The JCC of Northern Virginia Early Childhood and School Age Services Programs wanted to comment on the following additions/changes to the VA licensing standards:

22VAC 40-185-220 Aides

The JCC is concerned that not allowing staff members who are over the age of 16 to be alone with children will impact the ability to hire High School staff members. Hiring younger staff provides for new energy in the afternoons as well as provides students with the opportunity to become exposed to early childhood settings to inspire careers later on.

22VAC 40-185-240 Staff Orientation

Will training staff that do not work with infants on SIDS and Shaken Baby be necessary? This time will use up time that that could be better spent training on areas that do pertain.

Daily Health Observations

Please clarify who will need Daily Health training and if this will need to be provided by a RN or similar professional.