I am writing on behalf of Providence Nursery School in Fairfax, Virginia, a cooperative, non-profit preschool that has been in operation for 47 years.  The cooperative preschool model, in which parents regularly volunteer alongside staff in their children’s classroom, is based on the principle that active parental involvement yields tremendous benefits for the individual child, the family as a whole, and each preschool’s community.  Over sixty parents at our small preschool undergo the current background check and training requirements to serve in their children’s classroom.  And in many of our families, both parents dedicate time each year to working in the classroom.  As a school, Providence Nursery School does everything it can to encourage parental involvement.

The Proposed Amended Standards threaten the cooperative preschool model by imposing on unpaid parent volunteers who are either counted in the staff-to-children ratio or who may work without sight and sound supervision of a staff member training requirements that would equal or exceed the total number of hours per year that the parent serves in the classroom.  As an example, the average parent volunteer at Providence spends 18-24 hours “co-oping” in their child’s classroom per school year.  We understand that many cooperative preschools have comparable expectations for parent volunteers.  Under proposed regulations 22VAC40-185-240 and 22VAC40-185-245, parent volunteers who meet the definition of staff would be required to complete 16 hours of orientation and 20 hours per year of ongoing training—the same amount as paid staff who work in the classroom each day.  This dramatic increase in training requirements for parents who serve in the classroom no more than once every 4-6 weeks will impose significant burdens on parents who want to participate in their child’s education.  The burdens will be particularly significant for families in which both parents wish to be actively involved in their child’s classroom experience.  In those families, both parents would need to complete the staff-level hours requirements, taking them away from their family and work responsibilities for more time than they will end up working in the classroom each year. 

To preserve the cooperative preschool model, and to encourage rather than discourage parental involvement in the classroom, the training requirements for parent volunteers in cooperative preschools should be kept at the current level, regardless of whether the parent volunteer is counted as “staff” as defined in the regulations.

In addition to this change, the orientation requirements in 22VAC40-185-240 should be clarified.  Subsection (A) requires “a minimum of 16 hours of orientation training.”  Subsection (B) provides that all staff shall complete the DSS-sponsored orientation course “within 90 calendar days of employment.”  And subsection (D) imposes an additional, facility-specific orientation requirement “within seven days of the date of employment.”  Currently, the DSS-sponsored orientation course is 10 hours in length, meaning that new staff need an additional 6 hours of orientation training to fulfill the requirement in subsection (A).  Does that mean that each facility’s specific orientation must be 6 hours in length, and that those 6 hours must be completed with seven days of employment?  For part-time preschools that operate for limited hours each week, adding 6 hours of orientation within the first week of a new staff member’s service will burden both current staff (who must provide the training) and new staff.  Please consider lengthening the period in which new staff may complete their facility-specific training to match the 90-calendar-day window allotted for completing the DSS-sponsored course.