On behalf of Overlee Cooperative Preschool I am requesting changes to the Proposed Standards for Licensed Child Day Centers, specifically in regard to the requirements for staff orientation and ongoing training. 

As one of the oldest Cooperative preschools in Northern Virginia,  Overlee Preschool was founded in 1945 and has been a place for parents to actively participate in their children’s early education by working directly in our classrooms as teachers’ aides. The new requirements for staff orientation (22VAC40-185-240) and ongoing training (22VAC40-185-245) would impose an undue burden on our parents by expecting them to complete 16 hours of orientation and 20 hours per year of ongoing training. Our parents volunteer on average only 50 hours a year in the classroom. Parents who are volunteering their time are simply not going to be able to complete the same orientation and training requirements as our paid classroom teachers.  

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. 

Parents working in classrooms at Overlee Cooperative Preschool complete all of the background checks outlined in Background Checks for Child Welfare Agencies. They work under the direct supervision of well qualified and trained classroom teachers.

If the orientation and ongoing training sections of the proposed standards are not changed, cooperative preschools like ours, may be forced to shut down, as parents are unwilling to enroll their children in programs which put unreasonable burdens on them. Either outcome robs children of the high quality, affordable early education that cooperative preschools provide. 

In a society where more and more households have two working parents, cooperatives have offered alternatives to be involved in these changing times.  A passage to amend these standards as-is would explicitly demonstrate that the state government is out-of-touch with everyday families and the struggles particularly for an organization focused on social services.   The commentary clearly shows that there is an oversight that needs to be corrected, and that there are people willing to petition their elective officials if their voices do not get heard through more practical forums such as this.

Ed Delacruz,

Overlee Preschool Parent