Dear President Gecker and Members of the Virginia Board of Education:

My name is Rachel McLaughlin. I am the lead teacher in the City of Charlottesville's Post High Program, Parkside. I work with students ages 18-22 with moderate to severe disabilities and have been a public school teacher for 19 years.

Overall, I support the proposed regulations pertaining to seclusion and restraint however I am concerned with the current language that recommends “all school personnel” must receive the initial training that focuses on skills related to positive behavior support, conflict prevention, de-escalation, and crisis response as well as the regulations, policies and procedures governing the use of physical restraint and seclusion. I believe this will add an unnecessary burden for divisions to train school employees that do not come into contact with students on a regular basis. I request consideration to revise the proposed definition of “all school personnel” to language that limits personnel required for this training to include “all school-based personnel who have ongoing, direct contact with students in instructional and school support roles.”  I hope the Board can perform a brief edit that limits division personnel affected by these regulations.

In addition, I am concerned with the cost of training and request that training costs be funded by the VDOE, not local school divisions if these new requirements are implemented. Special education funding is already sparse. My program does a lot of fund-raising in order to attend special events or dine out for special community meals. Transportation for special education in my district is already streched thin with barely enough vehicles and vans to meet the needs of our programs and students. Adding any additional mandatory training that would cost my district significant money would be detrimental to my program.

Thank you for the opportunity to provide public comment as you finalize the Virginia Seclusion and Restraint Regulations.

Sincerely,

Rachel McLaughlin, Parkside teacher