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  8:23 pm
Commenter: Grace Carlson, Overlee Preschool

Regulations negatively impacting cooperative preschools : PLEASE CHANGE!
 

On behalf of Overlee 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. 

As one of the oldest Cooperative preschools in Northern Virginia,  Overlee Preschool is a place for parents to actively participate in their children’s early 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. Our parents volunteer on average only 50 hours a year in the classroom. Parents who are volunteering their time are simply not going to be able to complete the same orientation and training requirements as our paid classroom teachers.  Most of our parents all work full time. This requirement would rob  full time working parents of the privilege and opportunity to participate and observe their children in their early education environments. 

I am requesting 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

If the orientation and ongoing training sections of the proposed standards are not changed, cooperative preschools like ours, may be forced to shut down, as parents are unable 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

Parents working in classrooms at Overlee 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 and trained classroom teachers.

As a full time working mom, I have found Overlee to be a treasure. I have been given the opportunity to participate in my chidlren's early education, watching them grow and develop, and make friends, acquire new communication skills. I myself have learned so much when partnering with the classroom teachers. I consider myself lucky to have found a community like Overlee; a community that supports my professional and familial endevours. I can prioritize my children and be present while balancing my career. I cannot say enough about this school. I urge you to reconsider the detrimental regulations that would negatively impact Overlee Preschool and schools like Overlee. As advocates of early education, the last thing a regulation should do is wipe out an affordable early childhood program that requires reasonable parental involvement. 

 

Thank you,

Grace Carlson, Overlee Preschool Parent

CommentID: 64557