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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3/25/18  9:37 pm
Commenter: Lisa Smith

Proposed changes to training requirements
 

As a parent actively engaged in the Annandale Cooperative Preschool community, I am requesting changes to the Proposed Standards for Licensed Child Day Centers, specifically in regard to the requirements for staff orientation and ongoing training. 

My husband and I specifically chose Annandale Cooperative Preschool so that we could actively participate in our children's education and have regular time in the classroom as a teacher's aide. The new requirements for staff orientation (22VAC40-185-240) and ongoing training (22VAC40-185-245) would impose an undue burden on parents by expecting them to complete 16 hours of orientation and 20 hours per year of ongoing training.  These reqirements are excessive and burdonsome, and will make it very difficult for parents to continue to particiapte in the co-op preschool model.

I respectfully request 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. 

 Parents working in classrooms at Annandale Cooperative Preschool complete all of the background checks outlined in Background Checks for Child Welfare Agencies.  We work under the direct supervision of well qualified classroom teachers in ACPS's award winning, NAEYC accredited program.

If the orientation and ongoing training sections of the proposed standards are not changed, cooperative preschools like ours will be forced to hire additional staff, making the cost prohibitive for many of our families.  Cooperative schools may have to close as parents are unwilling to enroll their children in programs which put unreasonable burdens on them.  Either outcome robs children of the high quality, affordable early education that cooperative preschools provide. 

We chose the co-op model because we beleive it's a great foundation for parent involvement in children's early education. The current proposed regulations will hinder that system from working, and potentially rob both children and parents of this vibrant, healthy, engaged learning environment. Please reconsider the training hours required. Thank you.

 

 

CommentID: 64343