consider the child’s views and may require
Revised 10.2020
the child’s consent to removal, if required by the laws in the child’s state of residence.

Step 6: Securing Access to Temporary Care for Child

The ED, in conjunction with the supervised provider and others involved in the case, will make the best possible efforts to
find a safe and nurturing temporary home for the child as may be required. This may involve working with state social
services and any number of other organizations.
Step 7: Interview Child (if age appropriate)
Frank’s ED will interview the child based in the needs of the child and as age appropriate. Prior to the removal of the
child from care and placement into the designated temporary care, the ED determines the child’s views in relation to the
proposed temporary care solution. If needed, the plans for care may be modified based on the feedback from the child and
the ED’s professional judgement.
Step 8: Preparation for Removal
Frank’s ED will consult will necessary legal counsel prior to the child being removed from a home. Frank will adhere to
all legal requirements. Frank may engage the social services department in the child’s state of residence or enter into a
supervised provider relationship for the removal of the child by a local provider. The ED will determine the appropriate
method of removal when placement may no longer be in the child’s best interest. Removal may be voluntary or
involuntary.
Frank does not return from the United States a child placed for adoption in the United States unless the Central Authority
of the country of origin and the Secretary have approved the return in writing.
Step 9: Removal
Frank’s ED will ensure that the removal follows the removal plan and that all applicable laws are regulations are
followed.

III. If a disruption becomes necessary, it is the policy and practice of Frank do the following. (96.50(d))

Policy: It is the policy and practice of Frank Adoption Center (“Frank”) that if counseling does not succeed in resolving
the crisis and the placement is disrupted, the agency or person assuming custody of the child assumes responsibility for
making another placement of the child.

Procedure for assuming custody and providing temporary care of children whose placement is disrupted
Step 1: Determine Placement is in Crisis
Any and all information provided to any Frank team member or supervised provider regarding the instability of a
placement for adoption shall be immediately communicated to Frank’s Executive Director (“ED”). The ED may
investigate the issue further and may make a determination that a placement is in crisis and begin to plan and execute a
plan for supporting the family, if appropriate. Frank may provide or arrange for counseling and support to avoid the
disruption, provided that the continued placement is safe and in the best interests of the child.
Step 2: Assessment of Child’s Safety
Upon a determination that a placement is in crisis, the first thing that the ED will do is ensure that the child is safe. This
may require an investigation. Any allegations of abuse or neglect will be appropriately reported. Frank’s ED acts promptly
Revised 10.2020
to assess the safety and needs of the child. If it is safe and in the child’s best interests to remain in the care of the
prospective adoptive family, Frank may encourage the family to continue caring for the child until a new arrangement can
be planned and made. If the child must be removed from the home for safety, Frank may engage the local Department of
Child Services or other entity for assistance in the child’s removal if the child is in the United States. If the child is in the
foreign country, Frank’s ED may work directly with authorities in the country or with the child’s orphanage or foster
home so as not to have additional new placements for the child. Frank will consult applicable laws, policies and attorneys
as may be necessary.
Step 3: Contact Supervised Provider (if applicable)
If the family is in the United States and a supervised provider is involved in the case, Frank’s ED will reach out to the
provider and seek their support and involvement in the disruption plan. The ED will discuss the relevant state laws that
may be involved and how to provide temporary care in the child’s current state of residence and which individual or entity
may be most appropriate to take custody of the child. If a supervised provider is involved, the ED will may efforts to work
collaboratively with this provider to best support the family. This step is inapplicable if there is no supervised provider on
the case.
Step 4: Report Disruption to IAAME
Withing two (2) business days of Frank having knowledge of the disruption, Frank’s ED will report the disruption to
IAAME following its instruction from IAAME’s Policy 004.
Step 5: Securing Temporary Care for Child
The ED, in conjunction with the supervised provider and others involved in the case, will make the best possible efforts to
find a safe and nurturing temporary home for the child as may be required. This may involve working with state social
services and any number of other organizations. If age appropriate, the ED will also consider the desires of the child. The
ED will further ensure that all applicable laws and policies are strictly adhered to.
Step 6: Assuming Temporary Custody of Child
If the child resides in North Carolina, the ED will review relevant laws regarding the custody or the child and may seek
advice from Frank’s state licensing liaison or outside legal counsel to ensure all legal requirements are met in determining
if Frank may assume custody of the child.
If the child resides outside of the state of North Carolina, the ED will consult its North Carolina licensing liaison to ensure
that all protocols are followed, and may consult attorneys in the child’s state of residence as well as the relevant offices
administering the Interstate Compact on the Placement of Children (ICPC). Frank may request that a local provider assume
custody of the child as a supervised provider of Frank.
If Frank assumes custody of the child, the requirements and placement will be governed by the applicable laws of North
Carolina and the child’s state of residence. Frank shall not return the child from the United States to the child’s country of
origin without the written approval of the U.S. Department of State and the central authority of the child’s country of
origin.
Step 7: Child Advocacy
Frank will continue to seek permanent placement for the child and advocate that the child be placed with a second or
subsequent loving permanent adoptive family. Frank will continue its efforts to advocate for the child until the child reaches
the age of majority.

Revised 10.2020
IV. If a disruption becomes necessary, it is the policy and practice of Frank that. (96.50(f))

When possible and safe, prospective adoptive parents will retain legal and financial responsibility for transfer of custody
in an emergency or in the case of impending disruption and for the care of the child. If Frank assumes custody of the
child, the requirements and placement will be governed by the applicable laws of North Carolina and the child’s state of
residence. 96.50(f)(1).
If the disruption takes place after the child has arrived in the United States, Frank will only consider that the child, as a
last resort, be returned to the child's country of origin, if that is determined to be in the child's best interests. Frank may
consider the child’s connection to the country, needs, age, etc. in determining the child’s best interest. 96.50(f)(2).
The child's wishes, age, length of time in the United States, and other pertinent factors will be taken into account by
general inquiry from Frank or by interviewing the child, if age appropriate. 96.50(f)(3).
Frank’s Executive Director will inform the Central Authority of the child's country of origin and the Secretary will be
notified. 96.50(f)(4).

Dissolution Services
Frank will not provide dissolution services pursuant to this Adoption Services Agreement. If dissolution services are desired,
Frank may, however, enter into an additional agreement or arrangement to provide such services. 96.51(b).

I/We have read and understood the above document: Frank Adoption Center’s policy and procedure related to the disruption
and/or dissolution of an adoption:

________________________________________ ______________________________________
Signature Signature

________________________________________ ______________________________________
Printed Name Printed Name

_______________________ _____________________
Date Date

Revised 10.2020
 Frank Adoption Center’s Policy Regarding Healthy and Effective Discipline

Frank Adoption Center requires that all adopting families comply with the agency’s policy regarding
discipline of a child in their care, whether the child be in the home via birth, foster placement or
adoption. This policy has been created based on ample research and state and national guidelines:

Adoptive parents, caregivers or any adult or other child living in the home will not utilize:
• Physical punishment, including hitting with the hand or any object, yanking, shaking or pulling
• Restricting movement by tying or binding
• Confining a child in a closet, box or locked area
• Withholding meals, rest or toilet use
• Mental and emotional cruelty, including verbal abuse and/or derogatory remarks about a child or
his or her birth family or country of origin

We/I agree to provide age-appropriate discipline techniques meant to encourage positive growth between
family and child. In the event positive methods prove unsuccessful, We/I agree to seek the services of a
family and child counselor, physician or psychologist to assist us to evaluate the situation and mediate
solutions.

I/We, __________________________________________, have read and agree to the statement

provided above.

Signed:

___________________________________ ___________________________________
Signature Print Name

___________________________________ ___________________________________
Signature Print Name

__________________
Date

Know that we are happy to provide further resources or opportunity for discussion at any time. We
understand that parenting is not easy and are always happy to work with families in the hopes of
making things go a bit more smoothly.

2000 South Main Street, Wake Forest, North Carolina 27587

 Policy Complaint Policy
Procedure Complaint Procedures
References 96.41(a)-(h), Hague Technical Guidance E.8, E.6, E.6a, E.9,

Policy: It is the policy and practice of Frank Adoption Center (“Frank”) to have written complaint policies
and procedures that incorporate the standards in 22 CFR 96.41 (b) through (h) and to provide a copy of
such policies and procedures, including contact information for the Complaint Registry, to prospective
adoptive parents at the time the adoption services contract is signed. It is the practice of Frank to insert the
complaint policy and procedure for submitting a complaint to Frank in each adoption service agreement
and to require signatures by prospective adoptive parents. 22 CFR 96.41(a).

Frank permits any birth parent, prospective adoptive parent or adoptive parent, or adoptee to lodge directly
with the agency or person signed and dated complaints about any of the services or activities of the agency
or person (including its use of supervised providers) that they believe to raise an issue of compliance with
the Convention, the IAA, the UAA, or the regulations implementing the IAA or UAA, and advises such
individuals of the additional procedures available to them if they are dissatisfied with Frank’s response to
their complaint. It is the policy and practice of Frank to inform all complainants regarding the Complaint
Policy, as outlined in Frank’s adoption services agreement. 22 CFR 96.41(b).

It is the policy of Frank to respond in writing to complaints received pursuant to 22 CFR 96.41(b) of this
section within thirty (30) days of receipt, and to provide expedited review of such complaints that are time-
sensitive or that involve allegations of fraud. 22 CFR 96.41(c). It is the policy and practice of Frank to
accept and process a written 96.41(b) complaint regardless of the length of time that has passed since the
event or service triggering the concern. HTG E.6. It is also the policy and practice of Frank not to limit the
acceptance of 96.41(b) complaints to Hague Convention cases, it is the policy and practice of Frank to
accept and process 96.41(b) complaints regardless of whether the issue originated from a Convention or
non-Convention case. HTG E.6a.

It is the policy and practice of Frank to maintain a written record of each complaint received pursuant to 22
CFR 96.41(b) and the steps taken to investigate and respond to it and makes this record available to the
accrediting entity or the U.S. Department of State upon request. 22 CFR 96.41(d).

Frank does not take any action to discourage a client or prospective client from or retaliate against a client
or prospective client for: making a complaint; expressing a grievance; providing information in writing or
interviews to an accrediting entity on Frank’s performance; or questioning the conduct of or expressing an
opinion about the performance of Frank. 22 CFR 96.41(e).

Frank provides to the accrediting entity and the Secretary, on a semi-annual basis, a summary of all
complaints received pursuant to 96.41(b) during the preceding six months (including the number of
complaints received and how each complaint was resolved) and an assessment of any discernible patterns
in complaints received against the agency or person pursuant to 96.41(b), along with information about
what systemic changes, if any, were made or are planned by the agency or person in response to such
patterns. 22 CFR 96.41(f).

96.41 Complaint policy and procedures Page 1 of 7

Frank provides any information about complaints received pursuant to 96.41(b) of this section as may be
requested by the accrediting entity or the Secretary. 22 CFR 96.41(g).

Frank understands and appreciates that feedback from any birth parent, prospective adoptive parent or
adoptive parent, or adoptee. It is the policy and practice of Frank to view such feedback as an opportunity
to continue to improve the quality of services it provides.

It is the policy of Frank to have a quality improvement program appropriate to its size and circumstances
through which it makes systematic efforts to improve its adoption services as needed. The agency or
person uses quality improvement methods such as reviewing complaint data, using client satisfaction
surveys, or comparing the agency's or person's practices and performance against the data contained in the
Secretary's annual reports to Congress on intercountry adoptions. 22 CFR 96.41(h)

Frank’s Complaint Procedure – For Processing Complaints Internally

Step 1: Dissemination of Grievance and Complaint Policy

Frank discloses its Complaint Policy to prospective adoptive parents upon initial contact in its Adoption
Services Agreement. See below. In the event an adoptee or birth parent contacts a Frank staff member with
a concern, the staff member in receipt of the concern will provide the concerned individual with the
Complaint Policy. 96.41(a).
Step 2: Front-line Resolution
The Frank staff recipient of any concern, that the Frank staff member deems easily resolvable shall make
efforts to resolve the concern. Examples of an easily resolvable concern would be that a client desires more
communication, the staff member made an error for which s/he should apologize, the client needs additional
information, the client is dissatisfied by wait times as a result of the foreign or U.S. government, etc. In
these matters the front-line staff member will attempt resolution of the concern. If the concern is more
significant than an “easily resolvable concern” the Frank staff member in receipt of the concern will notify
Frank’s Executive Director (“ED”).
Step 3: Executive Director Resolution
Once the Frank staff member shares the concern with their ED, the ED will determine if the concern raises
an issue of compliance with the Convention, the IAA, the UAA, or the regulations implementing the IAA
or UAA. The ED is responsible for determining whether the matter is a 96.41(b) complaint trigging the
Complaint Procedure, or a concern, which would not trigger the Complaint Procedure. 96.41(b).
Resolution of concerns - If the concern does not appear to raise an issue of compliance, and the complainant
has not alleged that the concern raises and issue with the IAA, the UAA, or the regulations implementing
the IAA or UAA, the ED may attempt to resolve the issue directly. The resolution of concern will depend
on the concern itself. The ED is responsible for this level of resolution. She will make initial efforts to
investigate the concern and understand the issue by contacting the front-line Frank staff member (if
applicable), the complainant and/or any other relevant staff members or supervised providers to create and
implement a plan for resolution of the concern that does not rise to the level of a 96.41(b) complaint. If the
concern is not able to be resolved by the ED, the ED may, at her sole discretion, engage Frank’s Board of
Directors in an effort to resolve the concern.
Resolution of complaints - If the matter raises an issue of compliance with the Hague Convention, IAA or
UAA, as determined by the ED, she will ensure the complainant has received the Complaint Policy. The

96.41 Complaint policy and procedures Page 2 of 7

ED may direct a current client to their Adoption Service Agreement or otherwise provide a copy of the
Complaint Policy to the complainant. The ED may instruct the complainant to submit the complaint in a
signed and dated writing to the ED. The ED may further instruct the complainant to include: (1) a detailed
description of the complaint; and (2) desired outcome of the complaint, if the complainant has not done so
already. The remainder of this procedure is specific to 96.41(b) complaints only.
Step 4: Executive Director’s Receipt of Written Complaint
Upon receipt of a written complaint by the ED, the ED will confirm receipt of the complaint to the
complainant and advise the complainant that they will receive a response from Frank within thirty (30)
days. The ED may inform relevant Frank staff, if applicable, that a complaint has been made. The ED will
create an action plan for responding to the complaint which will include an investigation process and a
deadline to respond to the complaint within thirty (30) days.
Step 5: Investigation of Complaint
Frank’s ED will create and implement a plan to investigate the complaint. The plan will be created on a
case-by-case basis based on the unique complaint and allegations. Some ways Frank may investigate
include, a review of the case file, a review of communication with the complainant, review of
communication with any relevant supervised providers, communication with the foreign government or
foreign individual or entity, interviews, etc. The ED will be responsible for implementation of the plan and
documenting the investigation.
Step 6: Executive Director Resolution in Writing
Within thirty (30) days of the date that the written complaint is received, Frank’s ED will provide a written
decision (“Decision”) to the complainant. The response will be emailed no later than thirty (30) days after
the complaint is received. To the extent that the complaint is time sensitive, review may be expedited. The
ED will draft a detailed response to the complainant, to include a detailed response to the allegations and a
proposed resolution, if applicable. The ED may, at her sole discretion, consult the Board of Directors at this
stage in the complaint resolution process. The Decision shall also include instruction on Frank’s internal
appeal process, if the complainant is dissatisfied with Frank’s response.
The complainant will be instructed to provide a written Request for Review within fifteen (15) business
days of receipt of the Decision is dissatisfied. The Decision shall provide instructions on where to submit
such a request. The Decision will further instruct the complainant on how to respond, advising the
complainant to include in the Request for Review, the reasons for disagreement with the Decision and the
outcome desired by the complainant. The ED shall save the complaint, Decision and any investigatory
material in Frank’s files (for submission with the Semi-Annual Complaint Report).
Step 7: Board Resolution in Writing
If the complainant submits a Request for Review to Frank’s Board of Directors within fifteen (15) business
days from the date that the Decision is sent, the Board of Directors will respond within thirty (30) days.
The Board will call a meeting to discuss the complaint and consult with Frank staff, and others, as may be
needed.
The Board President or their designee will draft the response to the complainant in consultation with Frank’s
ED. The Board Decision will be the final agency action. The complainant will be advised that the Board
Decision is the final agency action and provided with instruction on how to complain to the Hague

96.41 Complaint policy and procedures Page 3 of 7

Complaint Registry, including the link to make such a complaint, if still dissatisfied with the resolution.
Complaint Registry: http://adoption.state.gov/hague_convention/agency_accreditation/complaints.php
The ED is responsible for gathering and saving the Board Decision and saving in Frank’s files (for
submission with the Semi-Annual Complaint Report).
Step 8: Record Maintenance & Dissemination to Accrediting Entity
It is the responsibility of the ED to record and maintain all records related to the complaint. The information
contained in the records shall be reported semi-annually in the Semi-Annual Report on Complaints
(“SARC”) and the full file(s) will be made available upon IAAME’s request by Frank’s ED. 96.40(d).
Step 9: Reporting the Complaint
Frank’s ED is responsible for completing the SARC. The ED shall calendar and track the due dates for the
SARC report to ensure timely submission and report pursuant to the instructions outlined in IAAME’s
Policy 004 and in any other manner as requested by the accrediting entity or the Secretary. 22 CFR 96.41(g).
It is the responsibility of the ED to respond timely to all complaint-related requests from the accrediting
entity or the Department of State. The ED will respond as prescribed by the Secretary and/or accrediting
entity and thoroughly answer questions and/or document requests. The ED will document complaint-related
communications with the accrediting entity or Secretary in the record.
Step 10: Frank’s Review of Complaints for Quality Improvement Purposes
As a part of Frank’s Quality Improvement System, it reviews the complaints it receives for quality
improvement purposes. All complaints are provided to the Quality Improvement Committee of Frank’s
Board of Directors for review and implementation of quality improvement efforts. See Frank’s Quality
Improvement System below.

Frank’s Complaint Procedure – For Complainants to Lodge Complaints

Complaint Resolution Procedure Frank Adoption Center’s Grievance Policy is designed to permit any
client the right to lodge a signed and dated complaint about any of the services or activities of this agency
or persons involved with this agency that are believed to be inconsistent with state or federal laws and
regulations or standards of accreditations that pertain to Frank Adoption Center.
All complaints must be filed in accordance with Hague Convention regulations.
There are two types of grievances: formal and informal:
Informal Grievance: Frank Adoption Center urges all clients express their concern to Frank directly
before filing a formal grievance. To express concern, please contact the agency’s Executive Director and
clearly explain the issue. Allow time to talk about the problem, for the agency to seek additional advice if
needed, and to work with the agency to form a plan for moving forward in the best way possible for all
involved parties.
Formal Grievance (“Complaint”): In the event that an informal grievance does not result in a satisfactory
solution to the problem, or the client feels an informal discussion is not the best course of action, a formal
grievance may be filed. The following steps are to be followed when filing a formal grievance:

96.41 Complaint policy and procedures Page 4 of 7

 1. The person bringing forward the complaint should do so in a signed, dated and written format.
The complainant should explain which services or activities provided by Frank (or a supervised
provider of Frank) the complainant believes to raise an issue of compliance with the Hague
Convention, the Intercountry Adoption Act, the Universal Accreditation Act and any
implementing legislation thereof. 96.41(b).

2. Written complaints should be submitted to the Executive Director via US Postal Mail or via
email. Should the complaint be directly related to the Executive Director, the written complaint
should be directed to the Board of Directors’ President.

3. The Executive Director, or Board of Directors’ President, must respond in writing to complaints
received within 30 days of receipt, and provide expedited review of such complaints that are
time-sensitive or that involve allegations of fraud. 96.41(c).

4. The written response will include the steps taken to investigate and respond to the complaint.
96.41(d).

5. All written complaints and responses will be reviewed at the next regularly scheduled Board of
Directors' meeting. Frank Adoption Center will not take any action to discourage a client or
prospective client from or retaliate against a client or prospective client for: making a complaint;
expressing a grievance; providing information in writing or interviews to an accrediting entity on
the agency’s performance; or questioning the conduct of or expressing an opinion about the
performance of Frank Adoption Center. 96.41(e).

6. If the complaint concerns or raises an issue of compliance with the Hague Convention or the U.S.
implementing statutes and regulations, any consumer dissatisfied with Frank Adoption Center’s
resolution may file with the Hague Complaint Registry. Contact information and procedures for
the internet based Hague Complaint Registry: (any submissions must state with specificity the
date and nature of the complaint, including names of persons involved, and be signed and dated):
http://adoption.state.gov/hague_convention/agency_accreditation/complaints.php. 96.41(a).

Frank’s Complaint Procedure – For Using Complaints for Quality Improvement

Frank Adoption Center (“Frank”) has a quality improvement program appropriate to its size and
circumstances through which it makes systematic efforts to improve its adoption services as needed.
Frank uses quality improvement methods such as reviewing complaint data, using client satisfaction
surveys, or comparing Frank’s practices and performance against the data contained in the U.S.
Department of States annual reports to Congress on intercountry adoptions. 22 CFR 96.41(h).
Ongoing Regular Quality Improvement Efforts: Frank takes quality improvement seriously. Frank
believes that continuous education and improvements based on new information is necessary to provide
excellent services to its client families. Frank believes that quality improvement efforts are best when they
are ongoing allowing Frank to quickly make changes that will improve the quality of services provided to
future children and families. Frank further believes in seeking and providing creative solutions for its
organization, clients and the children it serves. As Frank believes in continues improvement and creative
problem solving, below is a list of ongoing improvement efforts made by Frank, though the list is not
exhaustive.

96.41 Complaint policy and procedures Page 5 of 7

 • Regular Client Communication – Frank’s staff make efforts to ensure that they are in regular,
direct, and personal contact with client families. Frank’s staff works to develop a trusting and
transparent relationship with all client families. Frank is open to feedback and encourages the
sharing of both positive and negative feedback from client family regarding the services provided
by Frank. When a client conveys a noteworthy expression of satisfaction, that feedback is shared
with Frank’s Executive Director (“ED”). The ED is responsible for quality improvement efforts
and for determining what, if anything, should be done to best ensure continued satisfaction.
Similarly, when a client expresses noteworthy negative feedback, that information is to be shared
with the ED. The ED is responsible for determining what, if anything, should be done to improve
satisfaction in that area indicated by the client family.

• Regular FSP Communication – Frank’s staff is in communication with foreign supervised

providers (“FSPs”) regularly when serving a mutual client with an active case. Frank
communicates with FSPs regarding various issues, including case-specific issues and issues and
changes in the country related to intercountry adoption. Frank staff communicates any
noteworthy information gained from these communications. The ED will decide whether efforts
can or should be made based on the information received to improve the quality of services
offered by Frank. Frank’s ED analyzes the issues, plans for, and implements improvement
measures on an as-needed, on-going, and case-specific basis.

• Regular Staff Communication – Frank staff are in regular communication with Frank’s ED. The
ED is focused on quality improvement in communications with staff and others related to its
clients and programs. The ED may determine that quality improvement efforts are necessary
based on communications and will be responsible for planning for and implementing quality
improvement plans based on staff feedback. Frank’s ED analyzes the issues, plans for, and
implements improvement measures on an as-needed, on-going, and case-specific basis.

• Communication with the Adoption Community – Frank’s ED is actively engaged with other
leaders in the intercountry adoption community. Frank’s ED is a member of the National Council
for Adoption and participates in its active and educational listserv. This listserv is an invaluable
resource for sharing information regarding best practices and having questions answered. The ED
monitors the communications on this listserv to determine if there are opportunities for quality
improvement. If the ED determines that there is an opportunity for improvement that would
benefit Frank to pursue, the ED will create a plan for the improvement, implement the plan and
monitor the implementation of the plan.

• End of Process Client Surveys – Frank’s ED or her designee will send a survey to each Frank
client family at the end of their intercountry adoption process. The information gathered may
include, but would not be limited to, overall satisfaction with Frank services, satisfaction with
foreign support, and satisfaction with Frank’s communication. Frank’s ED gathers this
information and reviews it to determine opportunities for improvement and to implement quality
improvement efforts.

96.41 Complaint policy and procedures Page 6 of 7

 • Quality Improvement Committee – Frank’s Board of Directors includes a Quality Improvement
Committee who meets quarterly to discuss opportunities for improvement and creates and
oversees quality improvement efforts to be made by the ED. The Committee will document
improvement efforts in meeting minutes.

Semi-Annual Quality Improvement Review – Frank’s ED is responsible for completing and submitting
Frank’s Semi-Annual Report on Complaints (“SARC”). Frank’s ED uses this as an opportunity for
improvement and will consider whether the complaint warrants any specific quality improvement efforts.
If the complaint(s) lead the ED to determine that quality improvement efforts are necessary or desirable
because of the complaint, the ED will plan for and implement such quality improvement efforts. 96.41(f).
Annual Quality Improvement Review – Annually, Frank’s ED reviews the fiscal year report posted by
the U.S. Department of State. The purposes of this review is to understand the overall state of intercountry
adoption, to compare the number of intercountry adoptions completed in each country by Frank versus
nationally, and to compare the fees charged by Frank with the average fees charged among other adoption
service providers nationally. This fiscal year report is reviewed by the ED, who will determine if quality
improvement efforts should be made, and if so, to create and implement an improvement plan.

96.41 Complaint policy and procedures Page 7 of 7