Georgia senators probe delays, new rules and unlicensed agencies in interstate child-placement process

Sen. Kay Kirkpatrick opened a special Senate committee meeting on the Interstate Compact for the Placement of Children (ICPC) saying the session was intended as an informational hearing: “We’ll not be voting today or making any motions,” and “the purpose is to understand the process and to give all parties a chance to be heard,” she said.

The committee heard a national overview of compact law, detailed state statistics and timelines from Georgia Department of Human Services (DHS) staff, and a sequence of firsthand accounts from adoption attorneys, licensed agencies, birth mothers and adoptive parents about repeatedly changing checklists, delayed packet reviews and the role of unlicensed intermediaries. The session included presentations from Rick Masters, a national compact attorney, DHS deputy commissioner Bridal Pedersen, ICPC administrator Aletta DeJola Adegin, special assistant attorney general Dina Krim, and RCCL inspector-general staff.

Why it matters: lawmakers and adoption professionals said processing delays and shifting requirements are keeping newborns and adoptive families away from their homes for weeks to months, raising legal and practical questions about uniform implementation of the ICPC, protections for birth parents and whether Georgia’s changes exceed national practice.

National compact background and the new ICPC. Rick Masters, a long‑time compact lawyer and consultant, told the committee compacts are contracts among states that provide uniform procedures; the ICPC dates to the 1950s and has been updated with a newer model compact that a number of states have adopted. Masters said the intent of the revised compact is to strengthen rulemaking and governance to reduce court challenges and enforcement confusion across states.

DHS staffing, caseloads and timelines. Bridal Pedersen, deputy commissioner for DHS’s Office of Health Law and Policy, said Georgia’s ICPC unit has been reorganized and that staff have already updated guidance and the public website. DHS provided the meeting with fiscal‑year workload figures: roughly 1,600 receiving‑state ICPC cases in FY25 (about 77% public matters, about 17.5% residential changes and roughly 5.6% private adoptions) and about 863 sending‑state cases (about 71% public matters, 22% residential and 6.4% private adoptions). DHS said the ICPC unit has processed nearly 2,500 sending and receiving cases so far in FY25.

DHS staff walked the committee through the ICPC regulatory categories and schedules used in Georgia: for many placements (regulations 1 and 2) senders may request a home study within three days, Georgia aims to complete assigned home studies within 45 days, issue a decision within three days after that, and—if approved—allows up to 180 days to use the approval. For licensed residential placements (regulation 4) DHS has a shorter clock: three days to approve or deny and 30 days to place after approval. Expedited placements under regulation 7 have shorter home‑study windows (assign in one day, complete in 15 days and transmit a decision within three days). DHS staff said Georgia strives to meet the receiving‑state Reg. 12 deadline (three business days) for private adoptions and that the agency typically meets that target “the vast majority of the time.”

“...we’re just getting started on this,” Pedersen said of the unit’s reforms, and she described updates to the public checklist and a more robust ICPC web presence.

Checklist changes, moving goalposts and practitioners’ concerns. Several adoption attorneys and agencies told the committee that, beginning in late 2023 and into 2024, Georgia’s ICPC office repeatedly changed the materials it required in outgoing and incoming packets and sometimes asked for items not specified in national Regulation 12. Attorneys said that shifting requirements — including requests for full maternal medical records in some cases — created weeks‑long delays when families were staying out of state with newborns.

Dina Krim, a DHS attorney who has reviewed outgoing private adoption packets, told the committee: “Regulation 12 gives the receiving state 3 business days to review the packet and approve or deny the adoption request.” She added that Georgia’s updated checklist was intended to reduce processing delays caused by incomplete packets but that private adoption packets are often complex and time‑sensitive.

Attorneys who handle interstate private adoptions said they sometimes receive late requests for documentation or new requirements after a packet has been submitted. “Moving the goalpost” was the phrase several practitioners used to describe the experience; attorneys and licensed agencies asked for clearer notice when checklist items change and for a formal appeals or review pathway where DHS returns a packet as incomplete.

Enforcement, interagency agreements and unlicensed placement actors. Residential Child Care Licensing (RCCL) in DHS’s Office of Inspector General has enforced a rule requiring out‑of‑state child‑placing agencies that place children in Georgia to either be licensed in Georgia or to have an approved interagency agreement (IAA) with a Georgia licensee. RCCL said it began active administrative review and outreach in mid‑July 2024. Since July 15, 2024 RCCL reported receiving 130 IAA submissions, approving 76 and finding 51 with “no jurisdiction”; two were withdrawn and none were denied as of the snapshot presented to the committee.

RCCL said it has opened investigations that led to citations for unlawful child‑placing activity. The agency described two citation levels: substantial‑compliance warnings for entities that appeared unaware of Georgia requirements and higher‑level citations where there was evidence of intentional or deceptive conduct. RCCL said it has prioritized quick administrative resolutions in many cases and that it copies the ICPC office on determination letters so sending‑state ICPC offices receive IAA approvals sooner.

Private testimony: families and birth parents. The committee heard numerous personal accounts. Adoption attorneys and agency directors described long‑standing industry practices, variable fees, and agencies that will pay birth mothers’ expenses — a practice that state law restricts to defined categories of permissible living‑expense or medical payments. Several licensed agencies and attorneys supported stronger scrutiny to stop unlicensed or deceptive intermediaries; others warned that overbroad or inconsistent requests can disrupt otherwise lawful placements.

A birth mother who testified said she had been moved across state lines for placement in another state; attorneys and advocates described instances in Georgia where non‑licensed entities or facilitators used out‑of‑state agencies to arrange placements. Some adoptive parents described long waits in hotels or Airbnbs with newborns while approvals were pending; one adoptive couple said tri‑state review delayed their return home beyond the holidays.

Policy proposals and next steps. Committee members and witnesses discussed administrative fixes, better interagency coordination and legislative remedies. Witnesses and a working group recommended exploring the Uniform Unregulated Child Custody Transfer Act (a model act crafted by a national drafting group) to give states clearer tools to prohibit and prosecute dangerous or commercial transfers that circumvent licensing and oversight. Multiple speakers asked DHS to commit to regular stakeholder meetings so practitioners and agencies can see changes to checklists before they are published.

What the committee requested. Senators pressed DHS for data on the proportion of incomplete packets, a clear timeline of average processing times by regulation type, and more specifics about how ICPC requests are escalated within the agency. DHS agreed to provide supplemental data to the committee and to continue stakeholder outreach.

The hearing ended without votes; Chair Kirkpatrick closed the meeting after asking staff to follow up on open questions and promising to keep the committee informed.

Ending: Senators and stakeholders left the hearing with a cautious consensus that Georgia needs both better enforcement of unlawful child‑placing activity and clearer, more consistent procedures so lawful interstate adoptions are not delayed by shifting administrative practices.