Thank You for the opportunity to review and comment on the Guidelines and Procedures for Licensure. Below is a list of comments from The Eastern Prince William Area Family Child Care Association. This Local Family Child Care Association has over 30 members and is actively involved in advocacy efforts and promoting professional training and quality regulated family child care. We are also actively involved in The Family Child Care Advocacy Coalition, working with other Local Family Child Care Association for advocacy and knowledge.

The Licensing Process

Page 8    Part 1V

VAC 40-80-130

Comment: Clarifications in this area would be helpful to providers

Page 9

22 VAC 40-80-150  Regarding Home Occupancy Permits

Comment: This is still a burden and hindrance in many areas of the state and for providers trying to become licensed providers. Our recommendation is that this not be required. We know that a large part of the state is lacking the ability for licensed family child care due to outdated zoning ordinances and/or no process regarding zoning for these providers to follow in order to be issued a Home Occupancy Permit. In some areas, as in Richmond, it is $1800.00 just to apply and submit an application. Though we support regulated family child care, it is critical that we have in place guidelines and practices that support a provider in ANY and ALL areas of the state wishing to operate and become licensed and not hinder it being an available option for child care for the working parents. We are concerned that this is not being address and that in order to support regulated family child care across the state DSS also needs to be aware of what the barriers are.

Page 11

22 VAC 40-8-170 “Notice to the applicant of issuance or denial of licenses”

Comment: The Eastern Prince William Area Family Child Care Association would like to suggest guidance to be included on how to rectify if denied. This clarification and guidance would then serve and offer providers guidance and support which may be needed.

Under Renewal Process

Page 13 Is the application still mailed out? Or only mailed out by some licensing offices and to some providers? As a local association we recommend that this is clarified and if it is only available via the website that is it stated. If the renewal application is mailed in some areas but not in others, this serves as an unjust way of doing it and unfair to providers as there needs to be consistency so all providers receive this information in the same manner.

Also the wording of "it shall be submitted in a timely manner" is used for when to submit the application and information. The Eastern Prince William Area Family Child Care Association would like to suggest clarification on what "timely manner" means. As it is currently worded, it is open to individual interpretation both on the side of the provider and also the side of the Licensing Specialist, which could create unnecessary conflict.

Page 19

Administrative Sanctions.

 Letter F

Currently this area states "Requires licensees to contact parents, guardians or other responsible persons in writing regarding health and safety violations.”

We are seeking clarification on if that included child abuse allegations or as to what it includes and what doesn't fall in this area. At what point is a provider to let parents know of child abuse allegations? And also at what point is something regarding this on the DSS Website under the provider’s file and name search? This is something that every provider should know and it should be clarified someplace.

Once again, The Eastern Prince William Area Family Child Care Association thanks you for the time to comment on this. We are made up of over 30 regulated providers serving the Eastern End of Prince William County to promote quality regulated family child care. Collectively also work with other organizations and local family child care associations for promote professionalism and as a Family Child Care Advocacy Coalition.

Mary Braxton, President- Eastern Prince William Area Family Child Care Association

Active Participant with The Family Child Care Advocacy Coalition

VAFCCA, Former President

VAFCCA, Former Board Member of 15 Years

1braxton@comcast.net

571-288-4466