Virginia Regulatory Town Hall
Agency
Department of Social Services
 
Board
State Board of Social Services
 
chapter
Standards for Licensed Child Day Centers [22 VAC 40 ‑ 185]
Action Amend Standards for Licensed Child Day Centers to Address Federal Health and Safety Requirements
Stage Proposed
Comment Period Ended on 4/6/2018
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3/18/18  5:22 pm
Commenter: Melissa Kuhn, teacher at Annandale Cooperative Preschool

Changes Requested by Cooperative Preschools
 

On behalf of Annandale Cooperative Preschool I am requesting changes to the Proposed Standards for Licensed Child Day Centers, specifically in regard to the requirements for staff orientation and ongoing training. 

 Since 1947 Annandale Cooperative Preschool has been a place for parents to actively participate in their children’s education by working directly in our classrooms as teachers’ aides.  The new requirements for staff orientation (22VAC40-185-240) and ongoing training (22VAC40-185-245) would impose an undue burden on our parents by expecting them to complete 16 hours of orientation and 20 hours per year of ongoing training.  Parents who are volunteering their time are simply not going to be willing or able to complete the same orientation and training requirements as our paid classroom teachers.   

 We request that the total number of training hours (both orientation and ongoing, collectively) for cooperative preschool parents be limited to the current 4 hours. Please remove the language "who are not considered staff" from section 22VAC40-185-245C describing the required annual training for cooperative preschool parents. Please include an exception for cooperative preschool parents in the new orientation training section 22VAC40-185-240. 

 Parents working in classrooms at Annandale Cooperative Preschool complete all of the background checks outlined in Background Checks for Child Welfare Agencies.  They work under the direct supervision of well qualified classroom teachers in our award winning, NAEYC accredited program.

If the orientation and ongoing training sections of the proposed standards are not changed, cooperative preschools like ours will be forced to hire additional staff, making the cost prohibitive for many of our families.  Cooperative schools may have to close as parents are unwilling to enroll their children in programs which put unreasonable burdens on them.  Either outcome robs children of the high quality, affordable early education that cooperative preschools provide.

I have had the privilege of benefitting from our cooperative program both as a parent and as a teacher.  I believed so much in this program that once my daughter went off to kindergarten, I couldn't imagine not being part of our amazing community and I applied to work here.  I am a VA licensed teacher and could choose to work anywhere (and have worked for other amazing institutions, such as Arlington Public Schools).  I choose to work at Annandale Cooperative Preschool because I believe we offer a high quality program to families in an affordable way.  We offer families a chance to be part of the early childhood process and to learn more about it along the way.  Please help us continue to be able to offer this effective approach to early childhood education.

Many thanks,

Melissa Kuhn

 

 

 

CommentID: 63853