FCPA appreciates the opportunity to review and provide feedback on the proposed updates to the VDOE licensing standards. We are supportive of the revisions, particularly the reorganization of the chapter and the inclusion of expanded staff development requirements. We believe these updates will strengthen program quality and help ensure staff are well prepared to provide high-quality services.

We would like to request clarification on the following items:

1. What impact, if any, will the proposed changes have on programs operating under a licensing exemption?
2. With regard to the new standard, 8VAC20-781-130, which introduces additional orientation requirements related to children’s health issues, child development, and classroom management: Will these trainings be developed and provided by the state, or will individual programs be responsible for creating and implementing the required training content?
3. Regarding the new standard, 8VAC20-781-450, which requires at least one lifeguard for every 25 children in the water who is actively supervising those children: Does this requirement apply to splash pads and water-play activities that include baby pools? Additionally, how is compliance with this ratio expected to be monitored or tracked in public pool settings where additional community members are concurrently using the facility?

We appreciate the thoughtful work that has gone into these proposed updates and welcome any clarification you can provide.