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  11:29 pm
Commenter: Mary Burkhalter, Hunters Woods Co-operative Preschool

Oppose changes
 

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.

On a personal note, my opinion is that the importance of developing a real community of support in your local neighborhood has never been more important than today.  If you take 5 minutes to read the news, I am sure anyone would agree. Before my family joined HWPS we didn’t know anyone living in our community.  The co-op has been our way to make family friends and be involved in our community that has carried over into the elementary school as well.  It is not the same as dropping off your little one and going home, we spend so much time in the school that we really get to know each and every child as well as their parents.  These relationships have been such a gift to my family.  Please consider the importance of developing a community when you consider your decision.

Making the choice to be a stay at home mom, we were pinching pennies to save as much as possible.  By the time my son was 3 we were looking at preschools and a co-op was the only affordable option. It was the best of both worlds – an affordable preschool and spending time with my son at school.  These changes in legislation would make the tuition increase to a point where it is not affordable or even feasible.

Additional education hours will create an impossible and ridiculous burden.  Families of 3 and 4 year old children simply do not have an additional 36 hours of time.   All of the families involved in the co-op are busy raising little ones and we are already volunteering a significant portion of our time.  HWPS has been open for nearly 50 years and it works like a well-oiled machine.  The last thing we need is government-mandated regulations to destroy a beautiful community.  Respectfully consider our situation and how this will affect our lives when you make your decision. 

CommentID: 64733