Action | Amend Standards for Licensed Child Day Centers to Address Federal Health and Safety Requirements |
Stage | Proposed |
Comment Period | Ended on 4/6/2018 |
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 was founded in 1945 and has been 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.
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 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.
Early education is so critical and the cooperative preschool model have been essential to our kids growth and development over the last three years. Having a place to actively watch our kids grow and learn essential life skills -- how to respect the feelings, ideas, and right of others; to resolve conflicts and solve problems; and to explore new ways of doing things - is irreplaceable to our family and community.
We think it's essential that the State of Virginia continue to support cooperative preschools and all the positive externalities it provides the State. In maintaining/supporting the cooperative preshool option for parents throughout Virginia, we ask that you all reconsider the proposed staff orientation and ongoing training regulations, as discussed above, that would be uncessarily burdemsome and detrimental to the future viability of cooperative preschools.
Thank you for your consideration.
Sincerely,
Chris Wood
Overlee Preschool Parent
Arlington, VA