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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4/5/18  9:45 pm
Commenter: Kate Coleman

Preserve co-op preschools
 

As an Arlington, VA resident and parent of three children who attend or have attended co-operative preschools,  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.

The proposed new training requirements for parents who volunteer at cooperative preschools are so burdensome that they will doom the traditional cooperative preschool model. It is not feasible to ask parents of young children to undergo 16 hours of orientation training and 20 hours of annual training. This is especially burdensome considering the high cost of living in Arlington, which requires many households to have two working parents who are already struggling to balance work and home life. . 

We ask 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.

Cooperative preschools have been a valued early education option in Virginia for decades. My children's school, Rock Spring Cooperative Preschool, was established in 1943. The traditional cooperative preschool model has many benefits for children and families including low tuition (because the parents serve as unpaid classroom aides) and deep, meaningful parental involvement in children's early education (widely acknowledged as beneficial for children's development).

In order to comply with the new regulations, cooperative preschools would have to hire aides so that parents would not be counted in staff ratios. This would not only reduce the significance of parents' roles in the classroom, but would also raise tuition so significantly that many families could be left without any affordable preschool options. Decreasing childcare options at a time when parents struggle to find affordable childcare is the opposite of what Virginia should be doing to support its families.

We respectfully urge you to implement the above changes to the proposed regulations in order to preserve the viability of traditional cooperative preschools. 

Sincerely,

Kate Coleman

Arlington, VA

CommentID: 64713