After reviewing the proposed changes, I am exceptionally disheartened by the recommended changes. As the director of a childcare organization that serves over 700 children annually, these changes overall will add a significant amount of administrative and financial burden. For every item that reduces (minimally) the administrative burden, there is another that increases it 10-fold.

The savings on activated charcoal are completely undermined by the significant addition of cost and training for epinephrine. I am at a loss how requiring childcare providers to have epinephrine on hand will have any sort of a positive effect on either the supply shortage, or how it will help the children. Parents are required to provide epinephrine to be on premises for their child if needed. It does not appear that this requirement is being removed. If we are now requiring an emergency health plan, then there should be no instances where suddenly and unexpectedly a child has an allergic reaction requiring epinephrine that has not already been provided by the parents/guardians. There has to be another way to look at this problem. It was clear from the comments on the epinephrine town hall that this is something childcare providers overwhelmingly disagree with. Pushing this forward is directly hurting childcare providers. 

The reduction in unnecessary information requirements (parent employment, name/number of child's physician, addresses of emergency contacts, etc.) is a great step in the right direction as this information is utterly useless to the childcare providers. The proposed changes to physical examinations, TB screenings for staff, and training and qualifications for staff are a welcome and reasonable change. However, the requirement for a documented daily health observation adds a significantly larger administrative burden than the paperwork requirements remove. 

While I appreciate that the state is trying to better support children with special needs, the number of children that our program serves would make the new special needs provisions nearly impossible. This would require us to hire a significant number of staff and to implement numerous different programs which we can honestly not afford. At some of our locations this would need to be done for over half of our children. I am not sure how this is tenable and how we are expected to afford a professional to provide this support and these recommendations. There has to be another way to solve this issue. 

Overall, while there are several positives, the end result of these new regulations detrimentally affects childcare providers. This very much feels like an attempt to sway the voting base without any actual thought or care given to how this affects the providers. Additional burden on the childcare industry, which is already on life support, is a bad idea and will continue to cause childcares to close. Childcare providers need a break right now, not new, more restrictive and more administratively burdensome regulations sold to them under the guise of "supporting parents". Parents need their childcare providers to stay open, and they need their costs to stay down. Increasing administrative burden and overhead increases the cost of care and causes childcares to close, reducing available childcare for parents. This legislation would do the opposite of what is intended.