Dear VA Department of Social Services:

I am writing to strongly oppose the implementation of the proposed changes to the Standards for Licensed Child Care Centers (22VAC40-185) as written.  I have served on the board of directors at Dulin Cooperative Preschool in Falls Church, Virginia for the past six years, while three of my children have attended the preschool.  As treasurer of the board, I have a deep understanding of the financial impact these regulations would have on both the cooperative preschools and the families that use them.

First, everyone wants children in preschool to be safe and provided with appropriate developmental education.  That is not in dispute.  What is troubling, however, is that these proposed regulations will function in the real world in direct opposition to those goals.

Second, there is similarly no dispute that meaningful parental involvement in early childhood education is incredibly beneficial to young children in terms of their future educational success.  Cooperative preschools are at the forefront of that involvement, with parents providing substantial administrative work to preschools, as well as support to qualified teachers in the classroom.  That significant involvement also provides benefits to parents and families by fostering community and developing support systems. 

Third, the proposed regulations will create extraordinary increases in expenditures of both money and time to cooperative preschools without providing corresponding benefits to children or to families.  Families of young children in Virginia already struggle to find quality, affordable childcare/preschool for their children.  These regulations do not alleviate the problems, but exacerbate them.  In short, the required training will have very little, if any, return on the investment in terms of benefits to children or the community.

Finally, these regulations will substantially impair cooperative preschools’ ability to provide affordable early education to children.  Generally speaking, families who wish to enroll their children in preschool have one of two resources:  time or money.  Those with sufficient funds will be less affected by these regulations.  Those families with only time to offer will be substantially harmed, and most likely excluded, from early childhood educational opportunities.  The affordability of preschool and daycare will be harmed by these regulations and children will miss out on opportunities to thrive if they are implemented in the current form.

With those general comments in mind, I propose the following specific changes at a minimum:

• In 22VAC40-185-245C – remove the words “who are not considered staff” from the regulation.   Increasing the required annual training hours for volunteering parents in cooperative preschools from 4 hours to 20 hours (plus an addition 16 hours of orientation) is unduly burden for both parents and schools.  Further, the additional hours will not materially benefit the children served by this model, as classes are already structured and led by qualified teachers.  Finally, finding the time to attend training outside of regular work hours would be an additional burden. 
• In 22VAC40-185-240 – create exceptions to the 16 hour orientation requirement both for parents volunteering in cooperative preschools and for appropriately educated and trained staff members.  While state mandated basic training makes sense for child care workers who lack professional levels of education, it does not make sense for highly qualified career educators.  In fact, requiring 16 hours of basic education will cause educators to forego more appropriate and higher level training they would have otherwise obtained. 
• If these regulations do go into effect, I propose that, because of the substantial changes, there be a delay until at least the fall of 2019 to allow cooperative preschools and other child care programs to make plans for coming into compliance. 

In conclusion, major changes to these regulations are necessary.  The regulations as written do not serve children, families, or daycare/preschool employees.  In fact, they will cause harm to all of them.  The cost to train all volunteers in cooperative preschools will be insurmountable.  Even if it were possible to provide for the costs, it will be difficult if not impossible to find staff willing to complete the required training hours.  Those costs will be placed onto parents and families, and the increases will be significant enough that children will miss out on educational opportunities.  Please consider the real world impact and make changes to the proposed regulations that will allow the cooperative preschool model to continue into the future.