The current draft of 8VAC20-781-270 Supervision of children (F) reads: “For children under 10 years of age, the licensee shall ensure sight and sound supervision by staff who are always physically present without separation by a physical barrier, except that staff need only be able to hear a child who is using the restroom provided that: (1) There is a system to assure that individuals who are not staff members or persons allowed to pick up a child in care are not present in the restroom area while in use by children; (2) Staff check on a child who has not returned from the restroom after five minutes. Depending on the location and layout of the restroom, staff may need to provide intermittent sight supervision of the children in the restroom area during this five-minute period to assure the safety of children and to provide assistance to children as needed; and (3) Staff can hear or see the children (video equipment, intercom systems, or other technological devices shall not substitute for staff being able to directly see or hear children).”

My preschool and school aged children are competent to be out of sight or sound supervision for short periods. I trust my child's teachers to scaffold my children’s learning as they build confidence through short-term independent tasks such as using the restroom, putting personal items in their cubby, retrieving said items, and moving between rooms on a secured hallway.

Please change 8VAC20-781-270 F to allow children preschool aged and above reasonable freedom of movement at school. I suggest that Virginia adopt this language in place of the current draft of 8VAC20-781-270 F:

“For children under 5 years of age, the licensee shall ensure sight and sound supervision by staff who are always physically present without separation by a physical barrier, except that staff need only be able to hear and maintain verbal contact with a child who is out of sight using the restroom, retrieving personal items, or performing another similar short-term task, provided that: (1) There is a system to assure that the restroom or task area is secure, e.g., individuals who are not staff members or persons allowed to pick up a child in care are not present while it is in use by children; (2) Staff check on a child who has not returned from the restroom or task area after five minutes. Depending on the location and layout of the restroom or task area, staff may need to provide intermittent sight supervision of the child in the restroom or task area during this five-minute period to assure the safety of all children in their care and to provide assistance to them as needed; and (3) Staff can hear or see the children (video equipment, intercom systems, or other technological devices shall not substitute for staff being able to directly see or hear children).

For children 5 years of age or older, but under 10 years of age, the licensee shall ensure sight and sound supervision by staff who are always physically present without separation by a physical barrier, except that staff need only be able to hear and maintain verbal contact with a child who is out of sight using the restroom, retrieving personal items, or performing another similar short-term task, provided that: (1) There is a system to assure that the restroom or task area is secure, e.g., individuals who are not staff members or persons allowed to pick up a child in care are not present while it is in use by children; (2) Staff check on a child who has not returned from the restroom or task area after ten minutes; (3) Staff are nearby so that they can provide immediate intervention if needed; and (4) There is a system to ensure that staff know where the children are and what they are doing.”