Last month, the State Department announced that eight of the remaining estimated 160 international adoption providers had halted work, some by choice and others because of failure to complete renewal of their accreditation with the government.
Intercountry adoption has been on a downhill slide for a number of years, seeing an almost 80 percent decrease in the number of adoptions since 2004. The path to this point is woven with country closures for political reasons (Russia), concerns about unethical practices (Guatemala) and growing domestic adoptions in some countries (China).
These declines have also made it more financially challenging for agencies to continue facilitating intercountry adoptions.
But the announcement of adoption service providers exiting the space also comes as the State Department’s previous accreditor, the Council on Accreditation (COA), is being replaced by a newly formed organization, the Intercountry Adoption Accreditation and Maintenance Entity (IAAME).
State Department officials say the transition between accreditors is going well, but several agencies contacted by The Imprint have voiced frustration with the accreditors and the government.
“We started this so early so we could avoid this,” said Kelsey Melvin, assistant director of Faith International Adoption, one of three organizations whose renewal failed under the outgoing COA. “It’s COA on the one hand, but it’s clear that the State Department wants to decrease adoptions.”
Back to Square One
Faith International Adoption was just a week away from renewing its ability to finalize intercountry adoptions when its accreditor, COA, asked for a third round of additional information.
The agency leaders worked around the clock and responded to all the concerns within one day, but the deadline passed without COA approval, Melvin said. In previous rounds, if an agency’s accreditation lapsed, COA was allowed to continue the review process and accreditation was restored after the process was complete, unless there was a reason found that an agency could not be reaccredited.

Richard Klarberg, COA: State Department’s changes are “detrimental to international adoptions”
But now Faith International Adoption, and two other providers – Amazing Grace Adoptions and Adopt Abroad International, both also nearly finished with the renewal of their licenses to operate – have been told by the State Department to start the process all over again.
The State Department has told the providers that if they want to restart the process, it will be done through IAAME. That could mean several months without a license: State just gave IAAME the greenlight to start accepting applications in April.
COA said it disagreed with the State Department’s characterization of its work on this case.
“We had not expected State to characterize the posture of our work as a ‘refusal to accredit,’ and hence an adverse action. We did not ‘refuse to accredit,’” said Richard Klarberg, president and executive officer of COA, in an email to The Imprint. “We have said to the three agencies and to IAAME that we will cooperate fully by providing full access to the work that we have already done with regard to what was then their reaccreditation.”
The three agencies must also transfer all adoption cases in process to another accredited adoption service provider and cannot facilitate any international adoptions until their accreditation is reinstated.
Having already invested $15,000 in the reaccreditation process (not including all the time the staff has put into the process) the whole situation has Melvin and other agencies questioning how smoothly this transition will go.
“Now we have to start at square one with an agency that’s never done an accreditation,” said Melvin of Faith International. “We’ll have additional fees. We’re 99.9 percent done so we’ve paid for everything.”
Transition Turbulence
COA has served as the primary accrediting entity for State Department for the past 10 years, ever since The Hague Convention on Intercountry Adoption took effect in the United States, setting up the accrediting process for adoption service providers.
In October 2017, COA announced it would end its relationship with the State Department, citing a number of challenges in continuing to serve as an accrediting entity.
“We have reluctantly concluded that unilateral changes being imposed by the Department constitute ‘unforeseen circumstances’ that will render COA unable to continue its duties as the Department’s Accrediting Entity (AE) for intercountry adoption after more than a decade in this role,” Klarberg wrote, in a letter to Assistant Secretary of Consular Affairs Carl Risch.
Among the problems cited in Klarberg’s letter were changes to COA’s responsibilities that he considered “detrimental to international adoptions and inconsistent with COA’s philosophy and mission.”
One central source of contention appears to be over foreign employees and partners of the adoption agencies. Agencies have long been required to show formal, supervisory agreements with foreign service providers (FSP), the people on the ground in other countries working to finalize adoptions for American families.
Recently, the State Department instructed COA to require agencies to have other partners abroad, including government entities, such as state-run orphanages, enter a supervisory agreement as well.
Not long before COA’s departure, the State Department announced that a new accrediting entity, Florida-based nonprofit IAAME, had been created.
When COA’s departure became official, State prepared to gradually move all accreditation work – new applications and renewals – to IAAME by December 2018.
A State Department official told The Imprint in late 2017 that the responsibility for these supervisory agreements was already part of COA’s job.
“It’s our opinion these are not new requirements,” said Suzanne Lawrence, the special advisor for the State Department’s Office of Children’s Issues. “IAAME is coming in knowing what our expectations are.”
Both IAAME and State Department officials say the transition on accreditation is going smoothly.
“The Department, IAAME, and COA are working collaboratively and communicating regularly to ensure that each phase of the transition plan moves forward as planned,” a State Department official shared in an email to The Imprint.
“The transition process has been going smoothly as anticipated,” said Kim Loughe, executive director for IAAME. “The Council on Accreditation is completing renewals for eligible ASPs [adoption service providers] who will expire in 2018. IAAME is ready to take on new applicants and is working on the renewal process with ASPs due for renewal in 2019.”
Choosing to Leave
On the same day that the three agencies were refused accreditation, the State Department noted that several agencies had decided to allow their accreditation to expire – Adoption S.T.A.R., AAA Full Circle Adoptions, Inc., Buckner Adoption and Maternity Services, and Grace International Adoption Agency. State announced later in April that another provider, Center for Global Adoption, was also dropping out of international adoption.
These are just a few among a long list of agencies in the last two years that have not sought reaccreditation. As

Adoption S.T.A.R. Director Michele Fried on leaving international adoptions: “We saw the writing on the wall.”
intercountry adoption numbers have nosedived – from 22,989 in 2004 to just 4,714 in 2017 – so have the number of agencies providing international adoption services.
In March, Ryan Hanlon, vice president of education, research and constituent services for the National Council for Adoption (NCFA), which represents the interest of adoption agencies, estimated that the number of intercountry adoption agencies has fallen to 160 from a peak of about 200. “In four years, I can’t imagine there will be 100,” he said in an email to The Imprint.
Molly Reynolds, director of AAA Full Circle Adoptions, said the decision not to seek reaccreditation was because of the growing cost of international adoptions and her agency’s desire to concentrate on domestic adoptions. Reynolds said the exit of two licensed attorneys from the agency also made it difficult to meet the level of expertise required to facilitate international adoptions.
Adoption S.T.A.R. Director Michele Fried said their decision to not seek reaccreditation was part of the growing challenge and frustration in providing intercountry adoptions.
“We informed COA on Feb. 21, 2017 that we would not seek reaccreditation,” Fried said. “We cited that State Department’s overly burdensome policies were making it challenging. With all the challenges and international adoption plummeting it was in our best interest.”
Having been one of the earliest agencies to seek accreditation after the Hague was implemented, Fried said there was a desire for the agency to go out with a stellar record.
“I wanted to go out on a high with it being our choice,” Fried said. “We saw the writing on the wall.”
While the decision to not seek accreditation was made prior to COA’s announcement that it would no longer serve as an accrediting entity, Fried said it was another sign of the issues currently facing intercountry adoption. Operating in Bulgaria and Hungary, Adoption S.T.A.R. finalized all of its pending adoptions prior to the organization’s accreditation expiration. Now, the agency is focusing on a growing domestic older child adoption program.
“We’re saddened by the turn international adoption has taken,” Fried said. “I hope it changes, but I don’t think that will happen anytime soon.”
Child welfare policy consultant Maureen Flatley said while the exit of COA is a sad departure of a long-time quality accrediting entity with years of expertise in the area, blaming the State Department for the decline in intercountry adoption is shortsighted.
“State Department is the regulatory body and what they’re attempting to do now is probably what should have been done in the first place,” said Flatley. “What they’re fundamentally trying to accomplish is admirable. It’s time for all the parties to work together.”
Buckner Vice President of Communications Scott Collins said the agency has chosen to no longer serve as an accredited intercountry adoption agency in part because of the growing challenges in intercountry adoption, including the closure of Russia a few years ago and changes at the State Department.
“It’s just the changes in the political environment,” Collins said. There were “ongoing governmental changes” in the countries Buckner was operating in and “we saw changes in our own State Department.”
John Kelly contributed to this article