The proposed new training requirements for parents who volunteer at cooperative preschools are so burdensome that they will doom the traditional cooperative preschool model.   

The new language would require cooperative preschool parent volunteers to complete a 16 hour orientation and an annual 20 hours of training, as if they were staff.  Cooperative preschools would collapse should they try to impose these requirements because too many parents would be unable to commit to this many hours.  In order to comply with the new regulations, cooperative preschools would have to hire aides so parents are not counted as staff -- which would raise tuition unnecessarily and make the parents’ role in the classroom redundant. The cooperative preschool model would no longer exist. It would be a loss for many communities.  

Cooperative preschools have been a valued early education option in Virginia for decades.   Our school, Dulin Cooperative, was established in 1967.  Traditional cooperative schools like ours have a highly-qualified teacher in each classroom, with parents taking turns serving as an aide in the room, working under the direct supervision of the teacher.  Because they serve as the second adult in the room, parents are counted in staff-child ratios for some of our classes.  Parents, who undergo the same background checks as paid staff, typically volunteer between 3 to 6 hours per month.  This cooperative preschool model has many benefits including: 

• low tuition because the parents serve as unpaid classroom aides.  Cooperatives provide affordable part-time preschool.  Parents should have this option. 
• deep, meaningful parental involvement in children’s early education.  Cooperative preschool parents become more aware of their children’s social, emotional and developmental needs as they spend time in the school.   Cooperative preschools build community -- the school and families work together to prepare the children for kindergarten and beyond.  These families continue to be involved in their children’s education far beyond preschool.

RECOMMENDATION   The existing regulations provide adequate regulatory relief for parent volunteers, stating, “Parents who participate in cooperative preschool centers shall complete four hours of orientation training per year.” (22 VAC 40-185-240 (C)(5))   In order for parent-run cooperative preschools to survive, we make the following recommendations to the proposed new standards:

• We request that the total number of training hours (both orientation and ongoing, collectively) for cooperative preschool parents be limited to the current 4 hours. 
• Please remove the language "who are not considered staff" from section 22VAC40-185-245C describing the required annual training for cooperative preschool parents. 
• Please include an exception for cooperative preschool parents in the new orientation training section 22VAC40-185-240.