I oppose the proposed changes to the Standards for Licensed Child Day Centers, specifically in regard to the requirements for staff orientation and ongoing training.

The proposed new training requirements for parents who volunteer at cooperative preschools are extremely burdensome. As written (requiring more than 36 hours of training in one year), most parents will be unable to complete the requirement. At typical local sitter rates of $15 per hour, the expense to just hire a sitter so that a parent can complete the training is $540. 

I ask 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.

In order to comply with the new regulations, cooperative preschools would have to hire aides so that parents would not be counted in staff ratios. This would not only reduce the significance of parents' roles in the classroom, but would also raise tuition so significantly that many families could be left without any affordable preschool options.

I urge you to change the proposed regulations in order to preserve the viability of traditional cooperative preschools