I respectfully submit additional comment regarding the repeal of 8VAC20-840, the Virginia Child Care Provider Scholarship Program. My concern is not only that the regulation is being eliminated, but that the state is eliminating a workforce development tool rather than modernizing it to align with today’s early childhood career pathways.

1. The former scholarship program was limited to higher education coursework and did not support modern workforce pathways.

Under 8VAC20-840, the only eligible training was:

• Department-approved undergraduate courses,

• Offered through Virginia colleges or universities,

• Typically accessed through community colleges,

• Administered by the Virginia Early Childhood Foundation (VECF), which served as the scholarship manager.

This framework excluded:

• Registered Apprenticeships approved by Virginia Works

• Pre-apprenticeships

• Industry-recognized credentials

• Competency-based credentials such as the U-LAUNCH: Virginia Childhood Development Credential (VCDC)

• Workforce-aligned, non-college training providers

• System-based workforce development models

As a result, the program did not meet the needs of today’s early childhood workforce or support the talent pipeline required by Licensed Family Day Systems and child care programs statewide.

2. Eliminating the scholarship program without replacing it widens the workforce shortage in early childhood care.

As a Licensed Family Day System, I provide training and support to child care providers across multiple regions of the state. Many prospective providers cannot access college coursework due to cost, transportation, or scheduling barriers. The repeal of 8VAC20-840 removes one of the few state-supported training resources without offering an alternative aligned with current workforce realities.

3. Virginia’s workforce strategy now prioritizes Registered Apprenticeships — which the eliminated regulation did not support.

Virginia Works, the Commonwealth’s workforce agency, formally recognizes:

• Registered Apprenticeships

• Pre-Apprenticeships

• WIOA Individual Training Accounts

• Workforce credential programs

• Earn-while-you-learn models

These pathways:

• Reduce turnover

• Improve wages

• Strengthen professional preparation

• Support skill development in real settings

• Align better with the needs of home-based child care providers

Yet the outgoing scholarship regulation did not allow any scholarship funds to support apprenticeship tuition, related technical instruction (RTI), or credentialing.

4. The solution is modernization, not elimination.

If 8VAC20-840 is outdated, I urge the Department to:

• Develop a new Child Care Workforce Training Scholarship Program aligned with Registered Apprenticeships

• Permit scholarships to be used for:
  • Related Technical Instruction (RTI)
  • U-LAUNCH: Virginia Childhood Development Credential and competency-based credentials
  • Pre-Apprenticeships
  • WIOA-approved training providers
  • Community-based training academies

• Partner with workforce entities, including:
  • Virginia Works
  • Local Workforce Development Boards
  • Family Day Systems
  • Training providers

Repealing the regulation without replacement eliminates a state responsibility and removes a career pipeline that could easily be adapted to support modern workforce needs.

5. I respectfully request retention or replacement of the regulatory framework to support the early childhood workforce.

Eliminating scholarships altogether will:

• Reduce access to training

• Deepen the workforce shortage

• Disproportionately affect small home-based programs

• Place additional burden on Family Day Systems

• Contradict Virginia’s stated goals for childcare quality and workforce development

A modern, apprenticeship-aligned scholarship structure is urgently needed.

Respectfully submitted,