Action | Repeal existing regulation and adopt new Standards for Voluntary Registration of Family Day Homes |
Stage | NOIRA |
Comment Period | Ended on 3/31/2021 |
March 28, 2021
Cynthia Carneal Heflin
Program Consultant
Department of Social Services
801 East Main Street
Richmond, VA 23219
Dear Ms. Carneal Heflin,
Thank you for the opportunity to provide public comment related to the Department of Social Services’ intention to repeal and replace the outdated regulatory guidance for voluntary registered family day homes (22VAC40-180), as published in the Virginia Register of Regulations, Volume 37, Issue 14, March 1, 2021.
Child Care Aware of Virginia is a statewide nonprofit organization operating across Virginia to help families find child care, educate consumers as to key questions to ask when searching for child care, support the professional development of individuals working in child care, and to support child care providers in offering a safe and high-quality setting for children (in child care centers and family child care homes, including current and prospective voluntarily registered providers). In partnership with network member agencies ChildSavers in Richmond, The Childcare Network in Fredericksburg and Sentara Health Systems Family Connections in Harrisonburg, and through our work with the Department of Social Services, Division of Licensing Programs, Department of Education and other community partners, we have an on-the-ground view of the strengths and weaknesses of the current voluntary registration family day home guidance.
We commend the Department on its initiative to incorporate current health and safety criteria and to expand emergency preparedness requirements related to the program standards. We fully agree that replacing the guidance for voluntary registered providers is necessary for the protection of the public health, safety, and welfare of families with children (as well as the providers who are offering child care services) and is an opportunity to provide clearly written and easily understandable guidance.
As the Department considers modifications to the guidance, we offer the following suggestions to update the regulations to ensure that children in registered family day homes are safe and child care providers have the information and training they need to best promote the safety and healthy development of the children in their care.
Promoting the Health and Safety of Children
Emergency Preparation to Protect Children
Precautions to Prevent Accidents and Injuries
Responsibility to Uphold Laws and Regulations Important to the Protection of Children
Supporting Voluntary Registered Providers to Best Promote the Healthy Development of Children in their Care
The remaining recommendations relate to a fully-funded, state-supported VR system and the potential that the program could be used to help reduce child care deserts and increase the likelihood that providers may decide to become licensed once they feel more supported. More than 40% of Virginia families live in a child care desert. Support through a more vibrant VR program could help better serve families who need child care and potentially increase the number of providers who may one day want to seek licensure.
With a well-funded VR system, we recommend:
While the number of VR homes has declined in recent years, we see an opportunity to provide more robust support for VR providers, which could attract more home-based providers to the field and result in more licensed care in the long-term. The real beneficiaries of a more robust VR system would be the children, parents, employers, and communities that rely on child care – particularly now with the focus on economic recovery. We appreciate the opportunity to provide comments on this process and look forward to supporting the program and its participants as new requirements are implemented. Enhancing the VR system has the potential to better support Virginia families and further develop the child care workforce.
Should you have any questions, please contact Child Care Aware of Virginia Executive Director, Angela Wirt, at angela@vachildcare.com. We would be glad to provide further input or assistance. Thank you for taking the initiative to modernize the VR guidance.
Sincerely,
Angela Wirt
Angela Wirt
Child Care Aware of Virginia