Commenter:
Benita Petrella, Primrose School of Midlothian Village
Staff Training & Redundant Written Policy Requirements Already Covered by Standards
Staff Requirements and Training: Hiring, training and retaining staff in our industry is exceptionally challenging. We all recognize that turn-over is high. Easing the burden while also maintaining rigorous standards for child health and safety is important for child care.
8VAC20-78-120B.2.b. Lead teacher qualifications. We submit that reducing the mandatory training hours from 24 to 12 reduces the burden on the industry without sacrificing quality. Orientation training should also count towards this qualification.
8VAC20-781-140B. Orientation Training. We suggest giving Centers the ability to immediately begin this training (while supervised by a Program Director or Program Lead) after receiving the state police fingerprint background check clearance while awaiting the return of other background checks.
8VAC20-781-140A. Orientation Training. The 10 hour preservice training sponsored by the Department should be shortened to 5 or 6 hours and give staff who work at non-subsidy schools the ability to “opt out” of the chapters on subsidy training/billing, etc... Furthermore, the Department should permit schools that have their own preservice training programs to “opt out” by proving that their preservice training covers substantively the same topics and request approval that their training be used in lieu of the 10 hour preservice training at their Centers.
Requiring the creation and adoption of written policies and procedures for issues already addressed and required elsewhere in the Standards. It is redundant busy work to require Centers to write a policy or procedure covering HOW an issue will be handled when it is already explained and required by the Standards themselves. Examples, include:
8VAC20-781-40A.4. Playground safety as it pertains to (ii) maintenance of equipment and protective surfacing. This subject is already addressed in 8VAC20-781-260 with pages of playground equipment requirements. It is redundant to make Centers write a policy to explain HOW we will comply with the requirements already outlined elsewhere in the Standards.
8VAC20-781-40A.5. Supervision of Children as it pertains to (i) method of active supervision of children; This subject is already addressed in 8VAC20-781-270 requiring that staff provide for the safety of children and that staff remain alert to the needs of the children. It also requires the licensee shall ensure sight and sound supervision by staff who are always physically present… Likewise, 8VAV20-781-320states the center shall provide a variety of daily activities for all age groups that are age and stage appropriate and based on the physical, social, emotional, and intellectual needs of the children. It also states the center shall provide opportunities for staff-directed and self-directed activities; a balance of active and quiet activities; active outdoor play; and individual and group games. It is again redundant to make Centers write a policy to explain HOW we will comply with the requirements already outlined elsewhere in the Standards.
8VAC20-781-40A.8. and 9. Records and Confidentiality. Again, the Standards 8VAC20-781-50A already require the staff and children’s records be treated confidentially. It is redundant to make Centers write a policy to explain HOW we will comply with the requirements already outlined elsewhere in the Standards.
8VAC20-781-40A.15 and 19. Medication and Preventing the spread of disease and infection control. Once again, the new Standards would require Centers to re-write policies and procedures already meticulously detailed elsewhere in the Standards at Part VIII and Part VII of the chapter. It is redundant to make Centers write a policy to explain HOW we will comply with the requirements already outlined elsewhere in the Standards.
8VAC20-781-2410 A. Parent Communication and Notification. We object to requiring Centers to document in writing when a pattern of behavioral problems emerges or persists, including any actions taken in response. This is unwarranted overreaching by the Commonwealth into the relationships between Centers and their families. Relationships with our families are the lifeblood of our businesses. When problems arise, we have conversations, meetings, conferences and try various strategies. Our relationships are also contractual in nature. Our contracts govern when and how a child that is not adjusting well or is having behavioral issues can be unenrolled. These relationships should not be unreasonably interfered with by the State requiring documentation of behavioral issues and a course of action in writing.
