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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3/6/18  1:55 pm
Commenter: Latonya Carter

Unreasonable and unnecessary proposed changes
 

I am a parent and a staff member of a childcare center and disagree with instituting some of the proposed regulations.  

I am mother of three boys one of which is a newborn who just started infant care.  To obtain the infant care I was placed on multiple wait lists which were very extensive and luckily I was able to obtain care at the center I work at.  The group sizing requirements would further limit childcare by eliminating spots in classrooms that are already so difficult to access because many centers are unable to physically change the classrooms and the way the classrooms are run.  To limit the classroom that normally runs at full capacity to 12 spaces is not something that can easily be done.  This will obviously cause financial issues with the center as childcare is not exactly a big money producing industry.  If these regulations are being proposed to help provide better quality and more affordable care you are costing the centers and are inevitably going to force family owned and smaller centers not run by big corporations out of business. I know that the group sizing would not be something that we could implement in my classroom as it would require complete seperation of the teamlike atmosphere we use to assure all children receive the best care.   We work as a team and "grouping" off a section of the classroom is going to do nothing but cause problems with the parents make it harder to provide good care for the babies. 

Increasing the yearly training hours will create further hardship as well.  It is very difficult to obtain all of the required hours outside of working hours.  It is even more difficult to obtain FREE training hours and many of the classes that are eligible for training cost money.  To increase the amount of hours will be an additional financial burden that is not necessary.  We already are required to keep first aid and cpr and mat and daily health and the VADSS orientation training.  The additional hours are unrealistic and inconvenient.  In a field where pay is not high and the turnover is you are discouraging people from continuing to work in childcare. 

Requiring a center to provide written policy and procedures to maintain consistent staff in classrooms is something that would be very difficult to maintain.  I have worked in classrooms and turnover is eminent in childcare.  To say that we can "ensure" that consistent staff is in maintained in the classroom is not something that is always able to be done.  Maintaining ratio is more important to me than maintaining the same staff member in each room. 

CPR and First Aide requirements should give atleast 90 days instead of 30 days for compliance of new staff members.  To require a staff member to obtain CPR and First aid class on top of orientation training and begining a new job where they may only have had received one paycheck depending on how payroll falls is difficult and unreasonable.  CPR classes can be pricey and also availability of classes outside of work hours are difficult to find.  It would make more sense to allow a 90 day grace period. 

Requiring staff under 18 to be supervised does not make sense either.  Why would a staff member be paid to watch another staff member supervise the children.  This can leave room for  staff to sit around and be unproductive which can lead to staff socializing and not putting all of their focus on the children. 

 

CommentID: 63500