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

F. The licensee shall ensure that for infants who are awake and unable to turn over alone, staff shall make three attempts at supervised tummy time for approximately three to four minutes at a time.

8VAC20-781-410 Parent communication and notification

G. For each infant, the center shall maintain a daily record which can be easily accessed by both the parent and the staff working with the child. The record shall contain the following information:

6. For infants, who are awake and cannot turn over by themselves, (i) the number of attempts at tummy time, and (ii) the amount of time spent on their stomachs.

H. The licensee shall ensure staff maintain daily records required by subsection G of this section for 60 calendar days from the date of report.

• Asking staff to time three tummy times for each of four infants in their care means additional time spent not caring for children but writing down 12 different records each day.
• Because the chart may not be with them if they are on the floor, this means remembering the minutes and seconds for each child/ This may be especially difficult if interrupted to care for another child on the way to record.
• This specifies that three attempts are to be made. Will the licensee be in violation if a staff member makes four attempts? 
• Is the "amount of time spent" cumulative for the day or does it mean for each attempt made?
• Many centers give the daily records to parents when they pick-up their children. Requiring these records to be kept at the center will mean less up-to-date information for parents or duplicate paperwork for the center.
• I suggest deleting 410.H.