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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4/2/18  11:45 am
Commenter: Lesley Malus Reed, Arlington Unitarian Cooperative Preschool (AUCP)

Impact of New Regulations on Families and Cooperative Preschools
 

I am an alum of the AUCP program.  Having the opportunity to participate in my son's classroom from their early development (age 18 months through 5) was an invaluable experience for my family.  I learned to be a better parent and teacher in a consistent manner at school and therefore at home.  I worked part time and the time I had to volunteer was a dream come true.  The assigned orientation hours required in order to have this honor to co-op were a bit of a stretch with work and co-oping, but we made it work. 

This cherished school is a program I recommend to many friends and neighbors looking to participate while they work part-time.  I would not be able to manage to participate in the co-oping program under the proposed orientation and education requirements.  Please re-consider.  I felt that the experience gained and the parents who were in this program were prepared and I trusted them with the care of my toddlers who could not even speak when they started at that school to express their needs.  When my son was so ill from a complicated pneumonia, the community of co-opers picked up and took active care for my other toddler.  Due to our training and experience, I trusted not just the care of the parent’s I knew from my sons’ classes, but those who lived close by and never shared a class with my children because we were all trained with the same guiding principles and had consistent tools to which my kids were accustomed and by which they were comforted.  These tools were absolutely enough. 

In addition to the added hours required, I find that the requirement to remain in constant sight of a staff person defeats the purpose of providing assistance to the teacher.  If a child on the playground requires to go back into the school to use a restroom, it would be difficult to require the teacher, the child, and the 7 other students to enter the school for the 1 child.  It is counter-useful. If a child wants to finish a project prior to heading off to music or another activity the same scenario occurs.  The parents have been vetted and trained.   

Some facts:

Parent cooperative preschools, which have existed for over 100 years, are placed in jeopardy in Virginia by the Proposed Amended Standards.  Current Standards for Licensed Child Day Centers recognize the critical role of parent volunteers in the parent cooperative preschool model by including for cooperative parents an exception requiring limited training annually. This exception recognizes the unique role that parents hold in a cooperative preschool, as well as the intrinsic value of an early childhood education model premised on parent involvement.

The Proposed Amended Standards as drafted, however, undermine rather than support the cooperative preschool model by requiring cooperative parents to either:

(1) Complete the 36 training hours (16 orientation, 20 ongoing) required of professional staff, or 
(2) Remain in constant sight and sound supervision of a staff member.

These two alternatives fail to recognize that:

•Cooperative parents undergo the same background checks as staff;
•Cooperative parents assist professional staff in the classroom 1-2 days/month, for a total of 3-6 hours/month (thus required training hours could exceed the number of hours in class for the entire year);
•Cooperative parents serve a unique position in the classroom, where they remain under the guidance and supervision of professional staff but may at times not be in sight and sound supervision of staff.

These changes are unduly burdensome both to the cooperative parents who seek meaningful engagement in their children’s educations and to the small cooperative preschools that rely on parent engagement to survive.

To preserve the parent cooperative preschool in Virginia, the Proposed Amended Standards should be revised to allow cooperative preschool parents to work in the classroom without sight and sound supervision of a staff member provided that the parent:

(1)Satisfactorily completes the same background checks required of professional staff; and
(2)Completes a total of 4 hours of orientation and ongoing training annually.

Thank you for your consideration.

Lesley Malus Reed

CommentID: 64411