The 10-hour preservice training includes recognizing and reporting child abuse and neglect, and also a requirement in orientation training (140.b.2).

The repeated requirements for a new staff cost time and money to pay them.  Could this be eliminated to be required once in new hire training?

Could 150.A Ongoing Training (emergency preparedness and response, child abuse and neglect, and mandated reporter requirements) be included in the Department’s Health and Safety Course required annually in 150.B?  This would save time and additional steps to keep staff on-task for completing requirements.  

140.B.5-requirement for orientation training in child development.  This training is already covered in the 10-hour preservice training as “Foundations of Child Development”.  Repeating this training costs time and money.  Could one or the other be eliminated?

140.D Prelicensure Orientation

This does not seem like a one size fits all type training.  For a facility already licensed and hiring a new director, would there be a training tailored to already licensed, newly hired/promoted directors?  Programs where prelicensure training may not be applicable: after-school programs housed in a public school, short-term camp directors.  It may be more suitable for the admin of such programs to learn the whole licensure process, but that time and money to pay the staff to attend could be better spent with high demand training needs such as behavioral management, active supervision, managing a program, etc.