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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3/26/18  10:25 am
Commenter: Nancy Renner Fort Hunt Preschool

Amendments Place Parent Cooperative Preschools in Jeopardy
 

Parent cooperative preschools, which have existed for over 100 years, are placed in jeopardy in Virginia by the Proposed Amended Standards.

Current Standards for Licensed Child Day Centers recognize the critical role of parent volunteers in the parent cooperative preschool model by including for cooperative parents an exception requiring 4 hours of training annually, 22VAC40-185-240.  This exception recognizes the unique role that parents hold in a cooperative preschool, as well as the intrinsic value of an early childhood education model premised on parent involvement.

The Proposed Amended Standards, specifically 22VAC40-185-240 and 22VAC40-185-245, as drafted, however, undermine rather than support the cooperative preschool model by requiring cooperative parents to either:

      (1) Complete the 36 training hours (16 orientation, 20 ongoing) required of professional staff, or
      (2) Remain in constant sight and sound supervision of a staff member.

These two alternatives fail to recognize that cooperative parents:

       1) undergo the same background checks as staff; 

       2)  assist professional staff in the classroom 3-6 hours/month (required training could exceed total volunteer hours for the school year);
       3)  serve a unique position in the classroom as a volunteer under the guidance and supervision of professional staff but may at times not be in sight and sound supervision of staff.

The proposed changes are 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.

To preserve the parent cooperative preschool in Virginia, the Proposed Amended Standards must be revised to allow cooperative preschool parents to work in the classroom without continuous sight and sound supervision of a staff member provided that the parent:

         (1)     Satisfactorily completes 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, while appropriately safeguarding the children in care.

Representatives from parent cooperative preschools in Virginia further request the opportunity at a public hearing to 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,

Nancy Renner

Teacher, Director, and former cooperative parent, Fort Hunt Preschool, Alexandria, VA 

 

 

 

CommentID: 64346