E. A lead teacher is not required in each grouping of children during short breaks, special activities, and during the first and last 90 minutes of operation when a center operates more than eight hours per day and during the designated rest period if the following are met:

1. There is a staff member in the group *(***(redline- “who is over 18 years of age”)*** of age and has at least three months of programmatic experience; 

2. There is an additional staff member on premises who meets lead teacher qualifications, is not counted in the staff-to-children ratios and is immediately available to help if needed; and

It is acceptable for childcare center not to have a lead teacher present with a group of children at the beginning and end of the day (90 minutes on each side), during short breaks, and special activities, given that a lead teacher and a director are immediately accessible and are not included in the staff-to-child ratio. During these times, the focus is on small group play, games, transitions, nap time, and other less formal activities.   I also believe that there are capable high school students who can effectively supervise small groups of children, provided they have immediate access to a director for support or guidance and they have undergone thorough training and have a minimum of three months of hands-on experience.  This not only allows for flexibility in staffing but also provides valuable opportunities for responsible teenagers to contribute to the childcare environment, and potentially see the value in pursuing it as their own career! Again, it is extremely important that the high schooler be properly trained and supervised and it would be helpful to put limits on the number of children and the ages of the children that they can supervise during those time periods.