We appreciate the work that has been done to bring the Standards along.  The following suggestions remain.

781-30

G. Center shall implement policies for the possession and administration of undesignated or stock epinephrine.

Neither the DOE or Centers are not ready to implement the stock epi pen law.  We are child care providers not medical professionals.  Without the assistance and guidance of both the Departments of Education and of Health, it is unfair to simply add this section into the Standards now saying Centers go forth and implement policies to comply with the stock epi pen law (22.1-289-059).  Centers need DOE (and DOH) clarification, guidance and mechanisms in place for implementation (a standing health department order for approximately 3 weight based stock epi pens per Center, a payment mechanism addressing the cost of the epi pens and training, guidance regarding the logistics of things unique to Childcare i.e., whether the pens must go on field trips so we actually need a duplicate epi pens). 

This also contradicts other sections of the Standards -- 781-530 - the Center may possess and administer prescription medication "only to the child identified on the prescription label in accordance with the prescriber's instructions..."    and with all the appropriate paperwork.  We cannot do this with stock epi pens.

781-50

B. 8.    Previous child day care and schools attended by the child, as well as any child day care or school concurrently attended by the child.

We are trying to streamline the enrollment process and paperwork burden on families and staff (i.e., the removal of the address requirement for emergency contacts).  The addition of a requirement for parents to disclose “previous child care centers attended” as well as those "concurrently attended" seems like an unnecessary piece of information and potential privacy issue.  Centers may choose to ask, but the state should not require this information be disclosed.  If the parents skip this line on the enrollment application, Centers are left to track down the information or face a violation.  Again,  a waste of Leadership staff's time to what end?  This seems more like a "gotcha" for violations rather than an attempt to gather information actually needed to care for a given child.    

781-80

D. 1.    T.B. assessments.…shall have been completed within 90 calendar days prior to coming in contact with children at the center.

Allow TB tests to be valid for a previous 180 day (6 month) prior window.  Anything that can be done to streamline the hiring process and/or lessen the barriers ($$ of assessment) should be considered.  Item 2.A. states “…any staff member who develops symptoms compatible with Tuberculosis disease, regardless of the date of the last TB screening or assessment, shall immediately obtain and submit a new Tuberculosis screening.  (Therefore, a safeguard is already in place).  Allows for greater portability of teachers within the industry.  

781-130

B.8.     (ii) How the center will ensure that each group of children receives care by consistent staff or team of staff members.

Replace the word “ensure” with “will strive” or “will attempt”.  With teacher turnover and teacher callouts, we do our best to keep consistent staffing but flexibility is needed.

781-140

B.        The ongoing training shall not include the training required by 8VAC-781-130 B or C. (“C” is First Aid/CPR)

One of the most important certification training staff members receive is First Aid and CPR.

Its importance is devalued when staff does not receive credit hours for this training.  We contend that First Aid and CPR training should count towards staff annual training hour requirement.

781-270

B.        Child to staff Ratios

Consider update to four year old ratio, which currently is same as the preschool or 3 year old ratio.  Four year olds are one year from kindergarten where classroom size is public school setting is often 1:30.  Even in child care setting, ratio increases to 1:18 when a child turns 5.  Suggest a return to the 1:12 for four year olds.

781-400      Accident Reporting

B. 7.    Future action to prevent reoccurrence.

Add:  Future action to prevent reoccurrence, add "if applicable" because not every incident has a future action.  Children get bumped or fall even when well-supervised and properly instructed.  For example, when a toddler trips over his own feet while walking across the classroom and gets a bump.  We are left to write future actions like "remind toddler to be careful when learning to walk."  When a child is playing on the playground and falls down skinning his knee, we are again left to get creative with a "future action."  Completely agree with the report of the incident but the requirement of a future action in all cases fails to recognize the nature of childhood and wastes teacher and leadership staff's time.          

781-610

J.         Tables and high chair trays shall be cleaned and sanitized before and after each use for feeding.

Change to:  Tables and high chair trays shall be cleaned and sanitized before each use for feeding and cleaned after each use for feeding.   (Omitting the requirement to sanitize after use because you are going to sanitize AGAIN before the next use anyway.)