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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4/4/18  6:05 pm
Commenter: Sheri Kelleher, Hunters Woods Preschool

Changes Requested by Cooperative Preschools
 

On behalf of Hunters Woods 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.   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.  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 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:

1. Cooperative parents undergo the same background checks as staff;
2. Cooperative parents assist professional staff in the classroom 18-22 days/year, for a total of 45-55 hours/year (thus required training hours could be more than half of the number of hours in class for the entire year);
3. Cooperative parents serve a unique position in the classroom, where they remain under the guidance and supervision of professional staff but may at times not be in sight and sound supervision of staff.

These 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 should be revised to allow cooperative preschool parents to work in the classroom without sight and sound supervision of a staff member provided that the parent:

(1) Satisfactorily completes the same background checks required of professional staff; and
(2) Completes a total of 4 hours of orientation and ongoing training annually.
 

In my personal experience as a cooperative preschool parent and teacher for over 16 years, I feel the value of having parent involvement in the early childhood education lasts through out their child's school career.   Cooperative preschools have been around for over 50 years.  I believe by asking for parents to have 20 hours of annual training, including CPR and first aid certification is an unreasonable expectation of preschool parents in terms of time and expense.    VDSS must remove the language who are not considered staff” from section 22VAC40-185-245 describing the required training for cooperative preschool parents.  

 

CommentID: 64533