On behalf of Annandale 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.
Since 1947 Annandale Cooperative Preschool has been a place for parents to actively participate in their children’s 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. 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 Annandale 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 classroom teachers in our award winning, NAEYC accredited program.

If the orientation and ongoing training sections of the proposed standards are not changed, cooperative preschools like ours will be forced to hire additional staff, making the cost prohibitive for many of our families. Cooperative schools may have to close 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.

I am a full-time working parent and life-long Virginian that has chosen the cooperative preschool despite the impact on my job (i.e. needing to take already about a week of annual leave to comply with requirements). It is the most valuable thing I have ever done for my child and my many of my fellow co-oping parents woud agree. While I feel fortunate to have the annual leave to take off work, not all families are in such a position. By imposing new and more stringent requirements on co-oping parents, this proposed regulation is limiting the ability of lower-income working families to participate in this wonderful preschool model -- either because tuition costs will rise or because they will simply not be able to take the time off work to comply with the 20 hour requirement.