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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4/5/18  11:53 am
Commenter: Kaydee Myers

Save Cooperative Preschools!
 

I moved to Virginia last summer and had the privilege of joining a cooperative preschool right away.  I have been impressed by the parents and teachers in our school.  Their dedication to create quality, affordable childcare is amazing and could even serve as a model in other states struggling with the costs of early childcare and education.  However, most parents cannot complete 16 hours of orientation and 20 hours per year of ongoing training.  This requirement would drasitically reduce our membership, making it virtually impossible for working parents, or parents with any other commitments outside of their preschool-age children, to participate in their children's education in this manner.  

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, nor should they be held to the same requirements.  

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.  They learn continually as parents, and have chosen to participate in a preschool that makes them better parents and shows their children that they are invested in their education.

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 unable to enroll their children in programs which put these unreasonable burdens on them. Either outcome robs children of the high quality, affordable early education that cooperative preschools provide. 

CommentID: 64661