Virginia Regulatory Town Hall
Agency
Department of Social Services
 
Board
State Board of Social Services
 
chapter
Standards for Licensed Child Day Centers [22 VAC 40 ‑ 185]
Action Amend Standards for Licensed Child Day Centers to Address Federal Health and Safety Requirements
Stage Proposed
Comment Period Ended on 4/6/2018
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3/5/18  10:48 pm
Commenter: Angela Todd

Concerns with proposed regulations
 

As a parent of three young children these proposed regulations pose quite a threat to the care that my chidlren are currently recieving.  It appears that the "quality affordable childcare" that my children are already recieving will take a hit due to increased regulations that don't have the center and people caring for the children in their best interest. I have an infant who has just started care at 6 weeks old, a two year old and a 4 year old who have been enrolled at a licensed facility since they were 6 weeks old.  The first topic that particularly worries me is the group sizing.  Infant and toddler care in Northern Virginia is incredibly competitive.  Waitlists are extensive and the chances of  space being available for the timeframe needed for the average working family is slim.  Families looking to start their child in care between 6 and 12 weeks of age must get on wailists before they are even out of the first trimester of pregnancy and even then many centers cannot guarantee spots.  The center we attend cares for 16 infants at a time. If the proposed regulation of triple the ratio for the group size  was to pass that would threaten 4 infant spots in this center alone.  When "quality affordable childcare" is already so difficult to find you will be limiting families further by cutting spots out of centers who already have year long waitlists. What good is quality childcare if it is unattainable. Decreased capacity will also force centers to increase tuition so if you are lucky enough to obain a spot in a "quality" center the chances of being able to afford this care is now threatened even further.  I understand if going forward new centers applying for state licenses were required to abide by this type of regulation before business is established but to force a center to completely change practice and cut classroom size all you would be doing would be forcing families to turn to unlicensed unregulated childcare by eliminating spots and affordability at licensed childcare centers.
Another concern I have is the age restriction on staff members.  Personally I appreciate the younger staff members in the classrooms.  Many of the 16 and 17 year olds who tend to my children during the afternoon hours provide the high energy and enthusiasm needed during the afternoons which typically consists of more creative freeplay.  We cannot expect fulltime staff to work 12 hours daily and have the energy needed to tend to and supervise our children. I have had many babysitters who are juniors or seniors in highschool who have proved to be more responsible and reliable than a tired young adult who has already been working all day.
Lastly to require centers to report serious injury to the dept rep within two business days is excessive, Especially if serious injury is defined as anything that requires a visit to a medical professional.  Requring the center to contact agency representatives because my son stuck a pea up his nose is taking time away from the important things that the center and the agency should be tending to.  A yearly analasys of reports done upon inspection  is a more reasonable option or the definition of serious injury should be redefined, unnecesary reporting will only take valuable time away caring for the children.

I hope the reality of some of the indirect consequenses of these unnecesary changes for licensed centers who are currently operating prompts reconsideration of proposed regulation.

CommentID: 63491