Dear Members of the State Board of Social Services,                                                                                                                                                              

          On behalf of  Sleepy Hollow Preschool, a parent cooperative preschool, and other similarly situated parent cooperative preschools in Virginia, I respectfully bring to the Board's attention that parent cooperative preschools, which have existed for over 100 years, are placed in jeopardy in Virginia by certain sections of 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 4 hours of training annually, 22VAC40-185-240.  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, specifically 22VAC40-185-240 and 22VAC40-185-245, as drafted, however, undermine rather than support the cooperative preschool model by requiring cooperative parent volunteers 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 preschool parent volunteers:

       1) undergo the same background checks as staff; 

       2) assist professional staff in the classroom 3-6 hours/month (required training could exceed total volunteer hours for the school year); and

       3)  serve a unique position in the classroom as a volunteer under the guidance and supervision of professional staff but may at times not be in sight and sound supervision of staff.

The proposed 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.  

To preserve the parent cooperative preschool in Virginia, the Board is respectfully requested to please revise the Proposed Amended Standards to allow cooperative preschool parents to work in the classroom under the guidance and supervision of professional staff but without continuous sight and sound supervision of a staff member provided that the parent volunteer:

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

These changes will allow parent cooperative preschools, models of parent and family engagement in education, to continue their important work to the benefit of children and families in Virginia, while appropriately safeguarding the children in care.

Representatives from parent cooperative preschools in Virginia also would appreciate the opportunity to explain to the State Board of Social Services the effect the Proposed Amended Standards will have on parent cooperative preschools if enacted without revision and to fully explain the benefits of parent cooperatives at a public hearing.  We welcome any further opportunity to share further information with the Board.

Respectfully submitted,