I am writing as a school administrator serving children from 16 months through middle school to express strong support for the fast-track action to repeal the Fee Requirements for Processing Applications (8VAC20-830).

The removal of background check processing fees is an important and practical step toward strengthening the early childhood workforce. Childcare programs across Virginia continue to face persistent staffing shortages, high turnover, and increasing operational costs. Even relatively modest per-employee fees create cumulative financial strain in a field where margins are already extremely limited.

Early childhood programs experience higher staff turnover than many other sectors, which means background checks occur frequently. When these costs are shifted to programs, they function as an ongoing operational expense rather than a one-time administrative cost. Eliminating this fee reduces barriers to hiring, supports timely onboarding, and allows programs to direct limited resources toward educator compensation, training, and classroom quality.

From a workforce perspective, reducing administrative costs tied to hiring is aligned with the Commonwealth’s broader goals to expand access to childcare and stabilize the early childhood system. Providers cannot increase capacity without the ability to recruit and onboard staff efficiently and affordably.

This change also reflects an understanding that regulatory requirements designed to protect children should not unintentionally create financial barriers that limit program sustainability. Background checks are essential and universally supported by providers. Ensuring they remain accessible without additional financial burden strengthens compliance while supporting the workforce.

I appreciate the Department’s efforts to simplify the fee structure under 8VAC20-821 and support the fast-track repeal of Chapter 830. Actions such as this demonstrate responsiveness to provider feedback and represent meaningful progress toward a more sustainable early childhood system.

Thank you for the opportunity to provide input and for your continued work to support children, families, and early childhood educators across Virginia.

Michelle D’Antonio
Head of School
HRI Montessori

Please support 8VAC20-830.  Child care centers are struggling to hire staff and the turnover is enormous.  Paying the exorbitant price is impacting the budgets of many privately owned preschool.  

To the Virginia Department of Education and Board of Education,

 I serve as the Director of Finance and Operations at Hampton Roads International Montessori School. We are a nonprofit Montessori program dedicated to providing high-quality early childhood education to children from 16 months through 8^th grade in the Hampton Roads community.

I am writing today to express my strong support for the fast-track regulatory action to repeal the fee requirements for FBI background checks (8VAC20-830).

While our school fully recognizes and supports the necessity of rigorous background checks to ensure the safety and well-being of the children in our care, the recent implementation of a $70 fee per applicant creates a significant and unnecessary financial barrier.

As the Director of Finance and Operations, I see firsthand the real-world impact of these costs:

• Operational Burden: Transitioning from a free service to a $70-per-person expense introduces a recurring operational cost that was not previously budgeted. These funds are diverted away from classroom resources and student experiences.
• Workforce Challenges: The early childhood education field is currently facing a historic staffing shortage. Adding a $70 entry fee creates an immediate hurdle for onboarding new educators. The ECE workforce is primarily composed of women, many of whom are single mothers and the sole caregivers for their own children and aging family members. In a field where wages are already a challenge, a $70 fee is not just a line item—it is a significant portion of a week’s groceries or a utility bill for an entry-level educator if they are forced to absorb the cost of background checks to be hired. These individuals are also, often forced to come and go from the workforce based on family demands, and they must acquire new background checks at each center. In a sector where we are constantly working to raise wages and recruit talent, if these administrative costs are absorbed by the ECE it reduces our ability to offer competitive compensation and stabilize our workforce.
• Impact on Capacity: Our ability to serve families and expand access to childcare is directly tied to our ability to hire. When hiring becomes more expensive and administratively burdensome, it limits our capacity, ultimately impacting the families in our community who rely on us.

The removal of these fees is an essential step toward equity in the childcare landscape. Small programs and nonprofits like ours feel these costs most heavily. Many ECE centers across Virginia are founded and led by individuals with a deep heart for children and pedagogy, rather than a background in business or high-level finance.

In a sector where margins are notoriously razor-thin, even a "small" fee of $70 per applicant—when multiplied by the high turnover rates inherent in this field—can destabilize a program's budget.

By reverting to a system without these financial barriers, the state is making a meaningful impact on the sustainability of early childhood programs across the Commonwealth.

I fully support the use of the fast-track process for this repeal. This change reflects that the Department has listened to provider feedback and is committed to reducing the administrative and financial burdens that hinder our mission.

Background checks are essential for safety; however, financial barriers to hiring are not. Removing these costs will allow us to focus our resources where they matter most: the education and safety of our children.

Thank you for your time, your consideration of this feedback, and your continued efforts to support the early childhood workforce in Virginia.

Sincerely,

Lindsey Boyer

Director of Finance and Operations

Hampton Roads International Montessori School

To the VDOE and Board of Educators,

I am the School Director of Resurrection Lutheran School in Newport News.  We currently serve 124 6 week old - through 12 year olds and have 39 staff members.  In June we will be expanding into a new building with a capacity of 250 and 55 staff members. 

I want to express my strong support for the repeal of the background check fee requirements.  There has not been a fee for this for my entire tenure at this site and we were always appreciative of that because there are very high fees often associated for out of state background checks and the cost of onboarding and qualifying staff for this field is often expensive.  Many centers pay for this fee because the applicants that work in this field simply can't afford that upfront. 

Turnover and staff retention are at an industry high in the last 5 years and this just is not the time, if ever, to implement what would be and astronomical impact to many centers.  A lower fee, say $25 or so, may have been more palatable but still would have caused fiscal struggles to providers. 

I especially think non-profit and subsidized centers should not have to pay the full amount or there should have been a gradual increase not the shocking jump from $0 to $70.

Respectfully,

Melanie Mesick

School Director, RLS

I am writing to support the fast-track repeal of 8VAC20-830. As a provider serving a wide age range (16 months through middle school), I see firsthand how administrative fees hinder our ability to scale and sustain our workforce.

• The Problem: Frequent staff turnover makes background check fees a recurring operational drain rather than a one-time cost.

• The Impact: These costs limit our ability to offer competitive pay and onboard staff quickly.

• The Solution: Eliminating these fees aligns with Virginia’s goals of expanding childcare access and supporting program sustainability.

Thank you for simplifying the fee structure and removing these financial hurdles for Virginia’s educators.

To the Virginia Department of Education and Members of the Board of Education,

I am writing as an early childhood provider to share serious concerns about the new requirement that centers pay for staff background checks and to urge the Department to reconsider this regulation.

I am the Director of UCP Preschool in Reston, Virginia. We serve 48 children ages two through five and employ 25 staff members, including substitute teachers. While our program has relatively low turnover, the addition of mandatory background check fees places our school in a precarious financial position. Like many small programs, we are still working to recover from significant COVID-related losses and the expiration of relief funding that helped sustain us during that period.

For more than twenty years in this field, required background checks have not carried a direct fee for providers. That long-standing practice acknowledged an important reality: the cost of recruiting, onboarding, and qualifying early childhood educators is already substantial. Background checks—especially those involving out-of-state records—can be expensive, and centers frequently absorb these costs because many applicants simply cannot afford them upfront.

This change comes at a time when the early childhood workforce is already under extraordinary strain. Staffing shortages, burnout, and retention challenges are at an industry high. Introducing a sudden and significant new expense, particularly a jump from no cost to $70 per check, creates an outsized burden that many small, nonprofit, and subsidized programs are not equipped to absorb.

If a fee had been unavoidable, a lower amount, a gradual phase-in, or exemptions for nonprofit and subsidized providers would have allowed programs time to plan responsibly. Instead, the abrupt implementation of this requirement threatens the financial stability of centers that are already operating on narrow margins.

Early childhood programs play a critical role in their communities, and policies should reflect the fragile ecosystem in which they operate. I respectfully urge the Department and the Board to repeal this requirement or revise it in a way that acknowledges the realities facing providers across the Commonwealth.

Thank you for your time and for considering the impact of this regulation on early childhood programs and the families they serve.

Sincerely,
Ginger O’Rourke
Director
UCP Preschool
Reston, Virginia

Please reconsider fees to be charged for background checks. Childcare facilities and preschools usually experience a higher turnover than other businesses, hence will have more frequent background checks. To see the amount go from (almost) 0 to over $ 70 for the combined checks is outrageous. With an additional out of state cost for a background check, we are looking at up to $ 120 per prospective employee.

We have the choice to ask the prospective employee to shoulder the cost - which in most cases they cannot -, or the school pay for the checks. In the latter case, we have no choice than to increase our tuition, which is contradictory to the Commonwealth's goal to make childcare more affordable.

I serve as Assistant Head of School at Hampton Roads International Montessori School, a nonprofit program serving children ages 16 months through 8th grade. Our school currently serves approximately 250 students and employs 50 staff members.

I strongly support the fast-track repeal of the fee requirements outlined in 8VAC20-830. Background checks are essential to maintaining child safety. However, financial barriers tied to required background checks create unnecessary strain on early childhood programs.

In our program, background check fees apply not only to new hires but also to substitute teachers and to required updates for current staff. With ongoing staffing needs, these costs recur frequently and accumulate across the organization. Like many providers, we operate within a tight nonprofit budget. Funds directed toward background check fees are funds that cannot be invested in staff compensation, classroom materials, or program improvements.

The early childhood workforce is already under significant pressure, and reducing administrative hiring costs is a practical step toward supporting workforce stability. Hiring costs directly affect classroom capacity. Removing these fees helps programs onboard staff more efficiently, maintain appropriate ratios, and continue serving families reliably.

This change is particularly meaningful for smaller and nonprofit programs operating on narrow margins. Small operational changes have meaningful system impact, and removing barriers to hiring supports access for families across the Commonwealth.

Thank you for your time and for your continued efforts to streamline regulations in response to provider feedback. I strongly endorse the use of the fast-track process for this repeal.

Maria Burke
Assistant Head of School
HRI Montessori

Subject: Request for Consideration Regarding Licensing Fee Requirements

Dear Licensing Office / Virginia Department of Education,

I am writing on behalf of Chesterbrook Montessori School, a small, family-owned Montessori school in Arlington, Virginia, to request consideration regarding the application fee requirements under § 22.1-289.010 of the Code of Virginia and the regulations outlined in 8VAC20-821.

As a small school, we operate with limited resources and small class sizes. Meeting licensing requirements requires us to maintain several staff members in order to meet child-to-teacher ratios and safety regulations. While we fully support these standards, the combined costs of staffing, background checks, and licensing fees place a significant financial burden on a small program like ours.

We work hard to keep tuition reasonable for the families we serve, and additional regulatory costs make this increasingly difficult.

We respectfully ask that you consider the impact of these fees on small community-based schools such as ours and not implement these fees.

Thank you for your time and consideration.

Judy Balcazar and Lisa Banowit

Chesterbrook Montessori School

Head of School/Assistant Head of School

Subject: Request for Consideration Regarding Licensing Fee Requirements

Dear Licensing Office / Virginia Department of Education,

I am writing on behalf of Chesterbrook Montessori School, a small, family-owned Montessori school in Arlington, Virginia, to request consideration regarding the application fee requirements under § 22.1-289.010 of the Code of Virginia and the regulations outlined in 8VAC20-821.

As a small school, we operate with limited resources and small class sizes. Meeting licensing requirements requires us to maintain several staff members in order to meet child-to-teacher ratios and safety regulations. While we fully support these standards, the combined costs of staffing, background checks, and licensing fees place a significant financial burden on a small program like ours.

We work hard to keep tuition reasonable for the families we serve, and additional regulatory costs make this increasingly difficult.

We respectfully ask that you consider the impact of these fees on small community-based schools such as ours and not implement these fees.

Thank you for your time and consideration.

Judy Balcazar and Lisa Banowit
Head of School/Assistant Head of School

Chesterbrook Montessori School

We just found out about this fee when a woman we hired went to get her fingerprint done and this fee was initiated when she went to sign up online. 

This is high for our employees to pay and as a school, we would reimburse her for this, but coming up with this fee is a deterrent on a potential staff member. We would have to have a potential staff member sign up at school and we would have to put in our credit card to cover the initial cost, which isn't great practice. 

Please remove this fee as it will be a hardship on our employees. 

Thank you for your consideration.

Our program is required to background check every single promising applicant before we can continue the hiring process, which is multiple people per job opening.  We are also required to screen all regular volunteers and vendors who work in our school building.  Just this school year, this was 50 people for our school.  Increasing the cost of background checks adds another $70 per applicant on top of the current costs of OBI, TB screening, out of state checks, CPR licensure, First-Aid, and MAT trainings.  This also adds admin burden and time to navigate. 

This is an unnecessary hardship to pass on to schools and centers without additional resources.  I stand with other school leaders to get the new costs repealed. 

Dear Virginia Department of Education Licensing Office,

I write to voice grave concerns about the financial impact of the new background check fee on early childhood programs. I urge the DOE to support a fast tracked repeal of this new fee requirement imposed on early childhood programs.

I am the Director of Woods Creek Montessori in Lexington, Virginia. We currently serve 52 children, ages one to eight years old, and we employ 16 staff members during the school year. We serve primarily a two working parent community offering an after school program and a summer camp program in an area in Virginia with few options for year round care. We are the only licensed day center provider offering care until 5:30 during the school year and 5:00 during the summer program.

The addition of mandatory background check fees is already having a negative financial impact on our school. Like many early childhood programs, our budget is very tight and the sudden large cost increase of $70 per applicant is not sustainable for our school. Passing the cost increase to parents (through even higher tuition increases) or to applicants are not viable options and would have consequences on our school program

Thank you for considering the negative impact of this new fee requirement on early childhood programs.

Sincerely,

Caroline Russell, Executive Director

Woods Creek Montessori, Lexington, VA 24450

Please repeal the fast track action to charge a 70. fee for background checks for employees.  It will cause a costly hardship to child day centers and non- profits.

The cost of the background fees placed on our school is affecting the budget/expense we spend on staffing and is directly taking away from cost allotted to staff development. Please reappeal. 

Childcare centers are facing stricter and stricter budgets due to a number of cuts made to the federal and state budget. Piling on one more budget item not only impacts the yearly budget for the childcare center but it also has a ripple effect on the community. The cost of background checks will be pushed to the parents who are already paying sky high costs for childcare. Please Repeal the Fee Requirements for Processing Applications.

There needs to be qualified, certified, licensed and experienced people caring for our children. Please stop creating excuses to get rid of accountability in our educational institutions. Stop lowering standards and expectations for our society and taxing the rest of us. 

I support the proposed fast-track repeal of the Fee Requirements for Processing Applications (8VAC20-830). The fees associated with application processing place an added financial burden directly on providers, diverting resources that could otherwise be used to support staffing, program quality, and operations. In a field already facing significant financial and workforce challenges, reducing unnecessary administrative costs is a meaningful and necessary step. This repeal would help alleviate operational strain and better position providers to focus on delivering high-quality care and education.

Public Comment in Support of Repeal of 8VAC20-830
(Fee Requirements for Criminal Background Check Processing Applications)

I write in strong support of the fast-track repeal of the fee requirements outlined in 8VAC20-830. As President & CEO of Hopkins House, which operates two preschool academies in Northern Virginia serving over 200 young children each year, I see firsthand how these fees create unnecessary barriers for both educators and childcare providers.

Hopkins House employs 55 educators and administrators, along with substitutes, kitchen staff, and family support personnel — all of whom are required to undergo criminal background checks. These checks are essential to maintaining child safety, a goal we strongly support. However, requiring employees to bear the cost — often as much as $72.73 in Virginia, and frequently exceeding $100 for those with out-of-state work histories — places a significant financial burden on individuals working in one of the lowest-paid sectors of our economy.

These costs are not one-time expenses. Background checks are not portable between employers, meaning that educators must repeatedly pay these fees when changing positions within the field. This creates a recurring financial barrier that discourages qualified individuals from entering or remaining in early childhood education — a field already facing severe workforce shortages.

For providers, the impact is equally challenging. Some programs absorb these costs and pass them on to families, further increasing the already high cost of childcare. Others, like Hopkins House, require employees to pay, which can deter otherwise qualified candidates who are already financially stretched. In either case, these fees ultimately reduce workforce stability and limit program capacity.

Reducing administrative hiring costs is a practical and meaningful step toward strengthening the early childhood workforce. Removing these fees will help providers recruit and onboard staff more efficiently, maintain appropriate teacher-to-child ratios, and ensure consistent, high-quality care for families. This is particularly critical for nonprofit and community-based providers operating on narrow margins, where even modest cost reductions can have a significant impact.

The proposed repeal of 8VAC20-830 represents a thoughtful and responsive action to provider feedback. It removes an unnecessary barrier while preserving the essential safeguard of background checks themselves.

Thank you for your consideration and for your continued efforts to support Virginia’s early childhood workforce and the families who depend on it. I strongly endorse the use of the fast-track process to repeal 8VAC20-830.

The decision to stop covering the cost of criminal background checks for childcare workers creates a significant and unnecessary barrier for both current providers and those seeking to enter the field. Childcare professionals are already among the lowest-paid essential workers, and requiring them to shoulder these fees risks discouraging qualified individuals from joining or remaining in the workforce. At a time when families across Virginia are already facing limited access to affordable childcare, this added financial burden will likely exacerbate staffing shortages and reduce the availability of care options for working parents.

Background checks are a critical component of maintaining safe, high-quality childcare environments, and the responsibility for ensuring these safeguards should not fall on individual workers or small providers. By reinstating state support for these costs, the Commonwealth can demonstrate its commitment to both child safety and workforce stability. Repealing this change would help remove unnecessary barriers, support providers, and ultimately strengthen Virginia’s early childhood system for families and communities alike.

Repeal of this rule change.

Hello - I am the Executive Director of The Child and Family Network Centers, a nonprofit providing free, high quality preschool to 139 children in the City of Alexandria. 

I am writing today to express my strong support for the fast-track regulatory action to repeal the fee requirements for FBI background checks (8VAC20-830). As you know, early childhood education has a high employee turnover rate, and thus, the costs of conducting numerous background checks throughout the school year are prohibitive. It is yet another administrative cost that we must now find funding for, which is especially difficult in this economic and fundraising climate. 

One cannot honestly state that they support the funding and increased availability of early education in the Commonwealth, yet turn a blind eye to these types of administrative cost burdens that may not seem high, but add up quickly. 

Again, I strongly support the fast-track regulatory action to repeal the fee requirements for FBI background checks (8VAC20-830). 

Kindly,

Barbara McLaughlin