We agree that the licensing guidelines could be organized more clearly and concisely. 

22VAC40-185-80  Attendance records; reports

A. The center shall maintain a written record of daily attendance in each classroom that documents the arrival and departure of each child in care as it occurs.

Ques: Can a center used a preprinted log that offers ability to check units of time; for example the form could have blocks marked 9:00am-9:15am, 9:15am-9:30am, etc. and a teacher could quickly check arrival/departure times as children’s arrival/departure occurs?

22VAC40-185-240. Staff Orientation

A. Staff shall complete a minimum of 16 hours of orientation training appropriate to the age of the children in care.

&

22VAC40-185-245 (below)

G. Staff who are employed prior to (insert effective date) shall complete the VDSS-sponsored orientation training as required by this section within one year of (insert)…This training may count towards requirements

Ques:  Do these both apply to all Child Day Centers (our preschool is a half-day program, only open 20 hours per week)?  If so it seems these hours apply to required continuing education/training hours, is that the case?  

That would mean current staff would receive 16 hours for this training?

Comments:  Currently our new staff receive required training their first day at the center covering all aspects of their responsibilities.  Most centers use the first few months with on-the-job training focused and offer continuing training opportunities for new staff, but 16 hours orientation seems excessive and will definitely affect our budget.  We already have staff who think that 16 hours per year of continuing education per year is more than enough and feel they are often just reviewing the same types of topics over and over.  We do not want to discourage those considering working at our center from choosing to join our developmental program as they are exploring working in a developmental preschool setting.  It is also a huge hit to our budget.  We would be looking at over $200 per new employee just for orientation and if we find that staff member is not a good fit, this expenditure must be repeated. 

D. 9. & 10.  Prevention of sudden infant death…safe sleep…prevention of shaken

Baby...or distraught children.

Ques:  Do centers with children ages 30 months to 5 years old need to include these trainings?

22VAC40-185-245  Ongoing Training

A.  Staff shall complete a minimum of 20 hours of training appropriate to the age of the children in care annually. 

Comments:  We are a part-time preschool program of 20 hours per week.  Has there ever been consideration for having training hours based on whether a program is half day or full day?  We want to value our staff’s time and pay for training of all staff for 16 hours plus the cost of the continuing education courses.  We are a smaller program and already absorbed the changes from 2005 standards to add more training hours starting on June 1, 2006 to 12 hours   Then June 1, 2007 to 14 hours and then since June 1, 2008 to 16 hours.  Our continuing education costs are becoming a significant portion of our budget and without even considering the proposed addition of CPR/First Aid costs should we have to train all staff (we train 10 staff each year at this time) we will have to consider cutting our staff significantly.  So proposed training actually lowers the quality of our program.  We figured an increase of $1200 alone just to pay staff to add 4 hours each in training.  That does not include the cost of trainings. 

Will all trainings including Daily Health Observation, CPR/First Aid, and MAT and eMAT trainings be considered in training hours moving forward?  This is not really clear and needs to be easily understood.  If staff need 16 hours and safety is paramount, why wouldn’t they receive at least part of the training time for each of these?

G. Any child for whom emergency medications (such as albuterol, glucagon, and epi-pen have been prescribed) shall always be in the care of a staff member or independent contractor who meets the requirements in subdivision 1 of this subsection.

Question/Comment: This is very vague.  “In the care of” – does this mean any staff member on-site, or must it be the person who directly supervises the child? 

22VAC40-185-500  Handwashing and toileting procedures

Question/Comments:  What is the rationale for a staff member washing their hands “before” helping a child using the toilet and before diaper change?

In researching this topic, the Center for Disease Control (CDC) recommends washing hands after using the toilet, after helping a child use the toilet and after diaper changes.  We have included the link to this information.  https://www.cdc.gov/handwashing/when-how-handwashing.html

22VAC40-185-530  First Aid training, CPR and rescue breathing

Any staff who work directly with children shall have, within 30 days of the date of employment, a current CPR/First Aid.  Staff who work directly with children who were employed prior to (insert date) must complete CPR/First Aid within 90 days. 

Ques:  Why require ALL staff to be trained in CPR/First Aid?  Currently you need to have a staff member on site who is available and is training.  Also, why have new employees receive this within 30 days of the date of employment when there are already staff available with this training?  Why require all staff to be trained? 

We would suggest there could be consideration of using a staff to children ratio or total number of children attending the program daily.  This means that rather than requiring all staff who work with children to be trained, a center would use a basic calculation.  For example, a center would calculate that if their center has 40 children attending their site daily, they should have one staff member trained for every 8 children attending.  This would allow a center to calculate what they need daily, i.e. with this ratio they would need 5 staff members trained in CPR/First Aid on site daily.  This means there would be many options for someone to help in the event of an emergency requiring CPR/First Aid.  This training is costly, this year were quoted $80 per person to receive this training.  That does not include paying the staff member for their time to attend the course.  So this cost is $115+ per staff attending and is good for two years.

4. Any child for whom emergency medications (such as albuterol, glucagon, epi-pen) have been prescribed shall always be in the care of a staff member or individual Contractor who meets the requirements in subdivision 1 of this subsection.

We are a small center and the cost to train all staff is becoming truly cost prohibitive.  We are already asking a lot of this part-time staff.  We feel that the 16 hours now required gives us a well-trained staff.  We currently spend $1,000 each year to train about 8 to 10 of our total 24-26 staff members in CPR/First Aid each year.  We added MAT training and some eMAT training for 6 to 8 employees.  This means we generally have 16+ staff who have a 2-year CPR/First Aid certification and 4 on staff at all times with MAT or eMAT. This also means we have many staff members available throughout our center close by in case of emergencies.  We like to be able to schedule trainings to make it easy for staff to fit them in with their work schedule.   While it’s nice to try to have new staff trained in these areas within 30 to 90 days, it is really overwhelming to new staff and what we’d like to focus on is our developmental program and their responsibilities to the children in our care.  It can also be an unnecessary expense for centers.  Not all trainees become long-term employees, and we can’t afford to invest so much of our budget into someone who we do not choose to keep as part of our program.

We figure a cost of up to $15 to $40 per hour per staff member for training compensation which includes their time and cost of trainings like DHO, CPR, eMAT, etc.  This doesn’t include the costs we will incur for the new fingerprinting requirement.  So each staff member adding 4 more hours could cost a center $60 to $160 per person each year.   Multiply that by a staff of 20 and we will double our training costs.  This forces us to cut staff positions and/or increase tuition.  We then become unaffordable to young families and certainly less competitive with other schools in our area that claim religious exempt status.  We currently spend well over $3,000 per year training staff.  We cannot add an additional 4 hours to our part-time program budget.  

Thank you for your consideration.