To: Virginia Department of Education

From: Nikki Semenza, KinderCare

Date: August 25, 2026

On behalf of KinderCare Learning Companies (KinderCare), I am writing to request revisions to the Virginia Department of Education (VDOE)’s proposed 2026–2027 Virginia Quality Birth to Five (VQB5) Guidelines. KinderCare proudly serves over 10,000 children and employ over 2,000 early childhood educators at over 100 high quality early learning centers across the Commonwealth. We support Virginia’s goals of giving families clear information, strengthening teacher-child interactions, and directing meaningful improvement support to early childhood providers.

We respectfully request revisions to ensure that the final guidelines measure quality fairly, recognize incremental progress, accommodate responsible curriculum transitions, and protect families’ access to publicly funded care.

1. Replace all-or-nothing curriculum scoring with proportional credit

(Addressing Proposed Guidelines Document 8665: Section 4.2 "Curriculum Measure Requirements and Verification"; Current Guidelines Document 7061 v4: Section 4)

• The proposed guidelines award 100 curriculum points only when every participating classroom uses a VDOE-approved curriculum by May 31; otherwise, the site receives no curriculum points. Thus, Centers would drop to 0 points if a single room falls short. The previous standard provided partial credit and recognized incremental implementation.
• We ask VDOE to award points based on the share of eligible classrooms using an approved curriculum or, at minimum, establish meaningful partial-credit tiers.
• The final guidance should also include defined transition exceptions for newly opened classrooms, mid-year expansion, staffing disruptions, delayed procurement, age groups for which an appropriate approved curriculum is not reasonably available, and curriculum review delays outside a provider’s control.

2. Ensure curriculum status alone cannot push a site below “Meets Expectations”

(Addressing Proposed Guidelines Document 8665: Section 4.1 "CLASS Score Point Conversions," Section 4.3 "Quality Level Cut Points," and Section 5 "Curriculum Review & Provisional Approval"; Current Guidelines Document 7061 v4: Section 4)

Under the proposal, a site achieving an exemplary 4.50 CLASS average would receive 550 points with full curriculum credit ("Meets Expectations") but drops to 450 points ("Approaching Expectations") without it. The observed, real-time teacher-child interaction quality remains identical, yet the site’s public quality designation and mandatory improvement obligations would fundamentally change. Importantly, this could mislead parents by assigning a lower public quality label to a program with proven, strong classroom interactions.

• We ask VDOE to report CLASS Interaction Quality and Curriculum Implementation as distinct indicators on the public VQB5 Quality Profile portal rather than blending them into a single score that distorts observed quality.
• Blending scores makes it difficult to determine why a site received a lower rating. Separating the indicators allows VDOE and providers to direct the right support where it is needed—providing coaching for interaction quality when CLASS scores are low, or administrative/procurement assistance when curriculum rollout is in progress.
• This protection is particularly important when a provider introduces a new curriculum. VDOE should publish a clear submission and review timeline, allow provisional recognition while a complete application is under review, and provide a reasonable grace period after approval for phased classroom implementation. Providers should not be penalized for agency review time or orderly implementation intended to preserve quality.

3. Separate improvement support from minimal-quality enforcement and protect family access

(Addressing Proposed Guidelines Document 8665: Section 6 "Quality Improvement Commitments and Minimal Quality Standards," Section 6.2 "Public Funding Consequences and Appeals"; Virginia Code § 22.1-289.05)

• KinderCare supports targeted assistance for programs that would benefit from improvement. However, an “Approaching Expectations” rating should not by itself constitute failure to meet Virginia’s statutory minimal quality standard or justify loss of public funding. Equating a curriculum transition delay with a failure to meet statutory minimal quality standards could threaten to disqualify high-quality providers from receiving public funds and disrupts care for low-income working families.
• Before any funding consequence, we request VDOE to define what constitutes persistent failure and require meaningful support, written notice, a corrective-action period, hardship review, administrative review, and appeal.

4. Recognize effective provider-led coaching and improvement systems

(Addressing Proposed Guidelines Document 8665: Section 6.1 "Approved Technical Assistance Protocols" and Section 6.1.2 "Alternative Quality Improvement Plans")

• VDOE-approved alternative plans should be permitted to incorporate qualified enterprise coaching, accreditation, curriculum training, quality assurance, and professional development when those supports address the identified CLASS dimensions and include measurable goals.
• The final guidance should avoid duplicative meetings and paperwork, permit flexible delivery formats, and ensure providers are not penalized when state or regional coaching capacity is unavailable.
• Accountability should focus on evidence of implementation and improvement rather than the source of an otherwise equivalent support.

5. Establish safeguards and exception pathways for external observation requirements

(Addressing Proposed Guidelines Document 8665: Section 3 "Local & External Observation Verification" and Section 4.1 "CLASS Observation Requirements and Ratings Consequences")

KinderCare supports the use of external observations as an important component of measuring program quality. However, we are concerned with the proposed requirement that a site automatically receive a “Needs Support” rating if at least one external observation is not completed by the end of the program year. The completion of an external observation is not always within a provider's control.

A “Needs Support” designation should be reserved for situations in which a provider refuses participation or repeatedly fails to engage in reasonable scheduling efforts. Ratings should reflect program quality and educator interactions, not administrative barriers or contractor availability. Without these protections, providers may receive ratings that do not accurately represent the quality of care and education being delivered to children and families.

• We recommend that VDOE include safeguards when an observation cannot be completed due to factors such as observer capacity limitations, scheduling constraints, approved program closures, emergencies, or other documented circumstances outside of a provider's control. In these situations, providers that have demonstrated reasonable efforts to participate in the observation process should not receive an automatic adverse rating.
• We recommend that the VDOE include a documented exception process and alternative review pathway when an external observation cannot be completed despite provider cooperation

Conclusion

KinderCare supports a VQB5 system that gives families useful information and helps all providers improve. To achieve that goal, the final guidelines should recognize partial curriculum implementation, prevent curriculum status alone from driving a lower public rating, validate the new rating thresholds, distinguish improvement support from funding enforcement, and recognize effective provider-led improvement systems.

We respectfully ask VDOE to revise the proposed guidelines accordingly and to provide clear transition protections for newly approved curricula, including predictable review timelines and a reasonable implementation period. These changes would preserve accountability while producing ratings that more accurately reflect children’s experiences and protecting families’ access to care.

KinderCare appreciates the opportunity to provide feedback concerning revisions proposed to the 2026–2027 VQB5 Guidelines. We look forward to continuing the partnership to provide affordable, high-quality child care for families across the Commonwealth.

Sincerely,

Nikki Semenza, MSW

Sr. Government Relations Associate-East

(856) 266-0438

Nikki.Semenza@KinderCare.com