Virginia Regulatory Town Hall
Department of Social Services
State Board of Social Services
Standards for Licensed Family Day Systems [22 VAC 40 ‑ 121]
Action Licensed Family Day Systems Regulation Comprehensive Review
Comment Period Ended on 3/16/2011
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3/3/11  4:05 pm
Commenter: Lisa Farinholt-O'Brien

Burdensome Changes Could Impact Families/Children

Infant/Toddler Family Day Care is a private nonprofit organization that goes above and beyond the standard licensing regulations.  The best interest of children and Early Child Care Educators (ECCE's)/providers is at the core of the organizations values.  The organization was previously told they would have new licensing regulations and went above an beyond to implement the regulations only to be told that the regluations would not be changed.  Although not mandatory, the organization still went ahead and implemented most of the changes because it was in the best interest of the ECCE's and children in their care.

Now the state has decided they are going to require Infant/Toddler Family Day Care to change to the full new regulations.  This is a great burden on the organization financially and on the ECCE's since it is going to create confusion.  There are specific regulations that are particularly burdensome.

1- Proof of High School completion- Since most of our ECCE's are not from the United States this will be impossible for them.

2- Previous Experience- The seems unrealistic since most people interested in the child care field come to it to learn and may not have professional or volunteer experience but a love for children.  Our organization goes above an beyond by requiring over 20 hours of classroom training and 40 hours of on the job mentoring before the ECCE can even have a family referred to them for an interview.  This should be acceptable for experience.

3- Evidence of Finances- We serve low income indiviuals and help them to become financially secure.  This requirement seems to discriminate and may cause families that would otherwise enter our program not to.

4-CPR/First Aid Training will not count toward annual training hours.  Why?  If Medication training (MAT) does.

5- Heating System Checks- How does the state enforce this?

6- Recordkeeping- Our program/system already has recordkeeping in place and should be able to continue with this.

Please do not go back on what you previously told Infant/toddler Family Day Care and think about how the above changes could impact many families and the organization (especially finacially) if implemented.  Thank you for your consideration.


CommentID: 16162