I am concerned that the proposal includes the elimination of the Certified Preschool Exemption.  My school was under this exemption for many years as it is fully accredited by the American Montessori Society and AdvancED.  We had to add licensure when we added an aftercare program, and maintained both Certified status for the morning program and licensure for the afternoon.  This was cumbersome, and we let go of the certification, and licensed all programs.  This in itself is a concern because our school has to meet very rigorous standards, and licensure sometimes prevents us from conducting our programs in an optimal Montessori way.  If we could go back to Certified Preschool status, we would do so.  I would actually advocate for the opposite of this elimination - to allow a fully accredited school and ALL of its programs to be Certified and, therefore, exempt from licensure.  An accredited school should still have the ability to choose the exempt from licensure route.  I am pleased to see that the ratio for balanced mixed age groupings is still listed as 1:14.

This has been an issue for a while.  The regulations state that two year olds have a different ratio (mind you much needed) but include them in the preschool definition.  This causes confusion when working with subsidy as they only have rates for preschoolers, but two year olds (at least in my program) have a different cost- due to the different ratios.  This makes for confusion.

There needs to be clairfication on whether Medication Administration training counts as annual training, as well as Daily Health Observation.

I am glad to see that CPR/FA now counts fully as annual training hours.

I am interested to see how removing the exemptions from lincensure affects non profits like the Boys & Girls Club and also how public schools that offer prek have been exempt will now be required to be licensed?

Thank you for your hard work!

At first glance, I am concerned about the exemptions and how this change will change Recreation, Government run summer camp programs for school age children.   What is the timeline for implementation as this may have major impact on program implementation and budget.

I have some concerns about the new regulations, including the striking off of the current exemptions, including those for Sunday school and Summer Camp programs. While I believe that these should be run so that staff and programming are of high quality, the amount of record keeping required for each child may provide a barrier to participating in these programs. For example, new visitors to a church won’t be able to let their child participate with the other children in Sunday School and parents will need to provide excessive paperwork for their child to attend only a few hours of summer camp the entire summer. If these regulations really are to apply to any program now (without hourly/amount exemptions) offered for two or more children not in the home of the provider, then parents will end up having access to fewer caregiving opportunities, especially back-up care, as it will be too costly to operate.

While I appreciate the concerns for the children who are in non-parental care as well as the importance of looking after them, I also know the concerns of centers such as ours who must meet all of these requirements, and think that any new regulations must come with greater opportunities for centers to meet these requirements. For example, it can sometimes take months to receive back something so simple as a CPS background check. CPR and First Aid is important, yes, but waiting lists for these classes can be a real barrier, especially for programs like ours that have less than a handful of staff members and cannot afford to hire someone to come in just for our center. Under these new regulations, children without immunization records won’t be able to participate in programs—but how does the center have control over the doctor who “doesn’t have time” to give records to parents (for weeks or even months?) How can we meet the new demands without resources being available or with no greater control over external factors than we had before?

Additionally, the continual increase in annual training hours per staff member should not be done across the board. For small programs like ours, I must have substitute staff or we won’t have enough staff to operate if even one regular staff person calls out. Yet I have had a substitute, for example, who has worked less than 5 hours in as many months. The costs of CPS checks, fingerprinting, CPR & First Aid will total almost $200 for each—ok. But is it really necessary for me to pay another additional $180 (at minimum) for her wage to compensate for training time, and that is assuming I can find 20 hours of FREE training that actually fits with her schedule? The amount of substitutes willing to do this, in addition, to be called in for only a few hours, is very low, and increases the difficulty of finding and keeping subs. A program that operates 10 days out of the summer months can’t afford to pay for this training for its staff members, either. The reality is that these program costs end up being passed down to the parents, and that in turn provides barriers to access to the people who need it most. Substitutes or staff who work less than 4 hours a week or less on average should have a training requirement that is halved, at most, (or who will work a total of 30 days or less, as for a short-term summer program).

Childcare is at a crisis in our country. Parents do not have access to high-quality “affordable” child care. Yet in even so-called “unaffordable” child care, staff members are paid wages that allow them to qualify for FAMIS and Food Stamps. The poor wages discourage staff retention and application. Everyone is stuck in a bind and these regulations make the bind tighter, (as centers and therefore parents) are left to shoulder the burden of these extra responsibilities—from not being allowed to retain or hire that GED candidate, no matter how wonderful she is with kids, to being left scrambling for summer care as short term programs are forced to close or hike up their rates, to schools (such as private independent Montessori Schools) that also have a pre-k program seeing their administrative costs rise as the time they need to deal with another licensing body increases.  I do agree that the quality of programs offered for young children is essential, yet I do not believe all of these changes will produce the desired effects as programs cut corners on actual services to account for increased overhead. 

It is wonderful that group sizes have been stipulated. Ratio itself is not enough.

40-185-220B:  Adding the language “aides under 18 shall not be left along with children” is too broad and restrictive, especially for smaller daycares.  We would like to see an exception for smaller classrooms and daycare centers.  As our rooms are small and close to each other, we are able to hear what is taking place in each classroom from the main office. If anything, we would like for it to say “aides under 18 shall have sight or sound supervision.  That way they can be left alone in a classroom, but not entirely left alone without supervision.  As the requirements for a program leader/lead teacher must be 18 years of age, an aide under 18 would not be the main one responsible for teaching/instructing the children for most of the day anyway.  This way they could be used during rest time, absence of the lead teacher for short period of times, or during pick up and drop off times.

Regarding 40-185-245A about increasing the annual training to 20 hours.  We would like to see an exception for part-time and substitutes just like short-term program which only need 10 hours of training a year.  It is already a challenge to obtain the 16 hours of training for full-time employees.  It is almost impossible to find a part-time employee or sub who is willing to do 16 hours of training each year. Increasing the hours to 20 hours across the board for all employees too demanding and is setting the daycare center up to fail.

With all of the required training that needs to be completed already for new staff, adding the requirement that all staff shall have CPR and first aid within 30 days of the date of employment as outlined in 40-185-530A is excessive.  I can see having more than one person on the premises at all times would be needed, however, making it a requirement for all staff to have this training and to obtain it within 30 days of employment is excessive.  It would be more obtainable to require all program leaders/lead teacher to have CPR and 1st Aid training and extend the time frame to at least 90 days of employment.  Aides, part-time employees, and subs should not be required to have this training.

Please specifically explain the meaning of the following item - most specifically the meaning of the words "always be in the care of".  4. Any child for whom emergency medications (such as albuterol, glucagon, and epipen) have been prescribed shall always be in the care of a staff member or independent contractor who meets the requirements in subdivision 1 of this subsection.

These regulations sadly miss an opportunity to clarify expectations and best practices. The lack of readability reduces clarity and decreased compliance. The length makes the process seem overwhelming and increases the barrier to licensure. We can do better. This regulation update also fails to deal with multiple other sections of regulations that need modernizing.

22VAC40-185-240 B - DSS Orientation Course

• It is unlikely that this course will provide any value to teachers, there is no research to indicate courses of this nature are effective at teaching material or impacting behavior.

• Any course implemented should reflect best practices for adult education.

22VAC40-185-245 G Medication administration and daily health observation

• It's unclear why one would group these two things together and this decreases clarity of the following sections. This is EXTREMELY confusing.

• These two things MUST be separated.  Sections 1-4 would be under medication administration and section 5 would be its own daily health observation section.

• Further, the Medication administration sections 1-4 are poorly organized and written.

  • Section 1 and 3 say the same thing, they should be combined. I see absolutely no reason to separate them. Once rewritten this section should go first.

  • 1a and 3b Addressed the department rather than the licensed program which is not done in other areas. I just found that confusing.

22VAC40-185-245 G 4 Emergency Medications

• The “in the care of” wording concerns me.

• How would that work practically for children in the program? Is this expecting all staff to get MAT training?

• If there is an administrator not included in ratio of any other classroom immediately on call and MAT trained that would actually in my opinion be better because the person would be available and the other children supervised but that would likely not meet 'in the care of'.

• Perhaps it could state, “A plan shall be in place to ensure any child for whom emergency medications have been prescribed will have immediate access to a trained staff member.”

22VAC40-185-80 2 - Reporting of Injuries

• While it is very valuable to have injuries reported for data collections however this has already caused some questions.

• These reports are being used by DSS to target programs for citation which is eroding the relationships between licensing agents and the programs, not to mention adding additional work to already over stretched agents.

• Will these reports trigger a licensing visit? If so, how will the licensing agent’s caseload be adjusted to accommodate?

22VAC40-185-240 D - Orientation Period

• It seems this is implying though it is unclear that a program could not have an orientation period longer than 7 days even if the staff member is not supervising children during the period.

• Many programs have longer orientation periods, I don’t know why that would be a problem.

• It seems it could say “within seven days of assuming supervising responsibilities”

22VAC40-185-40 M - List of Allergies

• This seems confusing and to add unnecessary complication. I'm not sure why it would be confidential vs. just posted. Does all children mean other classrooms need a list of children not in their classroom? Does all areas mean also outside?

22VAC4-185-350 A Group Size

• The proposed group size for toddlers is 15, based on a 1:5 ratio which is understandable. Our program operates at a lower 1:4 ratio with a group size of 16 and I think that should be acceptable, it is only one more child and would be an additional teacher.

22VAC40-185-80 B 1 C

• This is unclear and I'm not sure why it would be necessary or even helpful.

• For example if we have two snow days would we need to notify?

• What if our power was out and we closed early one day then it wasn’t repaired the next so we closed?

22VAC40-185-240 C

• C would be unnecessary if you just add the word all to D between 'completed on ALL the following'

• Remember brevity and clarity for readers increases compliance.

22VAC40-185-245 B1 Exemptions to Training Requirements

• It is completely unclear who “staff who do not work with a group of children” would be.

• Administrators, directors, floaters, substitutes.

• Perhaps something about “regularly supervising children” would be clearer.

22VAC40-185-245 E (1-12)

• This has been repeated three times it seems that it would be clearer to write it once and refer to it.

• Perhaps a section on training topics”The following are acceptable training topics” Then with some listed as required for orientation and ongoing, orientation only, ongoing only.

NOTES ON EXISTING REGULATIONS

22VAC40-185-140 B Physical Exam

• This elaborate requirement is completely unnecessary just a simple regulation based on the lowest requirement there would be fine.

22VAC40-185-500 A3 a and b Hand Washing

• I have no idea why you would wash your hands before giving a child a diaper change or helping them use the potty. That seems really unnecessary. No one washes their hands prior to changing a diaper.

22VAC40-185-500 B 5 States Diapering

• It is best practice to allow cloth diapering if the program can do it in accordance with the other regulations

22VAC40-185-500 C Toileting

• This is burdensome and unnecessary.

• A classroom with 15 toddlers would not likely need two toilets and a changing table.

• How is it determined who is toilet training and who is not?

• Best practice would be to call it toilet learning rather than training in my opinion and for it to be a slow child guided process of introduction. But if we are following that process than ‘more than 10 children in the process of being toilet trained’.

• It is best practice to have bathrooms in the classroom of the children but this would encourage children have a communal bathroom.

22VAC40-185-510

This section is so poorly organized it is very unclear when the regulation is talking about prescription and non-prescription medication. It would be much clearer is it was a section for all medication (Rx and non) then a section for prescription medications in addition.

I have a strong concern over raising the number of hours that teachers need each year from 16 to 20 hours.  20 hours is more than my teachers work in one week! It is hard to find people willing to do this much training. We are not a big program and this puts an additional burder on my teachers that is unfair.  I don't have the budget to pay for my teachers to all do 20 hours a year, and while there are some good free programs, they are still limited.

I am also concerned, if I am reading it correctly, that any staff who teach a child with an allergy have to be MAT certified.  Currently we have a limited number of teachers/ director certified. We are available should an emergency arise.  To have all the teachers, who teach a child with an allergy certified is a financial burder on my school.

In general, please understand that many of us, who are smaller preschools, try very hard (and usually succeed) at meeting regulations.  However as they get harder and harder to meet you are putting us at a disadvantage.  Please consider amending regulations for smaller centers! Also, please look at all the wording for these regulations.  I am an educated professional and trying to read through the pages and pages of regulations and make sense of them was difficult.  It was too long and too complicated. Thank you for listening!

We agree that the licensing guidelines could be organized more clearly and concisely. 

22VAC40-185-80  Attendance records; reports

A. The center shall maintain a written record of daily attendance in each classroom that documents the arrival and departure of each child in care as it occurs.

Ques: Can a center used a preprinted log that offers ability to check units of time; for example the form could have blocks marked 9:00am-9:15am, 9:15am-9:30am, etc. and a teacher could quickly check arrival/departure times as children’s arrival/departure occurs?

22VAC40-185-240. Staff Orientation

A. Staff shall complete a minimum of 16 hours of orientation training appropriate to the age of the children in care.

&

22VAC40-185-245 (below)

G. Staff who are employed prior to (insert effective date) shall complete the VDSS-sponsored orientation training as required by this section within one year of (insert)…This training may count towards requirements

Ques:  Do these both apply to all Child Day Centers (our preschool is a half-day program, only open 20 hours per week)?  If so it seems these hours apply to required continuing education/training hours, is that the case?  

That would mean current staff would receive 16 hours for this training?

Comments:  Currently our new staff receive required training their first day at the center covering all aspects of their responsibilities.  Most centers use the first few months with on-the-job training focused and offer continuing training opportunities for new staff, but 16 hours orientation seems excessive and will definitely affect our budget.  We already have staff who think that 16 hours per year of continuing education per year is more than enough and feel they are often just reviewing the same types of topics over and over.  We do not want to discourage those considering working at our center from choosing to join our developmental program as they are exploring working in a developmental preschool setting.  It is also a huge hit to our budget.  We would be looking at over $200 per new employee just for orientation and if we find that staff member is not a good fit, this expenditure must be repeated. 

D. 9. & 10.  Prevention of sudden infant death…safe sleep…prevention of shaken

Baby...or distraught children.

Ques:  Do centers with children ages 30 months to 5 years old need to include these trainings?

22VAC40-185-245  Ongoing Training

A.  Staff shall complete a minimum of 20 hours of training appropriate to the age of the children in care annually. 

Comments:  We are a part-time preschool program of 20 hours per week.  Has there ever been consideration for having training hours based on whether a program is half day or full day?  We want to value our staff’s time and pay for training of all staff for 16 hours plus the cost of the continuing education courses.  We are a smaller program and already absorbed the changes from 2005 standards to add more training hours starting on June 1, 2006 to 12 hours   Then June 1, 2007 to 14 hours and then since June 1, 2008 to 16 hours.  Our continuing education costs are becoming a significant portion of our budget and without even considering the proposed addition of CPR/First Aid costs should we have to train all staff (we train 10 staff each year at this time) we will have to consider cutting our staff significantly.  So proposed training actually lowers the quality of our program.  We figured an increase of $1200 alone just to pay staff to add 4 hours each in training.  That does not include the cost of trainings. 

Will all trainings including Daily Health Observation, CPR/First Aid, and MAT and eMAT trainings be considered in training hours moving forward?  This is not really clear and needs to be easily understood.  If staff need 16 hours and safety is paramount, why wouldn’t they receive at least part of the training time for each of these?

G. Any child for whom emergency medications (such as albuterol, glucagon, and epi-pen have been prescribed) shall always be in the care of a staff member or independent contractor who meets the requirements in subdivision 1 of this subsection.

Question/Comment: This is very vague.  “In the care of” – does this mean any staff member on-site, or must it be the person who directly supervises the child? 

22VAC40-185-500  Handwashing and toileting procedures

Question/Comments:  What is the rationale for a staff member washing their hands “before” helping a child using the toilet and before diaper change?

In researching this topic, the Center for Disease Control (CDC) recommends washing hands after using the toilet, after helping a child use the toilet and after diaper changes.  We have included the link to this information.  https://www.cdc.gov/handwashing/when-how-handwashing.html

22VAC40-185-530  First Aid training, CPR and rescue breathing

Any staff who work directly with children shall have, within 30 days of the date of employment, a current CPR/First Aid.  Staff who work directly with children who were employed prior to (insert date) must complete CPR/First Aid within 90 days. 

Ques:  Why require ALL staff to be trained in CPR/First Aid?  Currently you need to have a staff member on site who is available and is training.  Also, why have new employees receive this within 30 days of the date of employment when there are already staff available with this training?  Why require all staff to be trained? 

We would suggest there could be consideration of using a staff to children ratio or total number of children attending the program daily.  This means that rather than requiring all staff who work with children to be trained, a center would use a basic calculation.  For example, a center would calculate that if their center has 40 children attending their site daily, they should have one staff member trained for every 8 children attending.  This would allow a center to calculate what they need daily, i.e. with this ratio they would need 5 staff members trained in CPR/First Aid on site daily.  This means there would be many options for someone to help in the event of an emergency requiring CPR/First Aid.  This training is costly, this year were quoted $80 per person to receive this training.  That does not include paying the staff member for their time to attend the course.  So this cost is $115+ per staff attending and is good for two years.

4. Any child for whom emergency medications (such as albuterol, glucagon, epi-pen) have been prescribed shall always be in the care of a staff member or individual Contractor who meets the requirements in subdivision 1 of this subsection.

We are a small center and the cost to train all staff is becoming truly cost prohibitive.  We are already asking a lot of this part-time staff.  We feel that the 16 hours now required gives us a well-trained staff.  We currently spend $1,000 each year to train about 8 to 10 of our total 24-26 staff members in CPR/First Aid each year.  We added MAT training and some eMAT training for 6 to 8 employees.  This means we generally have 16+ staff who have a 2-year CPR/First Aid certification and 4 on staff at all times with MAT or eMAT. This also means we have many staff members available throughout our center close by in case of emergencies.  We like to be able to schedule trainings to make it easy for staff to fit them in with their work schedule.   While it’s nice to try to have new staff trained in these areas within 30 to 90 days, it is really overwhelming to new staff and what we’d like to focus on is our developmental program and their responsibilities to the children in our care.  It can also be an unnecessary expense for centers.  Not all trainees become long-term employees, and we can’t afford to invest so much of our budget into someone who we do not choose to keep as part of our program.

We figure a cost of up to $15 to $40 per hour per staff member for training compensation which includes their time and cost of trainings like DHO, CPR, eMAT, etc.  This doesn’t include the costs we will incur for the new fingerprinting requirement.  So each staff member adding 4 more hours could cost a center $60 to $160 per person each year.   Multiply that by a staff of 20 and we will double our training costs.  This forces us to cut staff positions and/or increase tuition.  We then become unaffordable to young families and certainly less competitive with other schools in our area that claim religious exempt status.  We currently spend well over $3,000 per year training staff.  We cannot add an additional 4 hours to our part-time program budget.  

Thank you for your consideration.

Until now, there has been a robust system of cooperative preschools in Virginia that permit parents to contribute to "staffing" level of preschools by volunteering to assist in the classroom.  Parents take turns donating their time, so as to be involved in the early school years of their children and to reduce the costs of preschool (because less staff has to be hired for classes).  The proposed changes, however, will not permit these parents to continue to be treated as volunteers if they are are being counted on to provide coverage in classrooms.  Each parent, although they likely only volunteer one day a month (or less) in the classroom, will now be required to have all of the regular training of full-time preschool teachers.  (And go from 4 hours a year to 20 hours a year in training.)  That is simply impossible for most parents, whether they work inthe home or out of the home.  Because volunteering parents without that training cannot be used to provide (even partial) coverage for classrooms, all cooperative preschools will have to hire staff to replace cooperative parents, and use parents as redundant volunteers, which is utterly contrary to the point of the model.  Please consider exempting cooperative/volunteer parents from the staff training requirements, or else find a "middle-ground" where volunteer parents without full staff training (but full volunteer training) may count for, say, one-half of a staff person for staff-student ratio purposes.  Thank you.

My area of concern has to do with training.  Currently, the regulations require parents in cooperative preschools to have 4 hours of training annually.  The proposed change to the regs (22VAC40-185-245) requires that all parents “who are counted in staff ratios” (which now specifically includes parents in co-ops) have 20 hours of annual training, including CPR and first aid certification. This is an unreasonable expectation of preschool parents in terms of time and expense.  To avoid having parents counted in the ratio (to keep them from having to meet the training requirement), we’d have to have to hire an additional staff person to be in the classroom every day, which would cause our tuition to rise to an untenable level.  

There are many long-term successful cooperative preschools in Virginia.  The cooperative preschool model is based on parent participation.  In our case, we have one paid (educated, trained, professional) teacher in the classroom with three parent helpers and 20 children (ratio of 5:1).  Having parents as classroom aides is common among cooperatives.

The cooperative preschool model has many benefits including low tuition (because the parents serve as unpaid classroom aides) and genuine parental involvement in children’s early education (something virtually everyone acknowledges is important).  When parents are involved in their child’s education early on, they generally continue to be involved.  In my experience many of the parent leaders at the elementary, middle, and high schools in our area started out in cooperative preschools. To not have cooperatives as an option for early education would ultimately impact educational involvement and leadership in the entire community.

I ask that VDSS to remove the language “who are not considered staff” from section 22VAC40-185-245 describing the required training for cooperative preschool parents.  

I am writing to express my concern over the effect of the proposed new language in 22VAC40-185-245 regarding the required training for parents who participate in cooperative preschools. The implementation of the new language for such parents would no doubt ensure the termination of the cooperative preschool. I have a vested interest in Dulin Cooperative Preschool, in particular, as my granddaughter currently attends this school. My daughter, son-in-law, and I all are participating cooperative volunteers. Of greater concern to me is the number of children in Virginia who will be adversely affected if parents at a cooperative preschool are required to complete the number of hours of orientation and additional training hours put forth in proposal.

I have thirty-four years experience in education. I was a teacher in grades K, 1, and 2. I know firsthand the importance of involving parents in a child’s education. My students whose parents played an active role during those early crucial years were more successful not only during the year I had them but in the years that followed. There was not a single more significant factor in the success of my students than that of engaged parents.

Please acknowledge the benefit of cooperative preschools whereby teachers and parents unite to provide the initial (and in my view, the most critical) educational experience for children. Please recognize the children attending cooperative preschools will suffer if the proposed language is allowed to dismantle the traditional cooperative model.

Please remove “who are not considered staff” from the ongoing training exemption for cooperative preschools (22VAC40-185-245C).

In closing, I implore you to consider the impact of the new proposed regulations. Cooperative preschools are the most viable option for many Virginia families. And in many instances, cooperative preschools may be the only option. All children deserve a chance to learn, achieve, and reach his/ her potential. Please ensure our children are afforded that opportunity.

The proposed new training requirements for parents who volunteer at cooperative preschools are so burdensome that they will doom the traditional cooperative preschool model. It is not feasible to ask parents of young children 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.

My name is Halee Robbins, and my daughter attends Dulin Cooperative Preschool in Falls Church, VA. As the class parent for her class, I work closely with the school to coordinate various activities. While serving in this capacity, I have seen the camaraderie between teachers and parents. We work together toward a common goal; to provide the best early educational experience possible for our children. Serving as a cooperative parent in my daughter’s classroom has allowed me to see her from a different viewpoint. I have been able to observe her in several activity settings and have witnessed the way she interacts with peers and her teacher. I can see how developmentally she compares with others, and through these observations, I am able to address her needs by providing appropriate activities at home. The cooperative preschool model affords me the opportunity to play a major role in assisting my child in the development of skills and transition from home to school. Of utmost importance to me is my daughter loves going to our cooperative preschool. That is exactly the precedent an early educational institution should set thereby fostering a child’s love for lifetime learning.

Without the aforementioned change to the proposed regulation, costs will undeniably rise causing the termination of the cooperative model. Some families may not be able to afford to send their child or children to preschool – every child should get the opportunity to learn and reach his/her potential. Please allow Dulin Cooperative Preschool to continue its pursuance of excellence. 

The proposed new training requirements for parents who volunteer at cooperative preschools are so burdensome that they will doom the traditional cooperative preschool model. It is not feasible to ask parents of young children 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, Dulin Cooperative, was established in 1967. 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 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 implement the above changes to the proposed regulations in order to preserve the viability of traditional cooperative preschools.

The proposed new training requirements for parents who volunteer at cooperative preschools are so burdensome that they may doom the cooperative preschool model. It is not feasible to ask parents of young children 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, Dulin Cooperative, was established in 1967. 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 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 implement the above changes to the proposed regulations in order to preserve the viability of traditional cooperative preschools.

Save Our Cooperative Preschools!

The proposed new training requirements for parents who volunteer at cooperative preschools are so burdensome that they will doom the traditional cooperative preschool model. It is not feasible to ask parents of young children 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, Dulin Cooperative, was established in 1967. 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 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 implement the above changes to the proposed regulations in order to preserve the viability of traditional cooperative preschools.

I am writing in to express my concerns about the new proposed training and orientaion requiremens for parents at cooperative preschools. Currently parents at cooperative preschools are given an exemption to the training hours and expected to compelte 4 hours - this draft regulations would increase those to 36(!) which would be impossible for parents of young children. Cooperative Preschools are often the most affordable preschool options in the community not to mention they have very high levels of parents engagement and involvement in child's earliest education. Please consider keeping the exemption for preschool parents so cooperative preschools don't have to change their models. 

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, Dulin Cooperative, was established in 1967. 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 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 implement the above changes to the proposed regulations in order to preserve the viability of traditional cooperative preschools. Thank you for your time. 

Save Our Cooperative Preschools!

The proposed new training requirements for parents who volunteer at cooperative preschools are so burdensome that they will doom the traditional cooperative preschool model. It is not feasible to ask parents of young children 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, and the only early education option we will consider in our family. Our school, Dulin Cooperative, was established in 1967. 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 would not only reduce the significance of parents' roles in the classroom, but would also raise tuition so significantly that many families (including mine) could be left without any affordable preschool options. 

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

As a parent of three young children these proposed regulations pose quite a threat to the care that my chidlren are currently recieving.  It appears that the "quality affordable childcare" that my children are already recieving will take a hit due to increased regulations that don't have the center and people caring for the children in their best interest. I have an infant who has just started care at 6 weeks old, a two year old and a 4 year old who have been enrolled at a licensed facility since they were 6 weeks old.  The first topic that particularly worries me is the group sizing.  Infant and toddler care in Northern Virginia is incredibly competitive.  Waitlists are extensive and the chances of  space being available for the timeframe needed for the average working family is slim.  Families looking to start their child in care between 6 and 12 weeks of age must get on wailists before they are even out of the first trimester of pregnancy and even then many centers cannot guarantee spots.  The center we attend cares for 16 infants at a time. If the proposed regulation of triple the ratio for the group size  was to pass that would threaten 4 infant spots in this center alone.  When "quality affordable childcare" is already so difficult to find you will be limiting families further by cutting spots out of centers who already have year long waitlists. What good is quality childcare if it is unattainable. Decreased capacity will also force centers to increase tuition so if you are lucky enough to obain a spot in a "quality" center the chances of being able to afford this care is now threatened even further.  I understand if going forward new centers applying for state licenses were required to abide by this type of regulation before business is established but to force a center to completely change practice and cut classroom size all you would be doing would be forcing families to turn to unlicensed unregulated childcare by eliminating spots and affordability at licensed childcare centers.
Another concern I have is the age restriction on staff members.  Personally I appreciate the younger staff members in the classrooms.  Many of the 16 and 17 year olds who tend to my children during the afternoon hours provide the high energy and enthusiasm needed during the afternoons which typically consists of more creative freeplay.  We cannot expect fulltime staff to work 12 hours daily and have the energy needed to tend to and supervise our children. I have had many babysitters who are juniors or seniors in highschool who have proved to be more responsible and reliable than a tired young adult who has already been working all day.
Lastly to require centers to report serious injury to the dept rep within two business days is excessive, Especially if serious injury is defined as anything that requires a visit to a medical professional.  Requring the center to contact agency representatives because my son stuck a pea up his nose is taking time away from the important things that the center and the agency should be tending to.  A yearly analasys of reports done upon inspection  is a more reasonable option or the definition of serious injury should be redefined, unnecesary reporting will only take valuable time away caring for the children.

I hope the reality of some of the indirect consequenses of these unnecesary changes for licensed centers who are currently operating prompts reconsideration of proposed regulation.

j

thank you,

Dear DSS,

The proposed new training requirements for parents who volunteer at cooperative preschools are so burdensome that they will doom the traditional cooperative preschool model. It is not feasible to ask parents of young children 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, Dulin Cooperative, was established in 1967. 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 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 implement the above changes to the proposed regulations in order to preserve the viability of traditional cooperative preschools.

Thank you,

Jaime Iglehart

The proposed new training requirements for parents who volunteer at cooperative preschools are so burdensome that they will doom the traditional cooperative preschool model. It is not feasible to ask parents of young children 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, Dulin Cooperative, was established in 1967. 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 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 implement the above changes to the proposed regulations in order to preserve the viability of traditional cooperative preschools.

Regards,
Kelly Glanzer

Save Our Cooperative Preschools!

As a parent of two children in a cooperative preschool I would like to continue to be in their classrooms and be a part of their education as fully as I have been these last few years.  As a former teacher I know how important parents are in the lives of their children and how wonderful the cooperative model is for this!  However, the proposed new training requirements for parents who volunteer at cooperative preschools are so burdensome that they will doom the traditional cooperative preschool model. It is not feasible to ask parents of young children 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, Dulin Cooperative, was established in 1967. 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 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. Thank you.

Sincerely, Kristin Wajert

I have 17 years experience working at a licensed childcare center and the last 4 years acting as director.  Many of these proposed regulations are going to significantly impact all aspects of how child day centers operate.  My main concerns are the ammendments to the following: 

1. Director qualifications.  Limiting the director qualifications is going to rule out an entire pool of directors when staffing is already so difficult.  You will be eliminating long-term directors who have been successfully running centers for 15 plus years by removing these exceptions and requiring further education rather than experience. 

2. Not allowing aides under the age of 18 to be left alone unsupervised with the children.  This is unreasonable. We cannot ask fulltime staff to be present 12 hours a day.  The younger aides allow fulltime staff to be relieved in the afternoons; we should not have to pay staff to supervise other staff members.

3. Training hours: Increasing the amount of training hours for all staff members will be another unnecessary cost.  Finding and maintaining long-term staff is already difficult due to the fingerprint background checks and the orientation training requirements, so to add additional hours either unpaid or paid will just be another burden. Finding free training for staff is also difficult enough without increasing the hours required.

4. Group sizing:  Group sizing will negatively affect all aspects of classroom and center operation.  Centers that have been operating at capacity with classrooms maintaining state ratio requirements will be forced to reconstruct classrooms or decrease enrollment to abide by this regulation.  It is unreasonable to reconstruct classrooms and create physical barriers to separate groups.  This will impact the curriculum followed and also create unnecessary stress on the children as it is limiting the space that they are used to utilizing for play and academic activity.  Eliminating the open classroom concept can also result in injury by adding one more thing for the children to bump into.  We would be required to decrease enrollment in classrooms and increase tuition rates to bear some of the financial burden of operating below capacity. We currently and consistently operate with a year long waitlist in our infant and toddler classes due to the demand of care and this would further limit availability of childcare in the area.   Parents have expressed concern as well about multiple aspects.  How are children separated or grouped? By ability or intelligence?  How are the caretakers decided? Why can’t my child be with the lead teacher?  Why are children separated from friends?  How do we explain to the children why they cannot cross the barrier?  If is understandable if going forward you required state license applicants to use the group sizing requirements but centers already in operation should receive an exception or operate according to some type of grandfather clause.

5.  CPR and First Aide Requirement: We understand wanting all staff to obtain CPR and First Aide training but extending the timeframe from 30-90 days would be more reasonable.  Within 30 days many employees have only received one paycheck and may not have the funds to take the training class. Within 90 days staff members are more established and have enough time and funds to obtain the training.

6. Written policy and procedure to ensure consistent staff taking care of each group:  Daycare has high turnover due to difficulty of the job and lower paying wages.  While our goal is to provide consistent care obtaining and maintaining consistent staff is difficult and we will do our best but cannot “ensure” a written plan regarding consistent staff in classrooms daily.

As a toddler lead teacher who has trialed the group sizing I object to this regulation.  I teach toddlers 18 months and up and follow the 1-5 state ratio requirement with a classroom of 20 children.  When we trialed the group sizing in my classroom it caused many issues. We used 21 inch bookshelves to seperate the groups and assigned 2 staff members to each group.  During this time we had to have two seperate circle times for each group which as you can imagine made it difficult for the students to concentrate as two groups are doing different things only seperated by a shelf.  The children could see and hear the other students and many didnt understand why they were not allowed to play on the other side with their friends.  Parents were highly upset wondering why their child was in the group without the lead teacher,  If children were seperated by ability or if teachers picked who they got.  They also voiced concerns with who was in each group and if they could be switched to be with their friends. This caused problems for management as parents were complaining and were not happy with the seperation of the classroom. I also had two children who required medical attention as a result of the group sizing.  Toddlers are not walking confidently and "toddle" around often falling and with the large bookshelves restricting the area that they are used to playing in I had one student hit their forehead and needed stitches and another child who hit their lip and had to be checked by their doctor.  The trial caused nothing but issues in my classroom and would not work constructively in an environment with multiple groups. My class would be forced to cut spots and take childcare availability away from families in need. 

I also object to requring staff under 18 to be supervised by other staff. To me this creates an atmosphere where one staff member will be sitting around who can be better used in another room or relieved for the day.  The younger employees are often very enthusiastic about playing with the children and pleasing the parents and more often than not are more reliable that someone who has worked 8+ hours with the children all day.  They come in after school and are refreshed and ready to work which relieves some of the fulltime employees who have been working since 630 am.

I am a parent and a staff member of a childcare center and disagree with instituting some of the proposed regulations.  

I am mother of three boys one of which is a newborn who just started infant care.  To obtain the infant care I was placed on multiple wait lists which were very extensive and luckily I was able to obtain care at the center I work at.  The group sizing requirements would further limit childcare by eliminating spots in classrooms that are already so difficult to access because many centers are unable to physically change the classrooms and the way the classrooms are run.  To limit the classroom that normally runs at full capacity to 12 spaces is not something that can easily be done.  This will obviously cause financial issues with the center as childcare is not exactly a big money producing industry.  If these regulations are being proposed to help provide better quality and more affordable care you are costing the centers and are inevitably going to force family owned and smaller centers not run by big corporations out of business. I know that the group sizing would not be something that we could implement in my classroom as it would require complete seperation of the teamlike atmosphere we use to assure all children receive the best care.   We work as a team and "grouping" off a section of the classroom is going to do nothing but cause problems with the parents make it harder to provide good care for the babies. 

Increasing the yearly training hours will create further hardship as well.  It is very difficult to obtain all of the required hours outside of working hours.  It is even more difficult to obtain FREE training hours and many of the classes that are eligible for training cost money.  To increase the amount of hours will be an additional financial burden that is not necessary.  We already are required to keep first aid and cpr and mat and daily health and the VADSS orientation training.  The additional hours are unrealistic and inconvenient.  In a field where pay is not high and the turnover is you are discouraging people from continuing to work in childcare. 

Requiring a center to provide written policy and procedures to maintain consistent staff in classrooms is something that would be very difficult to maintain.  I have worked in classrooms and turnover is eminent in childcare.  To say that we can "ensure" that consistent staff is in maintained in the classroom is not something that is always able to be done.  Maintaining ratio is more important to me than maintaining the same staff member in each room. 

CPR and First Aide requirements should give atleast 90 days instead of 30 days for compliance of new staff members.  To require a staff member to obtain CPR and First aid class on top of orientation training and begining a new job where they may only have had received one paycheck depending on how payroll falls is difficult and unreasonable.  CPR classes can be pricey and also availability of classes outside of work hours are difficult to find.  It would make more sense to allow a 90 day grace period. 

Requiring staff under 18 to be supervised does not make sense either.  Why would a staff member be paid to watch another staff member supervise the children.  This can leave room for  staff to sit around and be unproductive which can lead to staff socializing and not putting all of their focus on the children. 

Save Our Cooperative Preschools!

The proposed new training requirements for parents who volunteer at cooperative preschools are so burdensome that they will doom the traditional cooperative preschool model. It is not feasible to ask parents of young children 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, Dulin Cooperative, was established in 1967. 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 implement the above changes to the proposed regulations in order to preserve the viability of traditional cooperative preschools.

On a personal note, the cooperative preschool was a wonderful experience for me, my children and my family.  These proposed changes would end the cooperative preschool model as it stands in Virginia today, and it would be a shame if families were priced out of this supportive, play based, family-focused model of early childhood education going forward.  Please make the above changes so that Virginia families can continue to benefit from cooperative preschool education as it stands today.

Dear State Board of Social Services,

The proposed regulations to update the Standards for Licensed Child Day Care Centers introduces a number of issues related to the operation of small, independently owned child day care centers.  In particular, parent-run cooperative preschools will be detrimentally affected by new substantive requirements in the proposed regulations.  This fact runs counter to the Board's Estimated Economic Impact that states, “Many changes that the Board proposes for this regulation will not change any substantive requirement for regulated entities but, instead, are aimed at clarifying existing regulatory requirements.”

Cooperative preschools provide an affordable, effective preschool solution by integrating parent participation.  Cooperative preschools utilize parents in the classroom alongside teachers and parents typically operate, maintain, and organize the preschool on an ongoing basis.  The State Board of Social Services has historically recognized the beneficial role of parent-run cooperative preschools by providing specific exceptions in existing Licensed Child Day Care Centers regulations.  The proposed regulations, however, have changed the exception for cooperative preschools so that, as currently worded, the exceptions do not provide the historical regulatory relief needed for these small, independent preschools to continue to operate in an affordable, effective manner.

At issue are the sections related to the orientation and ongoing training of child care staff.  As background, the regulations currently consider volunteers staff for the purposes of these regulations if the volunteer is counted in the staff-to-children ratios, among other things.  For the purposes of parent-run cooperative preschools, parents are volunteers in practice, but are considered staff for the purposes of these regulations because they are counted in the staff-to-children ratios.  As a result, parent volunteers are required to abide by the orientation and ongoing training requirements as laid out in the regulations.

The State Board of Social Services provided adequate regulatory relief in the current regulations for parent volunteers in the areas of both orientation and ongoing training, stating, “Parents who participate in cooperative preschool centers shall complete four hours of orientation training per year.” (22 VAC 40-185-240 (C)(5))  The proposed regulations, however, have effectively rendered this exception meaningless.  Please find below three recommendations for incorporation into the proposed regulations to continue to allow the operation of parent-run cooperative preschools.

• First, the proposed regulations separate orientation requirements from ongoing training requirements.  However, the proposed regulations maintain the existing exception for parent-run cooperative preschools only in the ongoing training requirements section.  It is recommended that the proposed regulations provide an exception to the orientation requirements for parents participating in the operation of a cooperative preschool, just as the current regulations provide.

• Second, the proposed regulations word the ongoing training exception as follows, “In a cooperative preschool center that is organized, administered, and maintained by parents of children in care, parents who are not considered staff shall complete four hours of training each year.” (22 VAC 40-185-245 (c))  It should be noted that parents who are not considered staff are not participating in the cooperative preschool.  In other words, there is no reason to except these parents because the regulations do not apply to them in the first place.  The exception should apply to parents who are considered staff, as noted above, given that those parents are the ones participating in the cooperative preschools.  The current regulation recognizes this fact.  It is recommended that the proposed exception be reworded as follows, “In a cooperative preschool center that is organized, administered, and maintained by parents of children in care, parents who are considered staff shall complete four hours of training each year.”

• Finally, it is recommended that the compliance date for any finalized regulations, after taking into account the recommended changes noted above, be postponed until the 2019 academic year, at the earliest.  This will provide smaller preschools with limited resources the ability to budget and plan for the significant proposed changes.

Thank you for your consideration in preserving preschool choice and reducing unnecessary regulatory burden.

CPR/First Aid Requirement – pg.32 A. All staff who work directly with children shall have within 30 days of the date of employment CPR & First Aid (F/A) Certification.

VCCA Request: As stated in the CCDBG guidelines all staff shall be “trained” in CPR & F/A.  We support 100% of staff to be “trained” and for 50% of all staff to be certified. The NAEYC requirement is 50% certification.

This allows one teacher to perform CPR and/or FA and the other teacher to care for the children. We're also requesting a 90 day, rather than a 30 day, grace period for new staff requiring certification. With these requested changes, this is a significant improvement over the current requirement of one staff to be CPR/certified.

The Economic Impact Analysis from the Virginia Department of Planning and Budget estimates that "licensees will incur costs likely to equal hundreds of thousands of dollars, and may stretch to several million dollars, initially and then will be a like amount every two years. These costs will also be increased because the turnover rate for child care workers would indicate that approximately 30% of trained staff will likely leave their employment each year. Given that these proposed changes are not driven by identifed deficiencies that might affect the health or safety of children in care the costs of these changes likely far outweigh the convenience of having one standard for all licensees." The CCDBG requires requires only subsidy providers to be CPR/First Aid be trained, not all providers. VCCA supports 100% trained & 50% of staff certified. Thank you.

Serious Injury Notification – pg. 11 B.c.2. The center shall inform the department’s representative, as soon as practicable, but not to exceed two business days, of any serious injury to a child while under the center’s supervision.

VCCA Solution:  We are strongly opposed to real time reporting, and instead, support providing separate serious injury information, to the DSS inspector, upon each semi-annual DSS visit. There is enough stress at the time of injury, having to call a licensing specilist would add an additional layer of stress, to the situation. 

CCDBG requires this data to be collected, on subsidy providers only. If serious injury reporting is going to be required of all providers, we request being able to produce this data, at the time of a center visit, as opposed to calling The Department of Social Services Licensing Inspector. Inspectors should also receive training on "serious injury" vs. "normal childhood injury". All injuries aren't serious injuries. Thank you.

Group Size – pg. 22 Table 1 Maximum Group Size Requirements Triple the ratio per age group except for school age children

VCCA Request: Due to the increasing demand, and limited availability, of infant care and toddler care, especially in densely populated areas, we object to limiting the group size, if it reduces current capacity/accessibility for licensed infant/toddler care. Where this may be more easily planned for prior construction, it’s difficult for many centers to conform now. Could there be a grand father clause?

At the very least, we are requesting that a variance may easily be granted, for centers physically unable, to meet this requirement, in a way that works best, for children in care. What may seem like a good idea, doesn't always work in every situation & children are far safer in licensed, supervised, group care than in unlicensed, unsupervised care. Thank you.

Director Qualifications – pg. 13

Similar to what the Department of Social Service and the Department of Education has experienced lately, child care centers are finding it increasingly difficult to find qualified staff.  We support expanding the limited pool of applicants. VCCA requests that directors have experience, plus one of the following education qualifications, in order, to meet the director requirements:

BA/BS Degree in any field, child related courses preferred, not required

Associates Degree in any field, child related courses preferred, not required

12 College Credits in child related subject matter without condition

CDA without condition

This will allow us to meet the demands and industry, where it is, providing administrative leadership necessary to run a successful child day program. 

Teacher Age Restrictions – pg. 15

Aides under 18 years of age may be included in staff-to-child ratios, but shall not be left alone with children.

We need 16 & 17 year old aides to be able to work independently the first & last hour of the day. We need this age demographic to relieve many of the full-time teachers by 5pm daily. Sixteen and seventeen year olds are watching children unsupervised all the time in home care. We believe that licensed care is a much safer option for them to be alone in a classroom for 1 hour the first or last hour of the day. 

?The Virginia Department of Planning & Budget's Economic Analysis states that, "this new rule may cause licensees to incur additional costs to ensure that these teenagers are not left alone with children in care.  This proposed change will likely limit the usefulness of 16 & 17 year olds as child care workders and, therefore, will make it less likely that they will be hired by licensees. Given that it is unlikely that 16 & 17 year olds are any less safe or competent as childcare workers than 18 year olds with comparable training, the cost of this proposed requirement likely outweigh any benefit."

??We would like to see this staffing option remain available. Thank you.

Aide & Program Leader Definition – pg. 6

To keep up with the trend of professionalizing this workforce the following terms would be more current:

Change to Lead Teacher instead of Program Leader

Change to Assistant Teacher instead of Aide

Thank you.

The Center Shall develop and implement a written policy and procedure that describes how the center will “ensure” that each group of children receives care by consistent staff or team of staff members. Pg. 24 F.

While it's our goal to provide consistent staff in every classroom, the reality is that there are times that this may not be possible. We don't agree with providing the department, with a written policy that will “ensure” consistent care in every class.  While certainly the goal, it's burdensome, to ensure this and, be in compliance, with this standard at all time. We will try to ensure or attempt to provide consistent staff whenever possible, but don't believe we should be written up at times when this is not possible. We would like to see this proposed regulation striken. 

The Virginia Department of Planning and Budget Economic Impact Anaysis states that, "While this consistency of care undoubtedly benefites children in care, who are then able to formable bonds with their caregivers, staff turnover rates of about 30% for childcare workers would severely impede licensee's ability to meet this proposed new requirement." ?

Thank you.

We would like State Board to consider the following comments from the Department of Planning & Budget sent to the Joint Committee on Appropriations, and Senate Committee on Finance:

"In general, the changes proposed in this action that will increase costs for licensees will likely cause licensees to either raise their child care rates to cover increased costs or, for marginally profitable businesses, leave the licensed child care field altogether. If licensees choose to close their licensed child care businesses becasue their time and resources could be used more profitably elsewhere, the supply of licensed child care slots would shrink which would also tend to increase child care rates. Either of these effects will raise the costs of licensed day care for parents.  This may either leave those parents with fewer resources to meet other needs for themselves and their children, or may cause them to seek out cheaper, unlicensed care givers. Requiring licensees to meet more costly licensure requirements also leaves them with fewer resources to spend in alternate ways! that might benefit their employees or children in their care."

Thank you for hearing our concerns and working with the child care industry, to find the right balance, for those in the field working, in early care & education. We so appreciate your time and support. 

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.

A healthy child care environment requires constant cleaning and sanitizing of surfaces and toys--literally every few minutes. Requiring these cleaning products to be locked in between uses causes caregivers to sanitize less. In addition, the time it takes to lock and unlock the products reduces the time the caregiver spends on child supervision and child interactions. I support a more practical, and less intrusive solution: Keep the cleaning solutions inaccessible and out of reach of children--the same instructions that are written on the products. This remedy has been adopted in other states and it works well to ensure both a safe and healthy child care environment.

Hello,

I have been a parent at Dulin Cooperative Preschool here in Virginia for the past 6 years, and served as the president of our school for 3 of those years. It has been such a transformative experience for my entire family.  The cooperative model has educated not only my children, but also our entire family in the play-based, social skills-oriented curriculum we focus on at our preschool.  The cooperative model has made us better parents and community members. 

The proposed new training requirements for parents who volunteer at cooperative preschools are so burdensome that they will doom the traditional cooperative preschool model. It is not feasible to ask parents of young children 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, Dulin Cooperative, was established in 1967. 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 implement the above changes to the proposed regulations in order to preserve the viability of traditional cooperative preschools.

Sincerely,
Lauren Dewhurst, Falls Church, VA

The Child Care Development Block Grant states that staff shall be “trained” in CPR and First Aid—not “certified.” I support the CCDBG language. In addition, I believe 50% of staff shall be “certified.” I also suggest that there is a grace period for training staff of 90 days. This will allow the time it takes to provide quality training.

The proposed new training requirements for parents who volunteer at cooperative preschools are so burdensome that they will doom the traditional cooperative preschool model. It is not feasible to ask parents of young children 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, Dulin Cooperative, was established in 1967. 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 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 implement the above changes to the proposed regulations in order to preserve the viability of traditional cooperative preschools.

I have been involved in the cooperative preschool environment, both as a parent and teacher, for over 24 years. 

I read all previous comments pertaining to this subject and I choose to concur with the statements and requests made by my fellow cooperative teachers, in order to avoid being redundant. 

In addition, Cooperative Preschool of Loudoun (formerly Winnie the Pooh Preschool, est. 1969) is not affiliated with, nor supported by, a church, but has a history of renting from churches in order to survive and serve the community.  This has often meant changing communities when the churches circumstances require us to do so.  I have battled many personal obstacles, and worked along side many dedicated parents and colleagues to adjust to economical and environmental demands in order to keep our school afloat.  Loudoun County continues to grow, but our enrollment has suffered the past several years with the growing number of child care centers and preschools that may meet the demands of full time working parents with multiple children and a higher than average household income.  Many of our families have one parent working at home in order to care for children under 2, and can only afford the "luxury" of a lower cooperative preschool part time tuition.  We are sought out and valued by international families seeking a cooperative spirit and environment, one in which they are either accustomed to or want to become part of, as a support system for social transition into a big county.  Many rely on the chance to trade their involvement with running the school, for affordable tuition in a safe and supportive educational environment for their families.  Our devoted parent board and staff have great concerns.
 Devotion has its limits and I believe the demands of the forementioned proposed regulations may cause our schools 50th anniversary year to be its last.

Respectfully and sincerely,

Nancy Geier

We would like State Board to consider the following comments from the Department of Planning & Budget sent to the Joint Committee on Appropriations, and Senate Committee on Finance:

"In general, the changes proposed in this action that will increase costs for licensees will likely cause licensees to either raise their child care rates to cover increased costs or, for marginally profitable businesses, leave the licensed child care field altogether. If licensees choose to close their licensed child care businesses becasue their time and resources could be used more profitably elsewhere, the supply of licensed child care slots would shrink which would also tend to increase child care rates. Either of these effects will raise the costs of licensed day care for parents.  This may either leave those parents with fewer resources to meet other needs for themselves and their children, or may cause them to seek out cheaper, unlicensed care givers. Requiring licensees to meet more costly licensure requirements also leaves them with fewer resources to spend in alternate ways! that might benefit their employees or children in their care."

Thank you for hearing our concerns and working with the child care industry, to find the right balance, for those in the field working, in early care & education. We so appreciate your time and support.

The Center Shall develop and implement a written policy and procedure that describes how the center will “ensure” that each group of children receives care by consistent staff or team of staff members. Pg. 24 F.

While it's our goal to provide consistent staff in every classroom, the reality is that there are times that this may not be possible. We don't agree with providing the department, with a written policy that will “ensure” consistent care in every class.  While certainly the goal, it's burdensome, to ensure this and, be in compliance, with this standard at all time. We will try to ensure or attempt to provide consistent staff whenever possible, but don't believe we should be written up at times when this is not possible. We would like to see this proposed regulation striken. 

The Virginia Department of Planning and Budget Economic Impact Anaysis states that, "While this consistency of care undoubtedly benefites children in care, who are then able to formable bonds with their caregivers, staff turnover rates of about 30% for childcare workers would severely impede licensee's ability to meet this proposed new requirement." ?

Thank you.

.

Aide & Program Leader Definition – pg. 6

To keep up with the trend of professionalizing this workforce the following terms would be more current:

Change to Lead Teacher instead of Program Leader

Change to Assistant Teacher instead of Aide

Thank you.

Director Qualifications – pg. 13

Similar to what the Department of Social Service and the Department of Education has experienced lately, child care centers are finding it increasingly difficult to find qualified staff.  We support expanding the limited pool of applicants. VCCA requests that directors have experience, plus one of the following education qualifications, in order, to meet the director requirements:

BA/BS Degree in any field, child related courses preferred, not required

Associates Degree in any field, child related courses preferred, not required

12 College Credits in child related subject matter without condition

CDA without condition

This will allow us to meet the demands and industry, where it is, providing administrative leadership necessary to run a successful child day program. 

Group Size – pg. 22 Table 1 Maximum Group Size Requirements Triple the ratio per age group except for school age children

VCCA Request: Due to the increasing demand, and limited availability, of infant care and toddler care, especially in densely populated areas, we object to limiting the group size, if it reduces current capacity/accessibility for licensed infant/toddler care. Where this may be more easily planned for prior construction, it’s difficult for many centers to conform now. Could there be a grand father clause?

At the very least, we are requesting that a variance may easily be granted, for centers physically unable, to meet this requirement, in a way that works best, for children in care. What may seem like a good idea, doesn't always work in every situation & children are far safer in licensed, supervised, group care than in unlicensed, unsupervised care. Thank you.

Serious Injury Notification – pg. 11 B.c.2. The center shall inform the department’s representative, as soon as practicable, but not to exceed two business days, of any serious injury to a child while under the center’s supervision.

VCCA Solution:  We are strongly opposed to real time reporting, and instead, support providing separate serious injury information, to the DSS inspector, upon each semi-annual DSS visit. There is enough stress at the time of injury, having to call a licensing specilist would add an additional layer of stress, to the situation. 

CCDBG requires this data to be collected, on subsidy providers only. If serious injury reporting is going to be required of all providers, we request being able to produce this data, at the time of a center visit, as opposed to calling The Department of Social Services Licensing Inspector. Inspectors should also receive training on "serious injury" vs. "normal childhood injury". All injuries aren't serious injuries. Thank you.

CPR/First Aid Requirement – pg.32 A. All staff who work directly with children shall have within 30 days of the date of employment CPR & First Aid (F/A) Certification.

VCCA Request: As stated in the CCDBG guidelines all staff shall be “trained” in CPR & F/A.  We support 100% of staff to be “trained” and for 50% of all staff to be certified. The NAEYC requirement is 50% certification.

This allows one teacher to perform CPR and/or FA and the other teacher to care for the children. We're also requesting a 90 day, rather than a 30 day, grace period for new staff requiring certification. With these requested changes, this is a significant improvement over the current requirement of one staff to be CPR/certified.

The Economic Impact Analysis from the Virginia Department of Planning and Budget estimates that "licensees will incur costs likely to equal hundreds of thousands of dollars, and may stretch to several million dollars, initially and then will be a like amount every two years. These costs will also be increased because the turnover rate for child care workers would indicate that approximately 30% of trained staff will likely leave their employment each year. Given that these proposed changes are not driven by identifed deficiencies that might affect the health or safety of children in care the costs of these changes likely far outweigh the convenience of having one standard for all licensees." The CCDBG requires requires only subsidy providers to be CPR/First Aid be trained, not all providers. VCCA supports 100% trained & 50% of staff certified. Thank you.

A healthy child care environment requires constant cleaning and sanitizing of surfaces and toys--literally every few minutes. Requiring these cleaning products to be locked in between uses causes caregivers to sanitize less. In addition, the time it takes to lock and unlock the products reduces the time the caregiver spends on child supervision and child interactions. I support a more practical, and less intrusive solution: Keep the cleaning solutions inaccessible and out of reach of children--the same instructions that are written on the products. This remedy has been adopted in other states and it works well to ensure both a safe and healthy child care environment.