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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4/6/18  9:03 pm
Commenter: Melissa Wolfe, President

Proposed legislation issues for cooperative preschools
 

 

To the State Board of Social Services, 

On behalf of the Virginia Cooperative Preschool Council (“VCPC”), the umbrella organization for parent cooperative preschools in Virginia, I respectfully bring to the Board's attention VCPC’s  concern that the 28 parent cooperative preschools in Virginia are placed in jeopardy by the Proposed Amended Standards.  

The parent cooperative preschool model has existed for over 100 years and the benefits it provides to families – both children and parents alike– are widely acknowledged.  As President of VCPC, as well as a parent member of a cooperative preschool, I am greatly concerned that the Proposed Amended Standards will no longer allow parents to actively and meaningfully participate in their children’s preschool education and ultimately will endanger the cooperative preschools here.

Virginia parent cooperative preschools, like other parent cooperative preschools throughout the world, are owned and run by parent members along with professional staff.  Cooperative preschool parents fulfill many roles, including acting as “parent helpers” in the classroom under the guidance and supervision of staff.   Like staff, parent helpers obtain the same criminal background checks as staff.   Unlike staff, under the current Standards, parents are required to perform 4 hours of training annually 22VAC40-185- 240).

By contrast, the Proposed Amended Standards require that parent helpers must be in continuous sight and sound supervision of staff, or must be characterized as “staff” themselves, which would require that they meet all of the requirements for professional staff.  The reasoned and reasonable accommodation for cooperative parents found in the current Standards, which recognize the intrinsic value of an early childhood education model premised on parent involvement, is gone.   

Unless the Proposed Amended Standards are changed, parent cooperative preschools will be gone.  Even though parents have the same background checks as staff, they are parent helpers, not professional staff.  Characterizing parent helpers as “staff”, and therefore requiring that they fulfill all the requirements for professional staff, would be 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.  Remove parents from our parent cooperative preschool and the preschools themselves cannot be sustained. 

To preserve the parent cooperative preschool in Virginia, the Board is respectfully requested to please revise the Proposed Amended Standards to allow cooperative preschool parents to work as volunteers in the classroom under the guidance and supervision of professional staff but without continuous sight and sound supervision of a staff member provided that the parent volunteer:

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

These changes will allow parent cooperative preschools, models of parent and family engagement in education, to continue their important work to the benefit of children and families in Virginia, while appropriately safeguarding the children in care.

VCPC also respectfully requests that, in addition to considering this petition, the Board also carefully consider all of the comments posted by or on behalf of Virginia parent cooperative preschools individually.   VCPC member schools may have other concerns in addition to the concern expressed here.  Representatives from parent cooperative preschools in Virginia also would welcome the opportunity to further explain to the State Board of Social Services the effect the Proposed Amended Standards will have on parent cooperative preschools if enacted without revision, and to fully explain the benefits of parent cooperatives.  

 

Respectfully submitted,

Melissa Wolfe

President VCPC

CommentID: 64917