I have 17 years experience working at a licensed childcare center and the last 4 years acting as director.  Many of these proposed regulations are going to significantly impact all aspects of how child day centers operate.  My main concerns are the ammendments to the following: 

1. Director qualifications.  Limiting the director qualifications is going to rule out an entire pool of directors when staffing is already so difficult.  You will be eliminating long-term directors who have been successfully running centers for 15 plus years by removing these exceptions and requiring further education rather than experience. 

2. Not allowing aides under the age of 18 to be left alone unsupervised with the children.  This is unreasonable. We cannot ask fulltime staff to be present 12 hours a day.  The younger aides allow fulltime staff to be relieved in the afternoons; we should not have to pay staff to supervise other staff members.

3. Training hours: Increasing the amount of training hours for all staff members will be another unnecessary cost.  Finding and maintaining long-term staff is already difficult due to the fingerprint background checks and the orientation training requirements, so to add additional hours either unpaid or paid will just be another burden. Finding free training for staff is also difficult enough without increasing the hours required.

4. Group sizing:  Group sizing will negatively affect all aspects of classroom and center operation.  Centers that have been operating at capacity with classrooms maintaining state ratio requirements will be forced to reconstruct classrooms or decrease enrollment to abide by this regulation.  It is unreasonable to reconstruct classrooms and create physical barriers to separate groups.  This will impact the curriculum followed and also create unnecessary stress on the children as it is limiting the space that they are used to utilizing for play and academic activity.  Eliminating the open classroom concept can also result in injury by adding one more thing for the children to bump into.  We would be required to decrease enrollment in classrooms and increase tuition rates to bear some of the financial burden of operating below capacity. We currently and consistently operate with a year long waitlist in our infant and toddler classes due to the demand of care and this would further limit availability of childcare in the area.   Parents have expressed concern as well about multiple aspects.  How are children separated or grouped? By ability or intelligence?  How are the caretakers decided? Why can’t my child be with the lead teacher?  Why are children separated from friends?  How do we explain to the children why they cannot cross the barrier?  If is understandable if going forward you required state license applicants to use the group sizing requirements but centers already in operation should receive an exception or operate according to some type of grandfather clause.

5.  CPR and First Aide Requirement: We understand wanting all staff to obtain CPR and First Aide training but extending the timeframe from 30-90 days would be more reasonable.  Within 30 days many employees have only received one paycheck and may not have the funds to take the training class. Within 90 days staff members are more established and have enough time and funds to obtain the training.

6. Written policy and procedure to ensure consistent staff taking care of each group:  Daycare has high turnover due to difficulty of the job and lower paying wages.  While our goal is to provide consistent care obtaining and maintaining consistent staff is difficult and we will do our best but cannot “ensure” a written plan regarding consistent staff in classrooms daily.