Regulatory Requirements for Staff Training

1. Orientation Training - Varies based on program,regulations require approximately twenty items are covered, must be completed by all staff within seven days of starting work 8VAC20-781-130 B

2. Preservice Training - 10 hour training online only, completed by every early childhood educator within 90 days 8VAC20-781-140 A

3. Daily Health Observation Training - 2 hour training typically online only, updated every three years, one trained staff member on the premises is required to have the daily health training 8VAC20-781-160

4. Medication Administration Training - Typically 8-16 hours online and practice, updated every three years, a trained staff member must always be immediately accessible to children with emergency medications 8VAC20-781-170

5. 16 hours of Annual Training - varies based on program 8VAC20-781-140

6. ADDITIONAL requirement that 3 hours of the 16 hours annual training are the VDOE online health and safety training update 8VAC20-781-140

7. First Aid and CPR Training - 2-8 hours training typically online or lecture and practice required, updated every two years, a trained staff member in each group of children, 8VAC20-781-150

8. Driver Training - varies based on program required prior to transporting children 8VAC20-781-180

Are these requirements reflective of an actual health or safety concern?

Yes. Early childhood educators absolutely need training to keep children in their care healthy and safe.

What is the appropriate regulation to address the safety concern?

What training is needed is a complex question to answer however we do know what is effective training and what is ineffective. We absolutely need regulation here but what is required and how it is implemented has a significant impact on the cost, accessibility, and quality of the training.

1. Orientation training requirements are needed, without critical information about the children in their care and the safety procedures directly after hire teachers cannot keep children safe. Program developed training tend to be more relevant, more applicable, and more likely to contain practice, mentorship, and support which lead to high quality training. There is an opportunity for improvement here however. Currently orientation training is required within seven days and this is very difficult especially for part time and substitute teachers.

   • Our proposed language is simple and clear, providing flexibility and safety.
     The center shall provide orientation training to all staff who will work with children. The orientation training shall be completed by staff before working alone with a child. The orientation training shall include all the following topics if relevant to the staff member’s job responsibilities:

     1. Content of and expected compliance with these regulations

     2. All applicable program philosophies, policies, and procedures

     3. Recognizing child abuse and neglect and the legal requirements for reporting suspected child abuse and neglect as required by § 63.2-1509 of the Code of Virginia;

     4. Introduction and orientation to each child assigned to staff, including health issues and accommodations

   • If the department wanted to support uniformity and access they could create an online portion of number 1. Content of and expected compliance with these regulations.

2. Preservice orientation is not needed and is a waste of time. We all know that the further a training creation occurs from the user the worse the training is. Online training of this nature is ineffective and this training in particular is actively harmful. There is an effort to rework the training but that is not what is needed. If some sort of uniformity is needed it should focus on content of and expected compliance with these regulations and can meet the federal requirements without anything more. 

3. Daily Health Observation training is also not needed and a waste of time. Yes, educators need knowledge about health but that is largely provided by first aid and CPR training. I have not found any evidence that any other state has a requirement for this type of training, there is no evidence that two hours of online only training is providing any meaningful impact, and teachers are spending thousands of hours a year doing this with little or no benefit. This section should be stricken from the standards.

4. Medication Administration training is very much needed and unfortunately a very low quality training. Prior to administering medication some type of training is absolutely needed and this training does at least have a practice component but the regulations should be opened up so that high quality training of various kinds could be piloted and tried. There is basically one provider of this training and it misses an opportunity to teach in meaningful ways. We would like to see this regulation stay as written but additional vendors be found to improve the training quality. Additionally emergency medications are covered in First Aid and CPR allowing that training to be sufficient for emergency medications could make a significant difference in the burden of medication administration. Emergency medications are the most important and the most unlikely to be used. It is difficult for educators to hold that though CPR and First Aid training covers emergency medication it is not sufficient for educators.

5. 16 Hours of Annual Training is a useful requirement. It encourages ongoing learning and ensures that educators are not isolated and stagnant in their classrooms. Quality of training offered can vary significantly from program to program but there are many high quality free options available to educators and this standard prior to the edits below was very effective at supporting educators.

6. 3 Hour Health and Safety Update is a terrible addition. This is be justified as lessening the burden of the 16 hour requirement but it doesn’t the exact opposite for high quality programs. Many high quality programs have professional development days that provide all of their 16 required hours adding this requirement increases their burden and the highest quality training is that that is closest to the source. This training is likely to be poor quality and irrelevant to many educators. We would like to see this clause stricken from the regulations. It can be allowed for those who use the training and not required for those who do not. 

7. First Aid and CPR Training is typically very high quality, includes a practice component, and requires regular updates. We would like to see this requirement retained as written.

8. Driver Training is not relevant to our program but is conducted by the program and thus likely to be most relevant and effective. We don’t have specific experience but it seems reasonable that this content should be reviewed annually.

What are the possible unintended consequences of the training requirements?

There are so many requirements that there is significant overlap which could be good if it were reinforcing critical information but unfortunately much of the time the courses actually conflict rather that reinforce one another. Especially DHO, MAT, CPR/First Aid, and Preservice Orientation. Training overload leads to diminished effectiveness and we would be much more effective if we narrowed the requirements and created consistency across the trainings. Training requirements consume significant staff time and cognitive capacity. When that time is directed toward low-impact or redundant trainings, it necessarily displaces higher quality opportunities. Early childhood programs already face severe staffing shortages. The cumulative burden of can act as a barrier to entry and retention.

These training regulations have an inequitable impact on high-quality programs. Programs that already invest in robust onboarding, embedded coaching, professional development days, and practice-based learning are often penalized by rigid training mandates that require staff to complete additional, lower-quality, centralized online trainings. Requirements such as the proposed 3-hour VDOE online health and safety update, do not reduce the overall training burden, limit program flexibility, displace higher-quality, locally relevant professional learning. As a result, the strongest programs face the greatest compliance burden, while weaker programs may meet requirements without improving practice.

These regulations focus on inputs rather than outcomes. The VDOE office of child care quality has significant efforts to observe, give feedback, rate, and coach programs. This framework is working against those efforts.

Please consider:

• Rewriting the orientation training as describe above and to be completed before working alone with children in 8VAC20-781-130 B

• Removal of 8VAC20-781-140 A preservice training - if this is not possible due to federal requirements, updating the preservice training to be created in the commonweath (not by PA) and focused only on licensing standards that teachers are expected to know and comply with. 

• Removal of 8VAC20-781-160 Daily Health Observation Training

• And Removal of the new clause requiring the VDOE 3 hour health and safety training in 8VAC20-781-140