I am writing to offer specific feedback on the proposed regulations regarding lapses in supervision. I strongly support the proposed requirement in the Parent Communication and Notification section, which mandates that parents be notified immediately if their child is left unattended or wanders away. Parents are the primary guardians of their children's safety and have an absolute right to know about any supervision lapse, regardless of duration. Transparency builds trust, and this requirement is a positive step for family engagement.

However, I strongly oppose the parallel requirement in the Attendance Records and Reporting section, which mandates reporting these same incidents to the superintendent within one business day. The current language is dangerously ambiguous. It fails to distinguish between a critical safety failure and a minor, momentary occurrence—such as a child hiding in a classroom loft for sixty seconds during a transition. Requiring reports for every minor instance will flood the department with paperwork, distracting from genuine safety threats, and increase the "policing" atmosphere that exacerbates teacher stress and turnover.

Furthermore, this regulation creates a perverse incentive for programs to expel children who exhibit age-typical behaviors like hiding or running when dysregulated, simply to protect the program’s license. I urge the Board to remove the new reporting requirement to the department or restrict it solely to instances where local authorities are contacted, while keeping the robust parental notification requirement intact.