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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4/6/18  11:11 am
Commenter: Cheryl Gnehm

Changes Requested by Cooperative Preschools
 

On behalf of Overlee 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 one of the oldest Cooperative preschools in Northern Virginia,  Overlee Preschool was founded in 1945 and has been a place for parents to actively participate in their children’s early education by working directly in our classrooms as teachers’ aides. The new requirements for staff orientation (22VAC40-185-240) and ongoing training (22VAC40-185-245) would impose an undue burden on our parents by expecting them to complete 16 hours of orientation and 20 hours per year of ongoing training. Our parents volunteer on average only 50 hours a year in the classroom. Parents who are volunteering their time are simply not going to be able to complete the same orientation and training requirements as our paid classroom teachers.  

We request 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. 

Parents working in classrooms at Overlee Cooperative Preschool complete all of the background checks outlined in Background Checks for Child Welfare Agencies. They work under the direct supervision of well qualified and trained classroom teachers.

If the orientation and ongoing training sections of the proposed standards are not changed, cooperative preschools like ours, may be forced to shut down, as parents are unwilling to enroll their children in programs which put unreasonable burdens on them. Either outcome robs children of the high quality, affordable early education that cooperative preschools provide. 

My husband and I very specifically chose a cooperative preschool so that we could participate in our children's classroom setting. We both volunteer at the school so would each need to complete 36 hours of training. We both work full time in demanding jobs with long hours. The additional training requirements would make it impossible for us to continue sending our children to a cooperative preschool and we would lose this very special opportunity to be with our kids. One of the greatest values of the cooperative model is the community that naturally revolves around it. Parents are actively engaged and participating in the school and become invested in each of the children, not just their own. Our children are thriving in this community and we would be incredibly saddened to see it die away under untenable trainng obligations.

 

Cheryl Gnehm

Overlee Preschool Parent

CommentID: 64785