Dear Members of the State Board of Social Services,

The proposed changes to staff and ongoing training requirements for licensed child day centers are detrimental to Virginia’s cooperative preschools. I urge you to remove the language "who are not considered staff" from 22VAC40-185-245 paragraph C.  I also support explicit exemptions for parent participants at cooperative preschools to the orientation and ongoing training requirements imposed by 22VAC40-185-240 and 22VAC40-185-245.

Currently, parent participants at cooperative preschools are counted as staff for purposes of meeting the required staff-to-child ratio, but such parent participants need complete no more than four hours of training per year.  The proposed language keeps the minimum training requirement, but appears inadvertently to remove parent participants from the staff-to-child ratio calculation by explicitly describing them as "not considered staff".  Following this description, cooperative preschools will be forced to either a) significantly raise tuition to hire additional staff in order to maintain the ratio or b) unrealistically require parent participants to officially become staff and to complete all staff requirements.  Many parents will be unable to accommodate either option.  Either outcome, therefore, would deprive children of the high-quality, affordable early education that cooperative preschools provide, force many cooperative preschools to close, and possibly destroy the cooperative preschool education model in Virginia.

My family's school, Annandale Cooperative Preschool, was founded 70 years ago, just after World War II.  It is a place for parents to actively participate in their children's education by working directly in classrooms as teachers' aides.  Parents working in classrooms complete all of the background checks outlined in Background Checks for Child Welfare Agencies (22VAC40-191).  They work under the direct supervision of well-qualified classroom teachers in an award-winning, NAEYC-accredited program.  Like other cooperative preschools, if the proposed rule goes into effect unchanged, our school may be forced to close its doors or to radically change its approach.

My family’s personal experiences with cooperative education have been life changing. Coming from a fully professionally staffed child day center, to that of cooperative education has afforded my family the opportunity to grow through learning together. We as a family are also brought closer to other member families through shared experiences in the classrooms, while at the same time we gain new appreciation for the rigors and difficulties of teaching. In my opinion, successful early education cannot follow a purely consumer model; parent involvement is essential.  Cooperative preschools, like Annandale Cooperative Preschool, are a highly effective way of fostering engagement and developing partnerships among teachers and parents.

Cooperative preschools represent unique and rewarding opportunities for parents to participate in their children's early education at an affordable cost.  They encourage parent involvement in the first stages of early education, and the benefits last many years.  They follow a unique, valuable model that should not be jeopardized without cause.  I am certain that the author of the proposed changes had no intention of altering the gem of early education that is cooperative preschools in Virginia. Please do your due diligence and alter the language of the proposed rule so that these worthy educational programs are not put at risk.

Kind regards,

The Osten Family - Joslyn, Jonathon, Elijah (Annandale Cooperative Preschool alum), Peter (Annandale Cooperative Preschool student)