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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4/2/18  1:05 pm
Commenter: Paul McDonald, AUCP

Impact of proposed regulations on cooperative preschools and their families
 

To preserve the parent cooperative preschool in Virginia, the Proposed Amended Standards need to 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.

The currently proposed amended standards put parent cooperative preschools in jeapardy. The current Standards for Licensed Child Day Centers include this exception for cooperative parents: "Parents who participate in cooperative preschool centers shall complete four hours of orientation training per year". 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:

  • Cooperative parents undergo the same background checks as staff;
  • Cooperative parents assist professional staff in the classroom 1-2 days/month, for a total of 3-6 hours/month (which means the required training hours could exceed the number of hours in class for the entire year!); and
  • Cooperative parents serve a unique position in the classroom, where they remain under the guidance and supervision of professional staff but may for small periods times not be in sight and sound supervision of staff. For example, I may be in the hallway helping children wash hands while the teacher is in the classroom setting up

The proposed 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.

My children have attended AUCP for the past several academic years, and I hope that my youngest daughter will have the opportunity to experience this amazing community for several more. I worry that these proposed standards will create such a burden of time commitment on busy, barely-manaing-it-all-as-it-is parents, that our thriving community will quickly wither, the school will not survive, our little girl will miss out on an important formative experience, and the deepest root our family has in Virginia--our AUCP community--will be cut.

 

CommentID: 64423