K. The center shall develop written procedures for prevention of shaken baby syndrome or abusive head trauma, including coping with crying babies, safe sleeping practices, and sudden infant death syndrome awareness.

Comment: Will this be required for all centers, or only for centers serving infants?

[ 9. 8. ] Prevention of sudden infant death syndrome and use of safe sleep practices;

Comment: Will all staff need to be trained in this, or only staff at centers serving infants?

 E. Within 30 days of the first day of employment, staff must complete orientation training in first aid and cardiopulmonary resuscitation (CPR), as appropriate to the age of the children in care. ]

Comments: Will increased availability and cost reduction be available to centers for this training? As a one classroom center, we do not have an internal trainer and we have used many different avenues for completing this training. It is very difficult to find available seats and available courses, and to not be able to hire staff if no course is available within the 30 days when needed would potentially mean that our center could not be open. Additionally, we already struggle with finding enough substitute teachers, and to add this requirement (when not easily available) for a staff person who might work only once a month would potentially reduce those willing to be subs. We have had to not hold school on some days or times in the past because we didn’t have a sub.

C. When children are regularly in ongoing mixed age groups, the staff-to-children ratio and group size applicable to the youngest child in the group shall apply to the entire group.

AND

O. The ratio for balanced-mixed-age groupings of children shall be one staff member for every 14 children provided:

Comment: How can both C. and O. be the regulation at the same time? In a mixed age group with 3 year olds, the ratio would be 1:10, as required by C. .As required by O, however, the ratio would be 1:14. Although our normal ratio is lower than both, it would be beneficial to understand the regulation. Please clarify.

4. For children diagnosed with specific learning disabilities or speech or language impairments: one staff member to eight children.

• Comment: There has never been a year that I have NOT recommended one or more of the children in my school be evaluated for speech therapy. There also has never been a time when parents pursue this, that a child has been found to not need services. Does that mean that we should either ensure our ratio is 1:8 at the beginning of the school year for this eventuality, or that we should not recommend parents pursue services? Our ratio normally is 1:8, so it is not a barrier for our particular center. However, I worry that this regulation will lead to the under-diagnosis of children. According to the CDC, “Nearly 8% of children aged 3–17 years had a communication disorder during the past 12 months.” Statistically, it is highly improbable that any center *not* have a child who would fall under this category, should they be diagnosed properly. Will children miss referral if staff work in a center whose administration discourages their staff from communicating these concerns to parents due to the new regulations? Will children with speech impairments, who should be in a language-rich classroom, not be admitted to centers that they were previously welcome at, because they would change the ratio needed? I would like to see this new regulation be re-evaluated to address these concerns.