The new standards say that children must be in sight and sound supervision, without separation by a physical barrier. This language is unclear on what is considered a physical barrier- is an infant in a playpen not considered properly supervised? What about a crib? Or a baby gate? This change in language is impractical and centers will have to spend money to change their physical environments or place more staff in the classrooms. Our center uses baby gates to create separation between spaces while still allowing teachers to fully supervise children. If I am on one side of a gate, I can fully supervise children on the other side and quickly assist when needed. When a gate breaks, children do not stay in the classroom and run down the hall, so if we cannot have gates there would be a far higher number of supervision lapses due to children leaving the classroom. 

The new standards say that each of those supervision lapses would need to be reported to the Department. This will create a huge administrative burden on teachers, who will need to fill out more paperwork, as well as on Department employees, who will need to review said paperwork. If a child runs into the hallway as we’re getting ready to leave the room and I follow them a few seconds later, do I have to report it as a lapse in supervision? Clarity as to what specifically is considered a lapse in supervision would be helpful. I fully support reporting these lapses in supervision to parents, and I feel reporting each incident to the department is unnecessary and will have unintended consequences. 

If the stress and the pressure to avoid any types of supervision lapse becomes serious children will be impacted. Children who run away or hide will be expelled from early childhood programs because programs fear that their license will be threatened if they make these reports. Children feel the stress of their adults and children who are already struggling will be most impacted. There are staggering statistics about the long term downstream effects of expulsion from early childhood programs and this regulation could further marginalize children whose response to stress is to flee.

Additionally, the standards state that children under 10 must remain in sight and sound supervision at all times, unless they are in the bathroom, in which case they can be out of sight supervision for a few minutes. I would like to see this exception extended to preschool-age children who are briefly in a safe space, such as a hallway, where they remain in sound supervision. In our school, children’s cubbies are in the hallway, and it feels unnecessarily restrictive that eight- and nine-year-olds (who regularly go without sight or sound supervision both at home and at public school) are not trusted to step into the hallway for a minute or two to retrieve something from their cubby. It means each time they want to retrieve something, a teacher must stop what they are doing, and stand in the hallway to wait for the child.

I encourage you to keep the old language regarding supervision.