The Office of Child Care maintains that the reauthorization of the Child Care and Development Fund (CCDF) by the Child Care and Development Block Grant Act (CCDBG) of 2014 would result in benefits for the 1.4 million children receiving child care subsidies.  It also asserts that children who are provided care alongside them would reap the benefits of this Act as well in the form of safer child care settings.  What that statement does not take into consideration is the significant costs versus benefit of implementing these changes in the field of child care. 

Furthermore, we point out that the Department of Social Services appears to have a vested interest in implementing the new licensing standards in order to relieve its licensing inspectors of their obligation to “wear two hats”.  Inspectors are currently called upon to separate any visit to a subsidy program into two parts – one to determine compliance with licensing standards and one to determine compliance with current subsidy requirements (SHSI).  The monitoring of licensing and regulatory requirements and the posting of those results on a public website are required by the CCDBG of 2014.  Implementing the proposed excessive standards across all programs, regardless of their receipt of subsidy funds, would in effect eliminate the need for the inspectors to perform what is basically two individual inspections. 

All of the proposed health and safety protections outlined in the CCDBG of 2014 are prodigious in theory.  However, the implementation of these changes come at high costs to the facilities.  That cost will eventually have to be passed along to the families we serve.  The cost may take the form of higher tuition, or result in a tighter budgets for centers, affecting competitive wage for quality employees or expendable income for facility improvements or curriculum costs.  The cost of quality childcare is already considered extreme and budgets are almost always tight.  Changes that add to the cost of offering quality care should be scrutinized for the benefit it will bring to programs, and not executed gratuitously. 

We understand the Department’s obligation to impose changes mandated by the CCDBG of 2014 on subsidy programs, but those changes should not be impressed upon all licensed facilities in the Commonwealth of Virginia.  Accordingly, we oppose the following proposed changes:

• 22VAC40-185-80.B.2 – Centers are already required to keep records of both serious and minor injuries on site.  These records can be reviewed at any time by the Department’s representative.  There is no additional benefit to mandating two reports. 
• 22VAC40-185-350. A – Changes to 22 VAC 40-185-310 (area size) in 2008 already reduced the ability to care to larger groups of children in any one area.  Group size is naturally dictated by area and ratio, and should remain a preference of the parent evaluating the facility. 
• 22VAC40-185-350. F – As child care professionals, we strive to maintain continuity of care.  As licensed facilities, we ensure consistent care by following licensing standards already in place - hiring and retaining staff members and assigning them to the groups with which they are qualified to work.  However, as will any other organization including public schools, there will be times that require substituting a qualified provider, who might not be familiar with each child in the group, for an absent caregiver. 
• 22VAC40-185-530 – Although we agree to an increase in the ratio of CPR/First Aid certified staff members, we do not agree that certifying 100% of staff members is necessary.  As noted in the Economic Impact Analysis by the Virginia Department of Planning and Budget, these changes are driven by the Department’s desire to align standards with the CCDBG of 2014, and not by identified deficiencies.  Facilities are already incurring substantial costs to offer additional orientation and training costs to staff members in the interest of increasing health and safety.