Unlike most state agencies in Colorado, the Division of Youth Services (DYS) – which is overseen by the Colorado Department of Human Services – develops its polices internally among agency leadership with no opportunity for outside entities to participate or observe. This raised questions about whether the DYS operates in compliance with state laws that require agencies provide notice and accept feedback on proposals for new rules.
The CPO reviewed hundreds of pages of DYS policy documents, research associated laws and regulatory procedures and inter views DYS staff, leadership and juvenile advocates. That study was used to produce an issue brief outlining concerns with the DYS’ lack of formal, transparent or publicly accessible process. Specifically, the CPO found that the DYS’ current guidelines lack elements that are common in the inclusive and transparent rulemaking processes of other state agencies.