Thank you for the opportunity to give feedback regarding these new standards. As someone who has directed a licensed child care program for almost 25 years I’ve learned to appreciate and value these guidelines, however, I also feel that it’s important to keep them relevant and obtainable for programs.

8VAC20-781-80 Attendance records; reporting

                A. The center shall maintain a record of daily attendance that documents the arrival and               departure times of each child as it occurs. – I don’t understand the purpose behind recording the arrival and departure times of each child as they occur. Our staff always sign the children in and out as close to those times as possible, but they are busy doing their jobs of interacting with the children which doesn’t allow for precise times to be measured in this way. I think it’s important to keep the focus on the safety of the children versus an exact record which serves no purpose.

8VAC20-781-120. Lead Teacher Qualifications – Meeting the Lead Teacher Qualifications remains one of the most difficult standard for programs. This was a challenge prior to the pandemic and it has become even more difficult to meet since. I suggest additional options for centers to meet this standard. Perhaps adjusting 2B to allow 6-months programmatic experience and 12 hours of training or adding another level where 3 months of programmatic experience and 24 hours of training.