To the Virginia Department of Education and Members of the Board of Education,

I am writing as an early childhood provider to share serious concerns about the new requirement that centers pay for staff background checks and to urge the Department to reconsider this regulation.

I am the Director of UCP Preschool in Reston, Virginia. We serve 48 children ages two through five and employ 25 staff members, including substitute teachers. While our program has relatively low turnover, the addition of mandatory background check fees places our school in a precarious financial position. Like many small programs, we are still working to recover from significant COVID-related losses and the expiration of relief funding that helped sustain us during that period.

For more than twenty years in this field, required background checks have not carried a direct fee for providers. That long-standing practice acknowledged an important reality: the cost of recruiting, onboarding, and qualifying early childhood educators is already substantial. Background checks—especially those involving out-of-state records—can be expensive, and centers frequently absorb these costs because many applicants simply cannot afford them upfront.

This change comes at a time when the early childhood workforce is already under extraordinary strain. Staffing shortages, burnout, and retention challenges are at an industry high. Introducing a sudden and significant new expense, particularly a jump from no cost to $70 per check, creates an outsized burden that many small, nonprofit, and subsidized programs are not equipped to absorb.

If a fee had been unavoidable, a lower amount, a gradual phase-in, or exemptions for nonprofit and subsidized providers would have allowed programs time to plan responsibly. Instead, the abrupt implementation of this requirement threatens the financial stability of centers that are already operating on narrow margins.

Early childhood programs play a critical role in their communities, and policies should reflect the fragile ecosystem in which they operate. I respectfully urge the Department and the Board to repeal this requirement or revise it in a way that acknowledges the realities facing providers across the Commonwealth.

Thank you for your time and for considering the impact of this regulation on early childhood programs and the families they serve.

Sincerely,
Ginger O’Rourke
Director
UCP Preschool
Reston, Virginia