Prior to 2012 VA DSS followed standard payment practices by paying for their clients enrollment in care.  When the ECCC systemm was implemented, this changed and now parents must pay if their child has too many absences.  This has resulted in widespread illness in centers as children are brought to school sick.  Parents are placed in impossible positions when balancing what they can pay for and their child's care.  By changing this policy the State of Virginia is putting the health of these children at risk.  There are many legitimate reasons why a child's absences may exceed the number allowed and most have nothing to do with just not showing up!  And if that were the case, there are checks and balances in place to make sure that gets reported promptly.

I am a single parent with more than one child.  When one of my children is sick I have to leave work and stay home and take care of my child which means I lose pay. When my child runs out of absenses due to illness or other reason, I don’t think it’s fair that we have to pay for a day they missed. Not only do I lose pay for missing work but now I have to pay more than I am used to paying for childcare. While 35$ doesn’t seem like a lot, it is a lot to a single mom with kids. When my child is ill or not feeling well, I make sure I do not bring my child to daycare.   Limiting absences is unrealistic especially when children are constantly around many germs and illnesses that spread! Personally my child missed more days than alloted because I kept her home when she was sick yet I was penalized for it with having to pay for the day she wasn’t there out of pocket.

I hope that there can be a change with that policy.

I am very grateful for the assistance that the Virginia DSS provides for my family in assisting with childcare fees. However, their policy limiting the number of absences they will pay for is concerning. If my child is absent it is because they have become sick due to being exposed to various germs they have encountered at the daycare facility.  The daycares policy about sickness and illness usually prohibit children from attending at least one day if not more or until cleared by a doctor which means either way my child will be absent from daycare and I will be absent from work where I make money to provide for my family. Being absent from work and missing out on money that I use to pay bills is one thing but to have an additional cost such as paying for childcare that my child was absent for is frustrating. If an absence was for something other than illness I can understand that. However, as a parent of a small child that attends daycare and has had to miss work to stay with the child mulitple times every month is again frustrating.

I am ecstatic about most of these changes, since we will finally be prioritizing education and stability in a child's life, instead of focusing on the activities of parents and testing the resiliency capabilities of children.

However, I am extremely concerned by this portion of the proposed law (emphasis added):

I. The eligibility period for TANF (nonVIEW), transitional child care, Fee Program, and Head Start begins with the effective date of the approval of the child care subsidy and services application. The eligibility period for VIEW and SNAPET participants begins with the date of referral from the VIEW or SNAPET program.

I fear that this has the potential to have a disparate impact on the families that we serve in addition to putting unnecessary additional pressure on all child care workers.

If found eligible, all other programs offered through DSS have an effective date as the date that a signed application is received by the agency (Social Security benefits and every other government program that I can think of also follows this principle, regardless of differing processing time frames).  Under this proposed change, however, not only would the same application be treated differently depending on the budget line that would be used, but also clients will now be at the mercy of their assigned worker’s work schedule, work load, and possibly prejudices and work ethic, instead of a consistent and equitable policy.

As an example, If a grandparent receives custody of a grandchild and applies online for Medicaid, TANF, and Child Care on the same day, the child care worker must wait until the Eligibility worker approves the TANF before we can approve TANF (nonVIEW) child care (grandparents are usually over income if we processed prior to TANF being approved).  Both Eligibility and Child Care workers have 30 days to process our respective applications.  If this change were to occur, not only will we continue having to be at the mercy of EWs processing their application first (typically it’s after the 20th day), the grandparents would now be responsible for paying out of pocket until the child care worker is able to process the application (usually very close to the 30th day). If all of this is to avoid manual attendance sheets, perhaps a better idea is to allow local agencies to issue eppic cards.  I think that would remedy much of the problems without having a negative impact on the clients that we are supposed to serve and help reach self sufficiency.

I implore you to reconsider this portion of the proposal.

• 22VAC40-185-530. First aid training, cardiopulmonary resuscitation (CPR) and rescue breathing.

• 90 days grace period is a better solution for new hire employees because of lifestyle factors such as money requirements, transportation and also scheduling restraints. Some new employees may be relying on this job for a first source of income and therefore would need time to have the money to even go and have CPR training. For others there are factors such as transportation and scheduling. Some employees who are parents themselves will have to make arrangements to have their own children taken care of in order to provide the time to take the 8 -hour training course.

• 22VAC40-665-230. Caregiver training and development..

• 90 days grace period is a better solution for new hire employees because of lifestyle factors such as money requirements, transportation and also scheduling restraints. Some new employees may be relying on this job for a first source of income and therefore would need time to have the money to even go and have CPR training. For others there are factors such as transportation and scheduling. Some employees who are parents themselves will have to make arrangements to have their own children taken care of in order to provide the time to take the 8 -hour training course.

• 22VAC40-665-330. Parental involvement and notifications.

• Children especially at a younger age are constantly active and will have little mishaps here and there. To require immediate notification and under such a limited time for every single accident would be overwhelming not only for the parents but also to the administration.

• 22VAC40-665-650. Supervision, ratio, and group size requirements.

• We object to this concept because it not only limits the amount of space for the children to learn and grown physically and educationally, it causes confusion for those who may not understand why they are limited in space and involvement with their fellow peers. It also disturbs the fluidity of teamwork that the teacher and aides may have built if they are separated into groups rather than a whole class.

.

• 22VAC40-665-220. General qualifications

• Many of us have either used a teenager to babysit our children or have been a babysitter in our younger years. It is unfair to put a specific age restriction on the fact that teenagers must be 18 years of age to be left alone with children. This age demographic helps to not only fill in some hours to relieve the earlier coming employees but helps these younger teens to build on their morals of responsibility and independence.

• 22VAC40-665-650. Supervision, ratio, and group size requirements.

• Life happens and at many times there are factors that we as human beings cannot control. Someone may get sick, there could be a family emergency, or there could be a life changing event for someone that may restrict them from attending their job. We are not stating that there wouldn’t be consistency in each classroom everyday however to require a written policy to make things set in stone is not only unrealistic but would cause problems and confusion to the parents who wouldn’t have known any different. The children in each class will always have someone to make sure their care is always constant and safe.

• 22VAC40-185-530. First aid training, cardiopulmonary resuscitation (CPR) and rescue breathing.

• It is unreasonable to expect a new employee who financially may not be able to pay for training based on pay schedule to comply within 30 days.  A 90 day grace period is a better option

22VAC40-185-80. Attendance records; reports.

reporting every injury that requires medical attention is unnecessary.  Redefine Serious injury or dont require real time reporting.  a more reasonable approach would be evaluation of serious injuries at time of inspection

22VAC40-185-350.  Staff-to-children ratio and group size requirements

Group sizing is going to cause financial strain on businesses.  Centers are going to have to choose between corraling the children in a restricted space and reconstructing classrooms or just cutting spaces out of classrooms completely which will also cause financial burden as centers will no longer be operating at capacity. This will most definitely force families to seek care from unlicensed  unregulated sources.

22VAC40-185-190.  Program Director Qualifications

Maintain current exceptions where directors are under grandfather clauses.  Why should people who have put their heart and soul into directing childcare centers for decades be forced to resign due to new educational requirements. Dont change these regulations have them remain the same or at the least maintain the exceptions currently in the licensing regulations.

22VAC40-185-220 Aides

What sense would it make to require any staff member between 16 and 18 be monitored by another staff member.  Many babysitters and even parents are 16 or 17 years old.  They are high energy enthusiastic caretakers who provide a fresh young interactive person to care for our kids.  This also allows full time staff to be relieved as they should not be expected to work 12 hours and care for children at their best ability. Centers are hiring these young caretakers because they are needed. Please remove this requirement.

• 22VAC40-185-350. Staff-to-children ratio and group size requirements.: subsection F

• Written policy to ensure consistent care for children is not feasible. Staffing is difficult and to make promises that cant be kept would be irresponsible.  I know that it is important to do the best to maintain consistent care but i think the main priority is to ensure the children are recieving quality care from a trained staff member.

22VAC40-665-230. Caregiver training and development

I object to 100% of staff obtaining CPR and First Aid Certification within 30 days of employment, a more reasonable and equally safe alternative would be 50% certified and 100% trained within 90 days of employment.  These modifications would still be an improvement to the current mandate.

22VAC40-665-330. Parental involvement and notifications 

I object to Real time reporting of serious injury by definition of any injury requiring medical attention.  I think that a reasonable alternative would be to require centers to maintain written documentation of serious injury to be readily available at time of licensing inspection or the definition of serious injury be reevaluated.

22VAC40-665-330. Parental involvement and notifications 

I object to Real time reporting of serious injury by definition of any injury requiring medical attention.  I think that a reasonable alternative would be to require centers to maintain written documentation of serious injury to be readily available at time of licensing inspection or the definition of serious injury be reevaluated.

22VAC40-665-650. Supervision, ratio, and group size requirements.

I object to the group sizing requirement.  I believe that it is reasonable that a variance be granted to centers that are currently operating.  It is unreasonable to expect a center to physically reconstruct centers or decrease availability when that have already currently been operating at capacity.

22VAC40-665-220. General qualifications

I object to the proposed regulation that teacher aides under the age of 18 be supervised at all times.  This age demographic is crucial in staffing to relieve fulltime teachers.  They bring high energy and enthusiasm to the classroom and allowing them to work in the school promotes the younger age demographic to explore future careers in childcare.

22VAC40-665-650. Supervision, ratio, and group size requirements.

I object to requiring centers to establish and maintain written policy to ensure consistent care in every class.  It is always a goal that we strive to maintain consistent staff in a classroom but staffing is difficult and to establish a written plan that wouldn’t be able to be followed would be irresponsible.  I believe that as long as the center is continuously providing safe and consistent care to the children that we should not have to comply with a written plan.

22VAC40-665-230. Caregiver training and development

I object to 100% of staff obtaining CPR and First Aid Certification within 30 days of employment, a more reasonable and equally safe alternative would be 50% certified and 100% trained within 90 days of employment.  These modifications would still be an improvement to the current mandate.

22VAC40-665-330. Parental involvement and notifications 

I object to Real time reporting of serious injury by definition of any injury requiring medical attention.  I think that a reasonable alternative would be to require centers to maintain written documentation of serious injury to be readily available at time of licensing inspection or the definition of serious injury be reevaluated.

22VAC40-665-650. Supervision, ratio, and group size requirements.

I object to the group sizing requirement.  I believe that it is reasonable that a variance be granted to centers that are currently operating.  It is unreasonable to expect a center to physically reconstruct centers or decrease availability when that have already currently been operating at capacity.

22VAC40-665-220. General qualifications

I object to the proposed regulation that teacher aides under the age of 18 be supervised at all times.  This age demographic is crucial in staffing to relieve fulltime teachers.  They bring high energy and enthusiasm to the classroom and allowing them to work in the school promotes the younger age demographic to explore future careers in childcare.

22VAC40-665-650. Supervision, ratio, and group size requirements.

I object to requiring centers to establish and maintain written policy to ensure consistent care in every class.  It is always a goal that we strive to maintain consistent staff in a classroom but staffing is difficult and to establish a written plan that wouldn’t be able to be followed would be irresponsible.  I believe that as long as the center is continuously providing safe and consistent care to the children that we should not have to comply with a written plan.

22VAC40-665-230. Caregiver training and development

I object to 100% of staff obtaining CPR and First Aid Certification within 30 days of employment, a more reasonable and equally safe alternative would be 50% certified and 100% trained within 90 days of employment.  These modifications would still be an improvement to the current mandate.

22VAC40-665-330. Parental involvement and notifications 

I object to Real time reporting of serious injury by definition of any injury requiring medical attention.  I think that a reasonable alternative would be to require centers to maintain written documentation of serious injury to be readily available at time of licensing inspection or the definition of serious injury be reevaluated.

22VAC40-665-650. Supervision, ratio, and group size requirements.

I object to the group sizing requirement.  I believe that it is reasonable that a variance be granted to centers that are currently operating.  It is unreasonable to expect a center to physically reconstruct centers or decrease availability when that have already currently been operating at capacity.

22VAC40-665-220. General qualifications

I object to the proposed regulation that teacher aides under the age of 18 be supervised at all times.  This age demographic is crucial in staffing to relieve fulltime teachers.  They bring high energy and enthusiasm to the classroom and allowing them to work in the school promotes the younger age demographic to explore future careers in childcare.

22VAC40-665-650. Supervision, ratio, and group size requirements.

I object to requiring centers to establish and maintain written policy to ensure consistent care in every class.  It is always a goal that we strive to maintain consistent staff in a classroom but staffing is difficult and to establish a written plan that wouldn’t be able to be followed would be irresponsible.  I believe that as long as the center is continuously providing safe and consistent care to the children that we should not have to comply with a written plan.

22VAC40-665-230. Caregiver training and development

I object to 100% of staff obtaining CPR and First Aid Certification within 30 days of employment, a more reasonable and equally safe alternative would be 50% certified and 100% trained within 90 days of employment.  These modifications would still be an improvement to the current mandate.

22VAC40-665-330. Parental involvement and notifications 

I object to Real time reporting of serious injury by definition of any injury requiring medical attention.  I think that a reasonable alternative would be to require centers to maintain written documentation of serious injury to be readily available at time of licensing inspection or the definition of serious injury be reevaluated.

22VAC40-665-650. Supervision, ratio, and group size requirements.

I object to the group sizing requirement.  I believe that it is reasonable that a variance be granted to centers that are currently operating.  It is unreasonable to expect a center to physically reconstruct centers or decrease availability when that have already currently been operating at capacity.

22VAC40-665-220. General qualifications

I object to the proposed regulation that teacher aides under the age of 18 be supervised at all times.  This age demographic is crucial in staffing to relieve fulltime teachers.  They bring high energy and enthusiasm to the classroom and allowing them to work in the school promotes the younger age demographic to explore future careers in childcare.

22VAC40-665-650. Supervision, ratio, and group size requirements.

I object to requiring centers to establish and maintain written policy to ensure consistent care in every class.  It is always a goal that we strive to maintain consistent staff in a classroom but staffing is difficult and to establish a written plan that wouldn’t be able to be followed would be irresponsible.  I believe that as long as the center is continuously providing safe and consistent care to the children that we should not have to comply with a written plan.

22VAC40-665-230. Caregiver training and development

I object to 100% of staff obtaining CPR and First Aid Certification within 30 days of employment, a more reasonable and equally safe alternative would be 50% certified and 100% trained within 90 days of employment.  These modifications would still be an improvement to the current mandate.

22VAC40-665-330. Parental involvement and notifications 

I object to Real time reporting of serious injury by definition of any injury requiring medical attention.  I think that a reasonable alternative would be to require centers to maintain written documentation of serious injury to be readily available at time of licensing inspection or the definition of serious injury be reevaluated.

22VAC40-665-650. Supervision, ratio, and group size requirements.

I object to the group sizing requirement.  I believe that it is reasonable that a variance be granted to centers that are currently operating.  It is unreasonable to expect a center to physically reconstruct centers or decrease availability when that have already currently been operating at capacity.

22VAC40-665-220. General qualifications

I object to the proposed regulation that teacher aides under the age of 18 be supervised at all times.  This age demographic is crucial in staffing to relieve fulltime teachers.  They bring high energy and enthusiasm to the classroom and allowing them to work in the school promotes the younger age demographic to explore future careers in childcare.

22VAC40-665-650. Supervision, ratio, and group size requirements.

I object to requiring centers to establish and maintain written policy to ensure consistent care in every class.  It is always a goal that we strive to maintain consistent staff in a classroom but staffing is difficult and to establish a written plan that wouldn’t be able to be followed would be irresponsible.  I believe that as long as the center is continuously providing safe and consistent care to the children that we should not have to comply with a written plan.

22VAC40-665-230. Caregiver training and development

I object to 100% of staff obtaining CPR and First Aid Certification within 30 days of employment, a more reasonable and equally safe alternative would be 50% certified and 100% trained within 90 days of employment.  These modifications would still be an improvement to the current mandate.

22VAC40-665-330. Parental involvement and notifications 

I object to Real time reporting of serious injury by definition of any injury requiring medical attention.  I think that a reasonable alternative would be to require centers to maintain written documentation of serious injury to be readily available at time of licensing inspection or the definition of serious injury be reevaluated.

22VAC40-665-650. Supervision, ratio, and group size requirements.

I object to the group sizing requirement.  I believe that it is reasonable that a variance be granted to centers that are currently operating.  It is unreasonable to expect a center to physically reconstruct centers or decrease availability when that have already currently been operating at capacity.

22VAC40-665-220. General qualifications

I object to the proposed regulation that teacher aides under the age of 18 be supervised at all times.  This age demographic is crucial in staffing to relieve fulltime teachers.  They bring high energy and enthusiasm to the classroom and allowing them to work in the school promotes the younger age demographic to explore future careers in childcare.

22VAC40-665-650. Supervision, ratio, and group size requirements.

I object to requiring centers to establish and maintain written policy to ensure consistent care in every class.  It is always a goal that we strive to maintain consistent staff in a classroom but staffing is difficult and to establish a written plan that wouldn’t be able to be followed would be irresponsible.  I believe that as long as the center is continuously providing safe and consistent care to the children that we should not have to comply with a written plan.

22VAC40-665-230. Caregiver training and development

I object to 100% of staff obtaining CPR and First Aid Certification within 30 days of employment, a more reasonable and equally safe alternative would be 50% certified and 100% trained within 90 days of employment.  These modifications would still be an improvement to the current mandate.

22VAC40-665-330. Parental involvement and notifications 

I object to Real time reporting of serious injury by definition of any injury requiring medical attention.  I think that a reasonable alternative would be to require centers to maintain written documentation of serious injury to be readily available at time of licensing inspection or the definition of serious injury be reevaluated.

22VAC40-665-650. Supervision, ratio, and group size requirements.

I object to the group sizing requirement.  I believe that it is reasonable that a variance be granted to centers that are currently operating.  It is unreasonable to expect a center to physically reconstruct centers or decrease availability when that have already currently been operating at capacity.