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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4/1/18  9:25 pm
Commenter: Jessica Smith, Annandale Cooperative School, Teacher and Parent

Changes Requested by Cooperative Preschools
 

On behalf of Annandale Cooperative Preschool 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. 

 Since 1947 Annandale Cooperative Preschool has been a place for parents to actively participate in their children’s education by working directly in our classrooms as teachers’ aides.  The new requirements for staff orientation (22VAC40-185-240) and ongoing training (22VAC40-185-245) would impose an undue burden on our parents by expecting them to complete 16 hours of orientation and 20 hours per year of ongoing training.  Parents who are volunteering their time are simply not going to be willing or able to complete the same orientation and training requirements as our paid classroom teachers.   

 We 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.  They work under the direct supervision of well qualified classroom teachers in our 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. 

Last year after living abroad, my family joined Annandale Cooperative Preschool both as co-oping parents with our daughter, and I joined as a staff member. We were warmly welcomed into the preschool community and while my daughter has made many friends throughout the school year, another benefit is that my husband and I have made friends with other families in a community where we previously knew no one. Preschool was a big decision for our family, mainly because of the prohibitive costs of childcare in the area. Frankly, it was cheaper for me to stay home with my daughter than to pay for full-day care. Ultimately, we decided that we wanted to enroll her because we value the benefits of preschool, and because the cooperative preschool allows us to participate in her education and is much more affordable than traditional preschools.

If the current proposed changes are accepted, families like mine will not be able to participate in such an enriching cooperative experience, because tuition rates will rise to an unaffordable rate for many and parents wont be able and/or available to devote the necessary time for the required hours of training. Please reconsider the above stated changes so that cooperative preschools remain an affordable option for families.

CommentID: 64404