22VAC40-185-350   F.   The center shall develop and implement a written policy and procedure that describes how the center will ensure that each group of children receives care by consistent staff or team of staff members.

I believe it is the goal of any child care center to provide consistent staff in every classroom.  I can tell you from 30 years experience in operating child care centers that there are times that this may not be possible.  For state licensing to mandate this and ask child care centers to "ensure" this is quite strange.  I believe this is an over-reach and will be overburdensome for centers to stay in compliance.  Unlike the public school system, parents are in our buildings and classrooms everyday.  If parents see a lack of consistency in staffing, they have the freedom to seek other child care.  (It's called the free market)  Centers always stive for consistent care but to mandate this is again, very strange.  Are we to "ensure" staff never take off work?  Are we to "ensure" staff never get sick or have to miss work because their own child is sick?  Are we to "ensure" staff, once hired, never seek other employment opportunities?  How would "consistent" be measured?  Would a center still be in compliance with this standard if, for example, a classroom utilized one subsitute staff in a 15 day period?   What if it was within a 10 day period?  A 5 day period?   I'm having a difficult time understanding this proposal!