As a parent of a child, and volunteer, at Overlee Cooperative Preschool in Arlington, VA  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 a cooperative preschool the parents are required to actively participate in their children’s early education by working directly in our classrooms as teachers’ aides.  The parents of each child spend, on average, 50 hours a year in the classroom, or about 25 hours/year per parent, asuming two parents splitting their time equally.  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. 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.

If the orientation and ongoing training sections of the proposed standards are not changed, cooperative preschools like ours may be forced to shut down, as parents are unwilling to enroll their children in programs which put unreasonable burdens on them. Either outcome robs children of the high quality, affordable early education that cooperative preschools provide. 

Watching my child in the classroom setting, and seeing how she learns and inteacts with other students and the teacher, has been of a tremendous benefit for myself and my child.  This first hand knowledge helps us to reinforce behaviours at home, as we can talk about situations at school to provide a concrete point of discussion.  It has also been fun to see her and all her friends grow up over the years in a way that is not possible unless you are in the classroom on a regular basis.

Thank you for your consideration.

James Cogbill
Overlee Preschool parent
https://www.overleepreschool.org/