Virginia Regulatory Town Hall
Agency
Department of Education
 
Board
State Board of Education
 
chapter
Standards for Licensed Child Day Centers [8 VAC 20 ‑ 781]
Action Revisions to the Standards for Licensed Child Day Centers
Stage NOIRA
Comment Period Ended on 1/31/2024
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1/22/24  10:00 am
Commenter: Kate Ferris

Creation of Additional Written Policies for Items Already in Standards
 

I object to 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. The Standards clearly spell out what is expected. Writing this type of policy could be applied to every single Standard in the list - making us explain HOW we will meet it instead of just doing the job at hand. Examples include:

Playground Maintenance - am I supposed to write that I will call a vendor and order more mulch when I deem that what we have is too shallow? It seems like a waste of time to have to write that out instead of just making the phone call.

Supervision of Children - we are already obligated to provide various types of educational activities throughout the day, including staff-directed and self-directed. Creating a policy for HOW we come up with those activities will look like this: "We used an idea off of Pintrest to create a craft for the letter A." Why bother with this information if we are already meeting the Standard?

Preventing the Spread of Disease - we already get trained on this both in the orientation and a separate class for Daily Health Observation. The new Standards would require Centers to re-write policies and procedures already meticulously detailed elsewhere in the Standards in Part VIII and Part VII of the chapter.  It is redundant to make Centers write a policy explaining HOW we will comply with the requirements outlined elsewhere in the Standards. 

Please stop the redundancy of policy creation and let us do our actual jobs.

 

CommentID: 221409