Virginia Regulatory Town Hall
Agency
Department of Education
 
Board
State Board of Education
 
chapter
General Procedures for Licensure and Background Checks [8 VAC 20 ‑ 821]
Action Adopt New Standards for the General Procedures and Information for Licensure
Stage NOIRA
Comment Period Ended on 3/2/2022
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Previous Comment     Back to List of Comments
3/1/22  12:42 pm
Commenter: Mark H. Emery

Disparity in 22.1-289-030 Regulations
 

The huge disparities and inequities in the Exemptions from Licensure among the types of programs offered and the organizations offering the programs is striking and the logic is unfathomable.

Examples:

A private school operating a summer program of instructional or athletic support of any length (hours per day) or any duration (days per year) is not considered a child day program and is not required to be licensed.

A local school division operating the same type of programming is considered a child day program and is exempt from licensing only if they are operated for no more than four hours per day or less than 20 days in a calendar year.

A local government can operate a program of recreational activities of any length (hours per day) or any duration (days per year) is considered a child day program and is exempt from licensing.

Any entity (local government, local school division, private school, etc.) is exempt from licensing if their program does not operate more than 20 days on a calendar year.

What was the reasoning that led to these huge disparities?  It surely can't have anything to do with the safety and security of the children.

CommentID: 120460