Thank you for the opportunity to provide feedback and suggestions.

VAC20-781-140 Orientation training

1. The licensee shall ensure that all staff who will work with children complete the preservice training sponsored by the Department within 90 calendar days of their date of employment. A staff member who has documentation of completing the preservice training shall not be required to retake the course.  

Comment: the preservice training is periodically updated with new health and safety information. I suggest clarifying the intent with this addition: A staff member who has documentation of completing the MOST RECENT VERSION OF the preservice training shall not be required to retake the course.

8VAC20-781-270 Supervision of children

2. In accordance with Part V of 8VAC20-820 and with approval by the Superintendent, a center may temporarily alter the staff-to-child ratios (i) by one child for groups of children from birth up to school age eligibility, and (ii) by two children for groups of children school age eligible through age 12. Under this provision, group sizes three times the approved ratios may be implemented for children ages birth up to school age eligibility. Group size for school-age children must meet the requirements in subsection A of this section.

Comment: The term “temporarily” is not adequately defined. Is the intent that this is allowed in times when perhaps the licensee is temporarily short-staffed but anticipates being able to rehire or find a substitute in order to quickly get back to the preferred/required ratios? Otherwise, what exactly determines whether the Superintendent would approve this alteration, and for how long?

8VAC20-781-270 Supervision of children

1. If a child with a special need is assigned to a more appropriate age group for the child’s developmental level, a written assessment by a recognized agency or professional shall be required at least annually. These assignments are intended to be a permanent new group and staff members for the child.

Comment: the word “permanent” is not adequately defined. I suggest clarifying the intent with this addition: “These assignments are intended to be consistent until that time when it is determined the child’s developmental level indicates a new assignment.”

8VAC20-781-320 Daily activities

2. For toddlers, media use up to two hours per day is permitted if the center operates more than six hours per day …

Comment: The AAP recommends no more than one hour a day for two- to five-year old children.

8VAC20-781-330 Daily care and activities for infants

2. Outdoor time, unless weather and air quality allow based upon the Air Quality Color Code Chart as provided by the Department of Environmental Quality indicates that outdoor conditions are hazardous.

Comment: Something is grammatically wrong with this sentence.

8VAC20-781-340 Resting and sleeping infants

3. The licensee shall ensure that staff shall not use sleep adaptive equipment unless otherwise directed in a written, signed statement by the child’s physician or physician’s designee.

Comment: Please define sleep adaptive equipment

8VAC20-781-380 Behavioral guidance

4. Promote ways of getting along;

Comment: What does this mean? Please clarify and reference age and developmental appropriateness for expectations. Too often we see teachers having expectations of how children engage socially that are wildly inappropriate and setting up behavioral problems. This warrants better guidance.

4. If time out is used as a behavior guidance technique:

Comment: If you are going to approve of time out being used for behavior guidance please require training on how to do it appropriately. Too often we see it used in a punitive manner especially when teachers are not skilled in their own self-regulation. This warrants specific training.

8VAC20-781-390 Prohibited actions

7. Verbal remarks which are demeaning to the child or psychological punishment of any kind, including ridicule or humiliation;

Comment: I suggest you edit to read: “Verbal remarks which are demeaning to the child OR CHILD’s FAMILY … Too often we hear teachers making derogatory comments about parents/families in front of children.

8VAC20-781-410 Parent communication and notification

B. The center shall maintain a written record and provide parents with a written report of each incident involving their child on the day of occurrence. The written report shall protect the confidentiality of other children involved, and shall include:

Comment: I suggest you edit to specify what type of incidents need to be reported to parents. Those that involve injury or harm? Those that involve behavioral concerns?