To the Virginia Department of Education and Board of Education,

 I serve as the Director of Finance and Operations at Hampton Roads International Montessori School. We are a nonprofit Montessori program dedicated to providing high-quality early childhood education to children from 16 months through 8^th grade in the Hampton Roads community.

I am writing today to express my strong support for the fast-track regulatory action to repeal the fee requirements for FBI background checks (8VAC20-830).

While our school fully recognizes and supports the necessity of rigorous background checks to ensure the safety and well-being of the children in our care, the recent implementation of a $70 fee per applicant creates a significant and unnecessary financial barrier.

As the Director of Finance and Operations, I see firsthand the real-world impact of these costs:

• Operational Burden: Transitioning from a free service to a $70-per-person expense introduces a recurring operational cost that was not previously budgeted. These funds are diverted away from classroom resources and student experiences.
• Workforce Challenges: The early childhood education field is currently facing a historic staffing shortage. Adding a $70 entry fee creates an immediate hurdle for onboarding new educators. The ECE workforce is primarily composed of women, many of whom are single mothers and the sole caregivers for their own children and aging family members. In a field where wages are already a challenge, a $70 fee is not just a line item—it is a significant portion of a week’s groceries or a utility bill for an entry-level educator if they are forced to absorb the cost of background checks to be hired. These individuals are also, often forced to come and go from the workforce based on family demands, and they must acquire new background checks at each center. In a sector where we are constantly working to raise wages and recruit talent, if these administrative costs are absorbed by the ECE it reduces our ability to offer competitive compensation and stabilize our workforce.
• Impact on Capacity: Our ability to serve families and expand access to childcare is directly tied to our ability to hire. When hiring becomes more expensive and administratively burdensome, it limits our capacity, ultimately impacting the families in our community who rely on us.

The removal of these fees is an essential step toward equity in the childcare landscape. Small programs and nonprofits like ours feel these costs most heavily. Many ECE centers across Virginia are founded and led by individuals with a deep heart for children and pedagogy, rather than a background in business or high-level finance.

In a sector where margins are notoriously razor-thin, even a "small" fee of $70 per applicant—when multiplied by the high turnover rates inherent in this field—can destabilize a program's budget.

By reverting to a system without these financial barriers, the state is making a meaningful impact on the sustainability of early childhood programs across the Commonwealth.

I fully support the use of the fast-track process for this repeal. This change reflects that the Department has listened to provider feedback and is committed to reducing the administrative and financial burdens that hinder our mission.

Background checks are essential for safety; however, financial barriers to hiring are not. Removing these costs will allow us to focus our resources where they matter most: the education and safety of our children.

Thank you for your time, your consideration of this feedback, and your continued efforts to support the early childhood workforce in Virginia.

Sincerely,

Lindsey Boyer

Director of Finance and Operations

Hampton Roads International Montessori School