On behalf of Overlee Cooperative Preschool I am requesting changes to the Proposed Standards for Licensed Child Day Centers, specifically in regard to the requirements for staff orientation and ongoing training. 

As one of the oldest Cooperative preschools in Northern Virginia,  Overlee Preschool was founded in 1945 and has been a place for parents to actively participate in their children’s early education by working directly in our classrooms as teachers’ aides. The new requirements for staff orientation (22VAC40-185-240) and ongoing training (22VAC40-185-245) would impose an undue burden on our parents by expecting them to complete 16 hours of orientation and 20 hours per year of ongoing training. Our parents volunteer on average only 50 hours a year in the classroom. Parents who are volunteering their time are simply not going to be able to complete the same orientation and training requirements as our paid classroom teachers.  

We request that the total number of training hours (both orientation and ongoing, collectively) for cooperative preschool parents be limited to the current 4 hours. Please remove the language "who are not considered staff" from section 22VAC40-185-245C describing the required annual training for cooperative preschool parents. Please include an exception for cooperative preschool parents in the new orientation training section 22VAC40-185-240. 

Parents working in classrooms at Overlee Cooperative Preschool complete all of the background checks outlined in Background Checks for Child Welfare Agencies. They work under the direct supervision of well qualified and trained classroom teachers.

As an Early Childhood Educator for over 30 years with administration and teaching certificates, I understand and value continuing education for both teachers and parents. However, requiring cooperative parents (who are essentially being mentored by an experienced teacher while volunteering for 50 hours a year) to train for more than 4 hours a year puts an undue burden on families.

Many thanks for your understanding, and consideration for families~ Samantha Trice