On November 12 -13, 2014, an administrative law judge in Tallahassee heard evidence and arguments in the Proposed Rule Challenge brought against DJJ by FAC and 27 counties.  The Rule Challenge was filed after DJJ held a series of rule workshops over the summer in an attempt to promulgate rules that comply with s. 985.686, F.S., the juvenile cost-share statute.  Although DJJ did make some revisions requested by the counties, FAC ultimately believed that the proposed rules did not comply with the mandates of the law.   Again at issue is the legal definitions of “predisposition” and “postdisposition” days , which determines the financial obligations of the counties and state.  Of particular concern to the counties is that in promulgating the new rules, the Department once again seeks to modify its policies and practices  to begin charging counties for detention days when a youth is on probation and commits a new law violation.  This is contrary to the Department’s practice in FY13-14, where it assumed all detention days for youth on probation regardless of the reason the youth was in detention.  The negative fiscal impact to counties as a result of this change in policy is estimated to be over $21 million.   No deadline has been set for issuance of the Final Order, but we do not expect it any earlier than mid-February 2015.