I strongly support the proposed Add-On Endorsement in Special Education. This initiative represents a thoughtful and practical response to the critical shortage of certified ECSE teachers across the Commonwealth.

School divisions are facing significant challenges in recruiting and retaining licensed ECSE teachers. The current pathway to endorsement can be lengthy, costly, and difficult for already-licensed teachers to navigate while working full time. These barriers discourage qualified teachers from expanding their credentials, even when there is a clear workforce need.

Creating a streamlined add-on endorsement will reduce time and financial burden while maintaining professional standards.  This approach will allow experienced, licensed educators to build on their existing knowledge and skills to serve children with disabilities from birth through age five. This will ultimately prioritize both educator access and student needs.

Support for Fast-Track Repeal of Fee Requirements (8VAC20-830)

I am writing as a school administrator serving children from 16 months through middle school to express strong support for the fast-track action to repeal the Fee Requirements for Processing Applications (8VAC20-830).

The removal of background check processing fees is an important and practical step toward strengthening the early childhood workforce. Childcare programs across Virginia continue to face persistent staffing shortages, high turnover, and increasing operational costs. Even relatively modest per-employee fees create cumulative financial strain in a field where margins are already extremely limited.

Early childhood programs experience higher staff turnover than many other sectors, which means background checks occur frequently. When these costs are shifted to programs, they function as an ongoing operational expense rather than a one-time administrative cost. Eliminating this fee reduces barriers to hiring, supports timely onboarding, and allows programs to direct limited resources toward educator compensation, training, and classroom quality.

From a workforce perspective, reducing administrative costs tied to hiring is aligned with the Commonwealth’s broader goals to expand access to childcare and stabilize the early childhood system. Providers cannot increase capacity without the ability to recruit and onboard staff efficiently and affordably.

This change also reflects an understanding that regulatory requirements designed to protect children should not unintentionally create financial barriers that limit program sustainability. Background checks are essential and universally supported by providers. Ensuring they remain accessible without additional financial burden strengthens compliance while supporting the workforce.

I appreciate the Department’s efforts to simplify the fee structure under 8VAC20-821 and support the fast-track repeal of Chapter 830. Actions such as this demonstrate responsiveness to provider feedback and represent meaningful progress toward a more sustainable early childhood system.

Thank you for the opportunity to provide input and for your continued work to support children, families, and early childhood educators across Virginia.

Michelle D’Antonio
Head of School
HRI Montessori

I would like to record my support for the add-on endorsement in early childhood special education (ECSE). Our school division has had an ECSE position posted all year, with little interest. Those who did apply did not have the ECSE endorsement. Teachers who currently teach VPI would benefit from this add-on endorsement. This regulatory action would enable teachers to save time and expense. Ultimately, our youngest learners will benefit from qualified, licensed teachers.

With the teacher shortage a reality, the more we can do to encourage adults to work with young children, especially B-5 special education children, the better our school divisions will be prepared. 

Thank you for this opportunity to comment.

Respectfully,

Angie White, Early Childhood Supervisor

I support the add-on endorsement in Special Education Early Childhood (ECSE) for a number of reasons:  1) It will provide an attainable option for current teachers with PreK-3 or PreK-6 (as well as Special Education General and Adaptive Curriculum) licensure to add an ECSE endorsement. Currently, existing early childhood educators would need up to 27 credit hours to obtain ECSE endorsement. This poses a significant barrier in terms of teacher time and money.  2) Licensed ECSE teachers have the opportunity to pursue an add-on endorsement in early childhood education for three and four year olds. The proposed add-on endorsement in ECSE provides parity.  3) Decades of research and experience document the value of inclusion for preschool students with and without disabilities. Virginia needs teachers who can meet the needs of ALL young children whether funded through ECSE, VPI, Mixed Delivery, Head Start, subsidy, family pay, etc. Flexible options such as this add-on endorsement provide an additional pathway to highly competent inclusive service delivery.

I support the add-on endorsement in Early Childhood Special Education and believe it is a necessary credential to enhance the quality of our early learning classrooms. I was personally endorsed in both Early Childhood Special Education and General Education, as this was an option at the college from which I graduated in West Virginia nearly 20 years ago.

I relied heavily on the knowledge I gained in special education to serve all preschool children, particularly because many students enter preschool with unidentified special needs. Having this training and endorsement helps teachers adequately address the needs of all learners in their classrooms.

In my current role as an administrator, it is very difficult to find teachers who hold an endorsement in Early Childhood Special Education. This is largely due to the additional coursework required beyond the standard special education endorsements for older age groups.

Additionally, Virginia needs to continue moving toward more inclusive models for all children. Providing opportunities for students with special needs to begin their education alongside their typically developing peers in preschool, supported by teachers who are trained to meet diverse learning needs, helps establish a strong foundation for inclusive practices. These practices ultimately benefit all students.