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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4/6/18  8:13 am
Commenter: Karin Hudson

Impact of New Regulations on Families and Cooperative Preschools
 

Parent cooperative preschools, which have existed for over 100 years, are being placed in jeopardy in Virginia by the Proposed Amended Standards. Current Standards for Licensed Child Day Centers recognize the critical role of parent volunteers in the parent cooperative preschool model by including for cooperative parents an exception requiring limited training annually. This exception recognizes the unique role that parents hold in a cooperative preschool, as well as the intrinsic value of an early childhood education model premised on parent involvement.

The Proposed Amended Standards as drafted, however, undermine rather than support the cooperative preschool model by requiring cooperative parents to either:

  1. Complete the 36 training hours (16 orientation, 20 ongoing) required of professional staff; or
  2. Remain in constant sight and sound supervision of a staff member.

These two alternatives fail to recognize that:

•Cooperative parents already undergo the same background checks as staff;


•Cooperative parents assist professional staff in the classroom 1-2 days/month, for a total of 3-6 hours/month. Thus, required training hours could exceed the number of hours in class for the entire year;


•Cooperative parents serve a unique position in the classroom, where they remain under the guidance and supervision of professional staff but may at times not be in sight and sound supervision of staff.

These changes are unduly burdensome both to the cooperative parents who seek meaningful engagement in their children’s educations and to the small cooperative preschools that rely on parent engagement to survive. As the current Board President of my own cooperative preschool, I have experienced first-hand the challenges confronted by families as they determine whether or not they can commit to a cooperative model. In addition to training already required by the state and hours spent in their child’s class, our preschool also requires families to serve on committees to maintain the smooth functioning of the school, to commit hours to the physical upkeep and safety of the school, and attendance at mandatory meetings throughout the school year. This is a model generally shared by most cooperative preschools. 

For many families, particularly two-parent working families, these requirements can be an impediment to enrolling. Parents must juggle work demands, limited personal time, travel (in our region), and caring for other children/family members, among other issues, when determining if they can enroll their child. Unfortunately, many families forego a cooperative experience or have to withdraw because the they simply cannot make the balance work for their lives. 

Cooperative preschools are often a more affordable option for families precisely because parents are assisting in the classroom. Moreover, I’ve seen mothers and fathers gain confidence in their parenting as a result of their time in the classroom and through the high-quality child development courses we offer or that parents seek out on their own to fulfill the current training requirement. This has translated into a contingent of parents who then take these skills and sense of community into the public school system and become active, effective members of their PTAs or even become teachers themselves.  

My fear is that these new proposed standards will dissuade even more families from joining our cooperative community and severely damage our ability to remain a viable education option. Now in our fifth year as a cooperative family, I cannot imagine having enrolled my children in any other type of preschool not only for the skills I have gained but also, more importantly, for the exceptional, nurturing learning experience my children have enjoyed and how it has set them up for success as they enter the public school system.

To preserve the parent cooperative preschool in Virginia, the Proposed Amended Standards should be revised to allow cooperative preschool parents to work in the classroom without sight and sound supervision of a staff member provided that the parent:

(1) Satisfactorily completes the same background checks required of professional staff; and
(2) Completes a total of 4 hours of orientation and ongoing training annually.

I respectfully urge you to implement the above changes to the proposed regulations in order to preserve the viability of traditional cooperative preschools.

 

 

CommentID: 64744