Virginia Regulatory Town Hall
Agency
Department of Social Services
 
Board
Child Day-Care Council
 
chapter
Standards for Licensed Child Day Centers [22 VAC 15 ‑ 30]
Action Revision from Periodic Review
Stage Proposed
Comment Period Ended on 1/2/2004
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35 comments

All comments for this forum
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11/4/03  12:00 am
Commenter: Amy  Brothers / Children's Academy, Inc.

I am pleased with the proposal.
 
I am over all very pleased with the proposed changes.  I feel that it is about time that the training hours were increased.  I also like specificly the upgrade of qualifications for the director.  The job that we do is very important yet until know do the standards start to show that.  I am pleased and the future is looking brighter for our children. 
CommentID: 41
 

11/5/03  12:00 am
Commenter: Heather HOffmann

I am happy with the proposal
 
It is about time that someone took a look at our childcare facilities and made some changes.  Our children are our future and we need to protect them.  I think it is wonderful that childcare providers will need more training time in order to care for children.  I also think the proposal to limit the number of children allowed in a facility is a positive step.  Overall, I am very pleased with the proposed changes.  It shows that we care about our children!
CommentID: 42
 

11/7/03  12:00 am
Commenter: michelle skidmore / Norfolk Christian Schools

Increase activity space sooner
 
While it is important to have a smaller student to teacher ratio, it is also important that these students are not crammed into a room together.  Increasing to 35 square feet per child is a great step, but I feel it shouldn't take 5 years to accomplish this goal.
CommentID: 43
 

11/12/03  12:00 am
Commenter: Karen Hayes

Quality at what cost?
 
The proposed regulations addresses some changes regarding larger class sizes and smaller ratios, but it does not address who will pay for these "quality" changes.    Me!  My children are in a wonderful licensed preschool and afterschool program that our family has grown to love.  However, if these regulations pass our family will not be able to afford the price tag.  I am all for strengthening health and safety regulations, but if my children will not be around to benefit what is the point?  Our old sitter says that she can still care for the kids, but I'd rather keep them where they are - happy.
CommentID: 44
 

11/13/03  12:00 am
Commenter: David Schilling / Tomorrow's World Child Care Centers

Very Displeased With Proposal
 

I am very displeased with the proposal to amend the Minimum Standards for Licensed Child

Day Centers.  The book, if read properly is a violation of rights to Day Care Providers in the

Commonwealth of Virginia.  If any ammendment is to be made, it should be to rewrite the entire standards as agreed by child care providers, not someone who knows nothing about child care or it's operations.

CommentID: 45
 

11/14/03  12:00 am
Commenter: Ronald Crouch / Moseley Architects

30% Tuition Increase Says My Provider
 

It may not be known that these changes have originated from the Governor's Office and not from the Child from Day Care Council who should really be the one to determine the need for such drastic changes. I am a recent widower and have 3 young sons. My oldest in 2nd Grade. I pay approximately $17,000 per year in day care costs. This is almost unaffordable as it is but I am very happy with the facility and the love and attention they receive. I have never belived there was an overcrowding issue. My day care has advised there will be a 30% increase in tuition to cover the lost revenue from the reduction in the number of kids and increase in staff requirements that the Governor wants. If the average people do not stand up and fight against these forms of government control on peoples lives then I will be forced financially to leave this system and these democratic "quality improvements" that they feel are so necessary. Day Care will only be reserved for the elite rich who can afford it. I thought the democrats cared for those that are struggling to keep themselves afloat financially. Fax the Governor and tell him how you feel (804) 371-6351 or call his staff at (804) 786-2211. Write Vernon Holloman, Ex. Dir. of the Proprietary Child Care Association of Virginia [vernon@visi.net]. He'll send you the Aug 30, 2003 letter he wrote to the Governor recent study results that says 95 to 96% of Virginians are happy with their day cares just as they are. Write Debra Andrews, Chair of the Board of Social Services [debra.andrews@sv.cc.va.us]. Stand up or be prepared to suffer the financial consequences or other emotional effects of pulling your children from where they love. Governor, please listen to the parents that have to write the checks each week. 

 

CommentID: 46
 

11/14/03  12:00 am
Commenter: Mary-Margaret Gardiner / Virginia Association for Early Childhood Education

In Support of Proposed Regulation Changes
 

Dr. Arnie Lapp Payne

Program Developer Supervisor

Virginia Department of Social Services

730 East Broad Street

Richmond, Virginia 23219-1849

 

 

Comments on Child Care Regulations:

 

Thank you for the opportunity to provide my comments to the council.  My name is Mary Margaret Gardiner.  I have worked in the early care and education field since 1976, for private for profit, non profit and church related child care.  I have worked as a parent educator , home visitor and provide training for child care workers through the HANDS program (Helping and Nurturing Developmental Stages).  I am also the president for the Virginia Association for Early Childhood Education.

 

I am very encouraged by the proposed changes to child day care regulations.  They have the potential to strengthen and improve the quality of care for the over 300,000 children with working parents in the Commonwealth of Virginia. 

 

The proposed changes in ratio, teacher training and group size among others are proven by research to be critical factors in providing quality care.  High quality care leads to the development of more advanced learning skills, such as language and math abilities and social skills.  By providing children with

Teachers who understand child development and have more opportunity to interact with the children because of smaller numbers of children and group size, we can positively effect the experience of the children we care for.

 

A second benefit of these proposed changes is likely to be reduced staff turnover.  The emotional cost of high turnover to children and families is high.  Children need consistency in caregivers who are warm responsive, and offer classroom environments and activities that take into account each child’s needs.

 

Reducing class size and increasing training cost money.  You are likely to hear strong opposition to these changes based on cost.  I ask you to consider the benefits to the children and working families.  Clearly, these benefits outweigh the costs, which if you really look at them may not be a burden.

Cost of hiring, training and finding caregivers to replace those who leave the field can be very expensive.  A 1998 study found the cost to be around $1500 dollars per employee.  $1500 can go a long way in training opportunities or making up for smaller group size.  Consider saving $1500 per employee times the number of staff that need to be replaced due to turnover.  People leave the field because of the stress of working with large groups of children, low pay, and lack of support through training and professional development.  I know from my own experience as a parent, my 2 year old child had 6 teachers in 8 months of child care.   How can a child ever feel safe and attached in an environment that has this level of turnover? 

 

We need to invest more in the lives of children, our youngest citizens.  It will pay off in the future with less money spent on special education, less grade retention,  improved scores on standardized tests, reduced crime and welfare rates and a more productive labor force.  Our state was once a leader in the level of care we provided for our children. These proposed changes are positive steps towards returning to that level.  We owe it to our children, our fellow citizens and the country to make these changes.

 

 

Thank you, for your time.

 

 

 

Mary Margaret Gardiner

VAECE President

 

 

CommentID: 47
 

11/14/03  12:00 am
Commenter: Ronald Crouch / Moseley Architects

State Opinions as Opinions Please
 

I simply had to respond to an earlier posting in an attempt to dispel its perception, that by studied actual facts, is not true. We need to be careful to present our opinions in this forum, as just that, if we have not educated ourselves to the actual facts: Here it is:

 

Innuendo:  “A second benefit of these proposed changes is likely to be reduced staff turnover.” Quote from Mary-Margaret K. Gardiner, public forum comment, posted 11/14/03.

 

Fact: Child care services in Virginia have been studied extensively and repeatedly since 1984. The two most exhaustive studies were conducted by the Joint Legislative Audit and Review Commission and Virginia Commonwealth University (JLARC/VCU)1 in 1990 with a follow-up study in 1997 and, most recently, by George Mason University from 1998-2000. The GMU study results were published as Senate Document 4 for the 2000 General Assembly. The GMU study was conducted by that university's Mercatus Research Institute and was conducted by a team of statisticians and researchers. The topic of turnover of employees in child care was studied. The GMU study reports that, in Virginia, the annual staff turnover rate among child care workers is 20% with the average child care worker remaining on the job 4 years and 7 months. In the licensed sector, the average child care worker stays employed in the field 9.3 years.  By contrast, the state's elementary school teacher turnover rate is 21.4% annually. Virginia continues to enjoy a stable workforce with low employee turnover among child care staff. Compared with other service industries and the public school system a 20% employee turnover rate is very acceptable considering that people move, get transferred, family responsibilities change, some suffer illness, some die.*

 

At my own day care, turn over is something I have not witnessed. The same staff have been there since the beginning of the Summer 2003 when I came off the long waiting list for my school-age child.  Many workers have been there for many years. The commenter who posted the above innuendo obviously had a problem was but that is not fair to suggest a high turnover rate in this profession and as a reason to make such drastic and costly changes. At least that commenter agrees that costs will be increased and haven’t ignored it like other commenters.  I am thankful for her that she obviously will not be financially impacted by this change because I will and that is a fact.

 

Another Fact: From the same above referenced studies, Both JLARC/VCU and GMU studies indicate that 96% and 95%(respectively) of parents in Virginia are satisfied or very satisfied with the quality of care their children are currently receiving and parents have not changed child care providers in the past two years*.

 

Opinion: So, why did the Governor’s office staff make these changes to the standards and hand them to the Day Care Council for passage and implementation? This is in sharp contrast to previous Child Day Care Council procedure that allowed members to work in subcommittee fashion as they actually performed the difficult task of drafting and editing the regulatory language themselves and, as a result, produced a product which was truly "owned" by the council and truly represented the needs of the populous. The Economic Impact Analysis for this change could only muster that there will be a "likely" increase in tuition cost. In my opinion that study was not was grossly incomplete if I know for a fact that I will be facing a 30% increase in tuition. Every care provider must be surveyed to share their impact on cost to their consumers. It seems the government would not want to hamper any signs of an economic recovery with such a potential financial impact on the consumer. I am sure the changes are well intended, but lets be sure the people they are intended for can afford them.

 

*Please write Vernon Holloman (Exec. Dir PCCAV) as I stated in my earlier posting. There is other information like the above that was sent by him to the Governor to help to dispel the perception that there is a major problem that has to be corrected in our licensed child care market in Virginia. [Vernon@visi.net]

CommentID: 48
 

11/17/03  12:00 am
Commenter: Kathryn Hundley

Infant play spaces
 
As I understand it an infant may stay sleeping where he is if it is considered a "safe environment."  As it has been my experience with infants they frequently go to sleep on the floor or in play swings that are both approved play spaces according to these rules.  If a caregiver only has to check on the infant every 20 minutes, which is not logical for a baby on the floor, then that baby could easily get stepped on.  I realize that this is an extreme example, but if it happened then someone could say, "well I was just following the rules."
CommentID: 49
 

11/17/03  12:00 am
Commenter:  

Support changes to standards.
 
I support the new changes to the Licensed Child Day Center standards.  I especially support the increased training requirements.  It is well documented that one of the most influential factors in the quality of services offered in child care centers is the training and education of the staff.   Virginia needs to catch up with much of the rest of the country and consider the safety and quality of child care and education services for young children a priority. 
CommentID: 50
 

11/17/03  12:00 am
Commenter: Margaret Sewell

Support for higher standards to promote quality
 
I strongly support the proposed regulation changes as a step towards more consistent, higher quality child care services for Virginia's children. As director of a program which currently operates ten licensed preschool classrooms, I see these changes as an enhancement, not a threat. The research clearly and consistently indicates that smaller group size, higher levels of teacher/caregiver training, and better staff:child ratios are associated with higher quality and better outcomes for children. Virginia's children and their parents deserve no less. At the same time that the regulations "raise the bar" in these key areas, they also allow centers greater flexibility in some others, for example in staffing at the beginning and end of the program day. These are common-sense trade-offs.
CommentID: 51
 

11/24/03  12:00 am
Commenter: Michelle Mills

Proposed Changes
 

I am very pleased with the proposed changes especially the sanitation and prevention of disease.   Parents need to be required to report communicable diseases in the house because even though the child may not show symptoms it may still be possible to pass the disease on to other children in the center.  I also think it is important that childcare providers inform parents when a child has been exposed to a disease.  Some of the other sanitary proposals seem like they should be already in place like requiring soap and water when washing hands and cleaning and sanitizing high chairs and diapering surfaces, but if they are not this is long overdue.

While reviewing the proposed changes there are at least two other sections that I felt were of dire importance.  I applaud the effort to decrease staff to child ratios.  This allows staff members to give more attention to each individual child.  As an expectant mother I want my child to be in a safe and comfortable environment where his/her providers will be able to adequately address all issues that arise.

Finally, I think that increasing the amount of training that is required is great.  I think that before people are allowed to work with children, they need to be trained.  I highly value my children and I want to be able to feel confident that they are in good hands.

CommentID: 52
 

11/25/03  12:00 am
Commenter: Katie Reaves

Happy with proposed ratios
 

I am happy to see that there will be better regulation of teacher to child ratio.  It is essential that children have the attention that they deserve and need.  I am also very pleased to see that there will be a proposed group size for each age group.  It is a danger to both the health and safety of the children if classrooms are overcrowded and this proposal will close a major loophole in the ratio regulations.  I think the proposal for child ratios will be a benefit to the children, the parents, and the child care center.  I am glad to see Virginia strengthening its regulations in support of children.

Katie Reaves

CommentID: 53
 

11/26/03  12:00 am
Commenter: Amy  Brothers / Children's Academy, Inc.

A reminder of what is important!
 

I have worked in child care for several years in several states.  Like it or not VA is pathetic with the standard compared to other states.  I suggest looking at Oklahoma who has a star rating system.  Each facility recieves a rating of one - five star rating such as resturants and hotels.  Different standards for each rating.  This way each center can choose the standards they want to acheive.  The parents also get what they pay for.  With that said. 

Yes, these changes are going to be a finacial challenge.  Okay parents overall are happy with their child care.  So what about the children and the teachers?  Right now if a child care facility is not accredited by any national organization it is considered a babysitter if not by the parents then this is the perception of the teachers or this what they percieve others think of them.  I see it everywhere.  When we have high expectations of our teachers and support them because we know that they can do it then what a difference we make in children's lives.  Changes are hard we are creatures of habbit, but think beyound to the lives that they will be truely touching.  The teachers need our support, what do they think about these changes?  Many I have talked to say Yes!  They are excited to see someone hearing them cry HELP!  You go into a classroom of 20 two year olds.  Even with another teacher or 20 schoolagers by your self.  Good Luck! 

I too believe that help is also needed for the private owners.  Dropping ratios and increasing square footage is a huge challenge.  These changes are going to push private owners to close some doors because parents may not be able to aford the cost increase.  Help has got to be availiable from somewhere. 

Notice how we are struggling over the "big" things?  the "money" things?  I have learned that as I teach the children they teach me, so what do they think?  Why does this have to be a political thing, it should be a child thing!

 

CommentID: 54
 

11/28/03  12:00 am
Commenter: Daniel Jobe

A Concerned Parent
 

I don't have a college degree, and I haven't read a bunch of studies on the subject of childcare. I DO have a 3 year old in a caring and nurturing childcare facility. I have seen the way she has blossomed in the 9 months that she has been there. 

My child is adventurous, and she falls.  Often.  I cannot imagine that 9 inches of mulch is going to protect her any more than 6 inches.  Its physics:  She's only 32 pounds, and even if she falls off the slide from four feet then 6 inches of mulch is just fine with me.

Adding 10 square feet to the minimum playing/living space doesn't make sense, either.  One square yard + one square foot will not make my child's quality any better.  It may, however, force our facility to decrease its population. If the school is forced to decrease its population by 30% then logic says our tuition will increase by the same amount.  (By the way, how will they choose who will be asked to leave?)  It is hard enough for a working family to make ends meet.

I truly believe that these proposed changes were made in the best of intentions.  Please make sure that common sense prevails.  Let's make sure that working people have quality childcare and not forced into leaving our kids at Grandma's with no educational curriculum.

 

 

CommentID: 55
 

11/28/03  12:00 am
Commenter: Jennifer Downing

Child Day Care Minimum Standards
 
I am very happy to see that our child day care centers are finally getting some recognition that there needs to be some major changes within these facilities. These children are the minds of our future. We need to improve these day care centers just as much or as often as elementary, middle, and high schools do. The education of these children and the facility of where these children are being taught in should be very important to lawmakers. I feel the most positive aspects of this proposal are the gradual increase numbers of training that each program director is required to have now, the increase in the amount of activity space each child will have, and the teacher per child ratio in the classroom. These children deserve the best educational centers possible, it is beneficial to the child's overall education. I am very pleased with this proposal.
CommentID: 56
 

11/30/03  12:00 am
Commenter: Kimberly Anne Landen

Child- Day Care
 
I am gald at the overall proposal at increasing the standards in day- care centers. Staff qualification and training is a needed must for the betterment of future children. In the long- run this will be less- cost effective and fewer children will  become injured. For example, if there were more training given on a pay- for -play playground daycare in the state of Virginia less children may not get seriously injured. Thank You 11/30/2003
CommentID: 57
 

11/30/03  12:00 am
Commenter: Nichole Meade

More clear qualifications
 
I do not apporove of the wording for center workers who work with students with disabilities and special needs.  All the regulation says the staff needs is KNOWLEDGE about modifications and the disabilities.  My question is "What does knowledge mean?"  If someone is sending their child to a liscenced day care center for students with disabilities then there better be professionals at the center with degrees and certifications for Special Education!  Knowledge could mean that they have heard of the disability.  There needs to be more clear descriptions of qualifications for staff to work in centers with children with special needs.  The qualifications also need to be more strict requiring the staff to have proper training and certification to work with these students.  Students with disabilities need more care and attention than children without disabilities and the staff should be qualified to handle the extra responsibilities. 
CommentID: 58
 

12/1/03  12:00 am
Commenter: Muriel Azria-Evans

Changes are not only appropriate but necessary.
 

With a background in early childhood education (PhD in Human Development and Family Studies), I feel it is my responsibility to respond to these changes. I feel these changes are not only appropriate but necessary. I would like to address several specific changes, including staff training, group size, director qualifications, and increased space requirements. It is well known that while childcare of poor quality is associated with poorer developmental outcomes, high-quality care is associated with outcomes that all parents want to see in their children, ranging from cooperation with adults to the ability to initiate and sustain positive exchanges with peers, to early competence in math and reading. The regulatory changes presented reflect what we would in the field consider characteristics of quality childcare.

The proposed changes highlight variables (e.g., the quality of child-caregiver relationship and the structural features of care) that have previously been examined in studies of childcare quality. First, we know that skilled/trained and stable childcare providers are necessary to promote positive development. Well-trained staff/providers are more likely to provide ample verbal and cognitive stimulation, be sensitive and responsive, and take part in more appropriate and engaged interactions with children in their care.

The ratio of children to caregiver has held up over time as one of the most sensitive indicators of quality care in all settings. The decrease in group size for two- and three-year-old children is in direct accord with ‘best practices.’ It is well known and accepted that “even small improvements in ratios and education are reflected in more sensitive, appropriate, and warm care giving, suggesting useful targets for investments in quality” (From Neurons to Neighborhoods, 2000, pg. 318).

Having taught future child care providers/directors/owners at a four-year higher education institution, I know how important it is for directors to have the appropriate managerial background to run a successful child care program. While most directors have the child development background necessary to meet the needs of the children in their care, some do not have the managerial skills necessary to plan and manage a budget and staff. These managerial skills may help decrease staff turnover, find external funding, maintain budgets, etc.

Lastly, the increase in space supports well-accepted research and theory (e.g., Piaget, Montessori) that children need adequate space to explore their world cognitively and physically. Young children learn through exploration and manipulation, which necessitates adequate space. Thank you for giving me the chance to comment and I hope my remarks can be helpful in the regulation process.

CommentID: 59
 

12/1/03  12:00 am
Commenter: Christine Ledbetter

proposed changes are a good start
 

In my opinion, the facilities for young children should have more stringent regulations. I think the proposed changes are a good start and well overdue. It is unfortunate that, in general, more emphasis is not placed on the importance of early childhood development.

I am a graduate student and my husband is an educator, so certainly we understand the need for affordable childcare, however there is truth in the idiom ‘you get what you pay for’. We would rather sacrifice this, that or the other and know that our child is in an excellent facility.

I think certainly a program director should have a Master’s degree and a program leader should have a Bachelor’s degree. In addition, aides should have a high school diploma or GED. I personally want to know that the people caring for my child are not only experienced, but also well educated.

 

CommentID: 60
 

12/1/03  12:00 am
Commenter: Gayle Hermoso

Proposed changes to minimum standards for day centers
 
Before viewing the proposed changes to the licensed child day center regulations, I was eager to see what areas of improvement daycare centers needed. I am pleased with the minimum standards, especially the section regarding sanitation and prevention of diseases.  However, I was not aware that the staff qualifications and training were so minimal.  Hopefully, our children will be left in the hands of educated and experienced individuals who love and care for them they way we do.  Regarding activities, I agree with Denise's comment that storytelling should be mandatory.  I, too, was unaware that toddlers and preschoolers were not read to on a regular basis.  It would be interesting to see how soon these much-needed changes will go into effect.
CommentID: 61
 

12/2/03  12:00 am
Commenter: Tricia Riggs

How many of you have children in Childcare? Opposed to propsed changes
 

After reading many of your comments I have to wonder how many of you will be affected by these changes? If you can no longer afford to send your child to a center , you have two options leave your job or find and in-home provider which may or may not be good for your child. This change will directly effect those that are already struggling to pay for quality childcare . My daughter is well taken care of by a wonderful staff (very low turn over) who not only care for her but about her. The amount of time and effort that they take with each and every child makes them a great benefit to my daughters education and well being.

All centers are not created equal -so how can you group them all together by space. While my childs well-being is the most important aspect, costs plays a roll like it or not. For those of us lucky enough to have our children in wonderful, caring and educational enviroments already -why penalize by making childcare so unafforable to "working parents"?

CommentID: 62
 

12/2/03  12:00 am
Commenter: Erica Hibner

Positive Daycare changes
 

Hello!

After reading the proposed new legislation, I can only see positive changes in store for our daycare centers.  While it is hard enough to leave your child, it must give parents some sense of comfort to know their children are in expert hands, rather than just any babysitter.  I also found it interesting that these revisions were derived from surveys completed by the actual daycare centers.  These regulations must certainly be in need if they came from the facilities themselves. As with any improvement, it comes with a price tag but how can we put a price on the safety and nurturing care of our children?  I would certainly spend the extra money for quality.  

Thank You

CommentID: 63
 

12/2/03  12:00 am
Commenter: Mandi Medhurst

Thumbs Up to Change!
 
I believe that the proposed changes are a step in the right direction.  There is no doubt that decreased class size and improving quality training will  improve the day care industry.  Improvements will cost, however, and I would not like the thought that these improvements would increase cost to a level that working families could not afford.The idea is to improve the situation for children and not take quality care out of reach of families that need it most. These changes need to be made, but administrators should work together to explore methods of cost subsidy.
CommentID: 64
 

12/3/03  12:00 am
Commenter: Jon Nafziger

Support qualification and ration changes
 
As a father of three young children, I encourage the Child Day Care Council to support the strengthening of staff qualifications and reducing staff to child ratios in licensed child care centers. These factors are the most significant ones in determining the quality of care that our children receive. While additional costs may be involved in meeting these requirements, the importance of quality care for our youngest children warrants these changes. I also appreciate the Council's efforts to provide for children's health and safety, and support practical steps to improve the current regulations. At the same time, I encourage the Council to offer providers as much flexibility as possible in the areas of space requirements and physical environment. Overly burdensome regulations that do not directly address the primary indicators of quality care can increase costs to families without corresponding benefits to children. Overall, improved standards for child care centers in Virginia, especially regarding the qualifications of staff and the number of adults to children, will positively impact our children at the most critical time in their development. Jon Nafziger
CommentID: 65
 

12/5/03  12:00 am
Commenter: Barry Meil / Winwood Children's Center

22 VAC 15-30
 

We have deep concern over the proposed changes.  Though our centers meet most of the proposed standards and will therefore see little impact on us, we are concerned about the negative impact it will have on the children of VA.

Our main concern is that it will dramatically reduce the number of children that may be served in VA.  Existing and future centers will be licensed for fewer children than is currently allowed.  Many small centers will be forced to close since it will be financially impossible to stay in business.  With reduction in licensed care comes the danger of more unlicensed providers opening, putting the children of VA in a situtation potentially far worse than what currently exists.

We applaud your efforts to improve the care offered to the children of VA.  May we suggest that instead of these proposed changes that you first give the Dept of Social Services the power to enforce the regulations currently on the books.

CommentID: 66
 

12/6/03  12:00 am
Commenter: Miriam Haddock

In favor
 
I am in favor of the proposed changes to minimum qualification and training requirements for staff in Virginia day care facilities. Our children are our most important resource and they need to have the best qualified caregivers possible. Also the proposed group size changes and staff to child ratio changes will give added protection and oversight to the needs of the children. As a grandmother with a grandchild in day care I am aware of the costs and I would not like to see these changes drive the costs up. However, the changes are needed and hopefully they can be accomplished without additional cost to the parents/grandparents. 
CommentID: 67
 

12/7/03  12:00 am
Commenter: CASENA GARLAND

DISPLEASED WITH PROPOSAL
 

The proposed regulations addresses some changes regarding larger class sizes and smaller ratios, but it does not address who will pay for these "quality" changes.  Well I know who-"THE PARENTS".

If the proposed regulations are approved, the daycare providers will be forced to increase tuition rates and reduce the number of children in each room.  The daycare providers will be placed in a terrible position because they will forced to send some children away.  I think this will be a tough decision for all those involved(daycare provider, parents and especially the children).

My daycare has advised, if this change takes effect, they will have to lower the number of children in each room, BUT be forced to make a large increase to the tuition rates. 

PARENTS: STAND UP OR BE PREPARED TO SUFFER THE FINANCIAL CONSEQUENCES OR OTHER EMOTIONAL EFFECTS OF PULLING YOUR CHILDREN FROM A PLACE THEY LOVE!

GOVERNOR: PLEASE LISTEN TO THE PARENTS THAT HAVE TO WRITE THE CHECKS EACH WEEK!!

CommentID: 68
 

12/8/03  12:00 am
Commenter: linda beamon / t.c.c.

minimum standards for licensed child day care centers
 
i agree with the proposal to insure the safety of our children by the actions  and changes taken.....we should always be attentive to what is going on not only with our children but with all children!!!!
CommentID: 69
 

12/29/03  12:00 am
Commenter: Jill Brown / Medallion School Partnerships

Proposals Clarify Regulations for Providers
 

I think the new proposals are clear and concise. As a provider, we appreciate the length of time given in regards to staff training, area and ratio requirements.  I also appreciate the format in which the proposals were created.  It  was easy to look through the proposed regulations and see what had been added and what had been removed.  In addition, the explanations for each new proposed regulation helped us to understand why they had been written.  Thank you.

 

 

CommentID: 71
 

12/30/03  12:00 am
Commenter: Rhonda Duffie

Yes! It's about time the regulations were updated!
 
I'm so pleased that VA is finally making some needed revisions to the minimum standards.  Six years ago, when my husband and I were looking for daycare for our son, we obtained a copy of the regs. and were appalled at the "minimum" standards.   Thankfully, we found a daycare center that exceeds the minimum standards.   They are a bit more expensive, but we are talking about fulltime care for our child.   To say that we can't make the improvements because it would cost too much is ridiculous - these kids are our future!  I'm wholeheartedly in favor of the changes.  I was saddened to hear that there are many daycare centers who've given the parents form letters to send, opposing the changes.   That's such a shame.  Daycare providers should have the children's best interests at heart, and their response to the changes are precisely why there should be increased minimum standards. 
CommentID: 72
 

12/30/03  12:00 am
Commenter: Tonya Hawker

Proposed standards for licensed child care centers
 

 

I am writing in reference to the changes being proposed for licensed day care providers.  I feel that some of the proposed changes are unfounded, and as a result, will negatively impact the children of this community, rather than improve childcare conditions.  Listed below are my concerns:

 

1-      Square Footage Increase Per Child

Currently, the amount of required activity space per child is set at 25 sq. ft.  Your proposal to increase the space by an additional 10 sq. ft. will result in drastic ramifications for my child’s daycare facility.   I have a wonderful childcare facility that is managed extremely well.  I wouldn’t want my child to be anywhere else.  I tell you this because this increase in square footage forces my child care facility to take extreme measures to remain open (i.e. significantly increasing internal expenses to fund for additional staffing and building expansions).  These costs will force my day care facility to make 1 of 2 choices-
            1- Close their doors

2-Pass the significant expense, associated with the increase in activity space per child, on to the parents. 

Council members, the parents already pay an enormous amount for child care expenses as it is.  And furthermore, I just DO NOT see how a 10 sq. ft. increase in activity space per child justifies the additional costs that the parents must bear.  I feel strongly that it is not a matter of square footage that makes a good child care facility.  It is how a director manages that space that is important.

 

 

2-      Decreasing the Staff-to-Children ratios

This proposal falls into the same opinion I have as noted above.  I feel that the current staff-to-children ratios are sufficient as they are.  What is important is how the day care director manages the staff and children.  Just adding an additional staff body is not what is important, and the additional expense involved in adding additional staff is not justified as a requirement for day care facilities.  How the staff is managed should be of more importance to this council.

 

3-      Requiring an additional staff-member to ride-along with a driver when 16 or more children are being transported in a vehicle.

My question here is this-  If school buses don’t need an additional person, why should child care centers need to have additional staff on the van.  In fact, day care centers have shorter routes to/from schools, seat belts and less children are on their vans then on regular school buses.  I feel my children are safer on the day care van with 1 driver than they are on our public school buses.  Again, I feel the focus should be on management of staff and children.  The easy way out of this situation is just to “add another person”.  HOWEVER, that is not the RIGHT ANSWER.

 

4-      Required Training

The proposal to require a LPN nurse to provide annual training to staff members regarding the observation of children’s health conditions is well noted.  In this situation, I feel that annual to bi-annual training would be appropriate.  In addition, I feel this, as well as additional child care training, should be offered by the state rather than passing the training expense on to the child care facility (especially through the use of an outside source). 

Please understand that I am all for additional training, but according to the standards, additional training is necessary at my day care’s expense, and appropriate/necessary courses such as CPR/First Aid, Health Screening and Medicine Administration will not even be counted as applicable credit toward the annual training requirements.  What exactly do you want in the form of annual additional training?  Again, this goes back to my point that the state should offer a career development plan with applicable training, that meets state guidelines, rather than regulate ineffective standards that do not benefit the child.

           

Let’s face it, it is unfortunate that a large proportion of child care staff are highly underpaid.  The fact that they take care of our children day in-day out should be reason to give them more training and higher wages for this type of career.  It would be much more prudent, in my opinion, to offer a state program that appropriately trains staff members to be “good” child care providers, rather than mandate irrelevant standards on day care facilities that really will not help the children of this community.  Here, dear council members, is where I believe your focus should lie.

 

Thank you in advance for hearing my views on this matter. 

 

 

CommentID: 73
 

12/31/03  12:00 am
Commenter: DeAnna Harkabus

Worried about change
 

I would like to start off by saying that I am very concerned about the proposed changes.  I am a single mother of 2 children, 3 year boy and 3 month old girl.  I struggle every month to make the payment for my child care center as it is, but I have had a bad experience with my son getting mistreated through a private sitter, that is why I decided to put him in a state regulated day care center.  If this proposal goes through, I will unfortunately have to take the chance of finding another private sitter and hope for the best.  This is unfair to the thousands of working parents out there that are happy with their current child care center and the regulations in place. 

CommentID: 74
 

12/31/03  12:00 am
Commenter:  

Social Worker concerned about changes
 

As a Social Worker in a rural county of Virginia, I have great concerns regarding the proposed child care center changes.  Many people have already done the calculations:  if the proposed changes take place, centers will have to raise their rates in order to keep their doors open.  They will also be keeping fewer children because of the space requirements.  This will have a huge economic impact on centers and parents.  Centers will be forced to choose which children they keep and which have to leave.  Parents will be able to help in this decision as many will be unable to pay the increased costs.

 

The Child Care Assistance Program through the Department of Social Services will ultimately be spending much more money.  Many agencies already have people on waiting lists because the funding is simply not available for everyone who qualifies for assistance.  Should the cost of child care increase, more people will apply for assistance.  Parents who are already on assistance may have increased costs as well, if they must cover the increased fees until more Assistance money is available.

 

A final concern is that more people will open and operate home-based child care illegally, hoping that they will not get caught.  Parents will either use the illegal care because of the cost, or will simply leave their children at home alone.  An increase in Child Protective Services may result from this.

 

Every good parent wants the best for their child(ren).  This is why parents work and/or attend school to further their education.  However, there are economics involved and parents sometimes have to choose between quality care and feeding their family or paying the rent.  For many Virginians, they must choose the latter, hoping that their child will be safe.

 

Please note that my major concerns are for how the staff to child ratios and space requirements will impact the children and their parents.  Most of the other proposed changes seem plausible and would only serve to enhance the quality of child care.

 

Thank you for your time and interest in this matter.

CommentID: 75
 

1/1/04  12:00 am
Commenter: Laura Adler

Please don't close our beloved preschool!
 
When I first heard about the changes to the minimum standards for Virginia Daycare, I was pleased. It was not until recently when I learned these changes would affect my family's preschool that I became alarmed. My family is a member of a non-profit, nationally accredited cooperative preschool that has operated in Northern Virginia for more than 40 years. Parents run the school and participate in the classrooms. We currently have space for about 65 families. Classes meet 2, 3 and 4 times a week for a few hours a day. Overall, I support the changes to the minimum standards. Many would raise the standards to a level which our preschool already meets or exceeds. But there are a few that would be disastrous. The 35 square feet per child minimum alone would probably close our school. We rent space and are currently paying as much as we can afford. We cannot function with reduced enrollment, as we depend on not only the money from 65 families, but the labor as well for running the school, staffing the classrooms and doing fundraising. I have spent much time in the classroom with my children and those of my friends, and I am comfortable with the 25 plus square feet per child we currently provide. After all, we are talking about approximately 6-12 hours a week, not 50 plus, including time in other classrooms, an additional multi-purpose room when available, and time outside weather permitting. My daughter attended this preschool for three years. I believe the quality of her experience there has directly contributed to her remarkably smooth transition into kindergarten at a local Fairfax County Public School, where she is currently excelling both academically and socially. I am not a working parent begging you not to raise my day-care rates. I am fortunate enough to be able to stay home with my children. I could choose any preschool in Northern Virginia for them. I chose our preschool because I feel it is the best choice for my family. Please don't take that choice away from us. Yes, let's improve day care! But let's not implement these changes without an exemption for preschools. In the rush to catch the children who have been "left behind," please don't leave mine behind. Thank you for your time.
CommentID: 76