I have some concerns about the new regulations, including the striking off of the current exemptions, including those for Sunday school and Summer Camp programs. While I believe that these should be run so that staff and programming are of high quality, the amount of record keeping required for each child may provide a barrier to participating in these programs. For example, new visitors to a church won’t be able to let their child participate with the other children in Sunday School and parents will need to provide excessive paperwork for their child to attend only a few hours of summer camp the entire summer. If these regulations really are to apply to any program now (without hourly/amount exemptions) offered for two or more children not in the home of the provider, then parents will end up having access to fewer caregiving opportunities, especially back-up care, as it will be too costly to operate.

While I appreciate the concerns for the children who are in non-parental care as well as the importance of looking after them, I also know the concerns of centers such as ours who must meet all of these requirements, and think that any new regulations must come with greater opportunities for centers to meet these requirements. For example, it can sometimes take months to receive back something so simple as a CPS background check. CPR and First Aid is important, yes, but waiting lists for these classes can be a real barrier, especially for programs like ours that have less than a handful of staff members and cannot afford to hire someone to come in just for our center. Under these new regulations, children without immunization records won’t be able to participate in programs—but how does the center have control over the doctor who “doesn’t have time” to give records to parents (for weeks or even months?) How can we meet the new demands without resources being available or with no greater control over external factors than we had before?

Additionally, the continual increase in annual training hours per staff member should not be done across the board. For small programs like ours, I must have substitute staff or we won’t have enough staff to operate if even one regular staff person calls out. Yet I have had a substitute, for example, who has worked less than 5 hours in as many months. The costs of CPS checks, fingerprinting, CPR & First Aid will total almost $200 for each—ok. But is it really necessary for me to pay another additional $180 (at minimum) for her wage to compensate for training time, and that is assuming I can find 20 hours of FREE training that actually fits with her schedule? The amount of substitutes willing to do this, in addition, to be called in for only a few hours, is very low, and increases the difficulty of finding and keeping subs. A program that operates 10 days out of the summer months can’t afford to pay for this training for its staff members, either. The reality is that these program costs end up being passed down to the parents, and that in turn provides barriers to access to the people who need it most. Substitutes or staff who work less than 4 hours a week or less on average should have a training requirement that is halved, at most, (or who will work a total of 30 days or less, as for a short-term summer program).

Childcare is at a crisis in our country. Parents do not have access to high-quality “affordable” child care. Yet in even so-called “unaffordable” child care, staff members are paid wages that allow them to qualify for FAMIS and Food Stamps. The poor wages discourage staff retention and application. Everyone is stuck in a bind and these regulations make the bind tighter, (as centers and therefore parents) are left to shoulder the burden of these extra responsibilities—from not being allowed to retain or hire that GED candidate, no matter how wonderful she is with kids, to being left scrambling for summer care as short term programs are forced to close or hike up their rates, to schools (such as private independent Montessori Schools) that also have a pre-k program seeing their administrative costs rise as the time they need to deal with another licensing body increases.  I do agree that the quality of programs offered for young children is essential, yet I do not believe all of these changes will produce the desired effects as programs cut corners on actual services to account for increased overhead.