Like all licensed day centers, we commit to setting up all teachers for success and providing our students with only qualified and prepared teachers.

Regarding 8VAC20-781-120, the proposed expectations for training prior to a promotion to a lead position is excessive and not necessary to prepare for such a promotion; fewer hours will be more than enough. Those hours plus a minimum of 6 months of experience will prepare any teacher for success in a lead position.

-- Please consider reducing the requirement from 24 to 12 hours, which is still plenty of time to include: 4 hrs on child development, 2 hrs on behavior guidance, 2 hours on health and safety, 2 hrs on curriculum (to include CLASS if applicable), and 2 hrs on parent communication and recordkeeping. NOTE: All of that would still be in addition to orientation training.

Regarding 8VAC20-781-140 about orientation training, I request a reconsideration of the 10 hour preservice training provided by the Department. There are sections that do not apply to all staff, so I request that it be organized so that teachers are only viewing what is relevant to their position and school.

-- Perhaps have different versions for administrators vs teachers, and subsidy vs non-subsidy schools.

-- Perhaps consider reducing the total number of hours for this particular training, as this is a significant burden for a center trying to hire to fill a current opening; the sooner a new hire can complete all required training, the sooner they can help the center meet its supervision needs.

Thank you.