This is a general overall comment:  When reading the two regulations (this one and the one for Conditions for licensure....it seemed that the verbiage used in the regulation for Education Programs referred many times to the qualifications/competencies needed for teachers, instead of the subjects/topics that the Higher Education Programs need to include.  It is just a matter of writing the required components of an Education Program in a way that can be more easily translated into a curriculum program  (e.g., "early educators must understand...." could be changed to, "study of and demonstration opportunities on (the topic)"; "demonstrated proficiency in the use of technology..." could be changed to, "provide hands-on opportunities to facilitate technology proficiency in the classroom...").                   more...

And...thank you for the opportunity to comment from VDSS.  We appreciate our partnership with VDOE and want to align what we are doing in child care with your good work in PK-12.  Several staff here are, or were, licensed EC or Elementary Education teachers in the public schools.  We believe that if all teachers and caregivers understand the imprtance of the earliest experiences and how they impact future learning, we can improve our teaching practices, and at the same time, facilitate stronger learning capability in all children.  Thanks, again.  Please contact me if I was not clear.