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  9:23 pm
Commenter: William Moore, Rock Spring Cooperative Preschool

Co-Ops in the community- I OPPOSE the changes
 

On behalf of Rock Spring 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 a father of two young children, I am extremely grateful for my wife to be able to have an active role in our daughter's education, devleopment and social commuinty.  All of this is made possible by the Cooperative Preschool structure, which has been thoughtfully and lovingly delveoped by an extremely invovled and caring Parent contingency at Rock Spring Coop Preschool over the last 75 years.  Rock Spring has created an environment for my wife to be part of my child's development in a way that wouldn’t be possible otherwise. She is able to have first hand insight on our child's skills, social interaction, motor, verbal and cognative developement and to participate side by side with her in the fun and learning she is provided through RSCP. 

We are grateful not only to be part of my daughter's classroom, but also to have the opportunity to volunteer through the school and meet other moms and dads in our community. This would not be possible if the school was set up any different than it is today. Additionally, the cost for childcare in this area is at an all time high whether it’s in school care or in home care, and the current school system allows for a slightly lower and more manageable cost.  I find it appalling that our government would find it appropriate to introduce language into policy which effectively forces a parent to be less inovlved in their child's life and development. 

The proposed new training requirements for parents who volunteer at cooperative preschools are much too burdensome for parents of young children. Additional training hours for parents would ultimately create extreme difficulties in time management and most importantly cut down spending quality time with children and families. It simply is not feasible to ask parents to undergo 16 hours of orientation training and 20 hours of annual training.

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. Our 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.

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

Our school community would just not be the same with the proposed changes. 

Sincerely,

William Moore

Parent at Rock Spring Cooperative Preschool

CommentID: 64710