Dear Members of the Virginia Department of Education,

I respectfully submit this letter for consideration regarding the proposed regulations that are planned to be implemented.

As a home child care provider with more than 15 years of experience, I believe it is important to express that many of these changes, rather than supporting providers, are creating additional challenges and making it more difficult to continue providing effective, high quality child care.

Home child care operates on a very small scale. Current regulations already require specific training and authorization in order to administer medication. I respectfully believe that responsibilities related to medication should primarily remain with parents, as they are the ones who best understand their children’s allergies, medical conditions, and individual needs.

For this same reason, many providers rely on parents to bring their children’s food. When parents provide meals, they ensure the food is safe and appropriate for their child and does not contain ingredients that may cause an allergic reaction. This approach helps reduce risk and supports children’s safety while allowing providers to focus on supervision and daily care.

Another concern involves insurance and liability. Home child care providers already carry the insurance required by the state; however, additional requirements and expanded responsibilities may result in increased insurance costs. For small providers, even modest increases in insurance expenses can have a serious impact on the ability to remain in business. In addition, the expectation of administering emergency medications such as EpiPens raises concerns about legal liability. These medications are expensive and must be replaced regularly, and administering them places providers at risk if an adverse outcome were to occur, despite acting in good faith and without medical training.

It is also important to recognize that not all licensed providers operate at full capacity. While some providers care for larger groups of children, others have much smaller enrollments. Although my license allows me to care for up to nine children, I currently have only three. My income reflects this reality and is not comparable to that of larger programs. Additional costs related to training, insurance, and medical responsibilities place a disproportionate burden on small providers.

Furthermore, home child care providers already comply with extensive state and county licensing requirements, including inspections and ongoing regulations. Even with full compliance, it has become increasingly difficult to compete with large centers and schools that have greater financial and staffing resources.

These proposed regulations have caused a high level of stress among home child care providers. While safety is a shared priority, regulations should also take into account the daily realities faced by small providers. In order to continue offering quality care, providers must be supported, valued, and placed in conditions that allow them to operate safely and sustainably.

Thank you for your time and consideration. I respectfully hope these concerns will be taken into account when evaluating and implementing future regulations.

Sincerely,

Ana Vasquez