8VAC20-781-40 Required Policies and Procedures

A. The licensee shall develop and implement the following written policies and procedures:

4. Playground safety.  Such policies and procedures shall include (i) how staff will engage in the active supervision of children and (ii) maintenance of equipment and protective surfacing.

RESPONSE: 

8VAC20-781-260  Includes three pages of playground equipment requirements as well as protective servicing requirements which must be followed by all State Licensed centers.  It seems redundant to also write a procedure as to how this is to be followed.

5. Supervision of children.  Such policies shall be consistent with all the requirements of Part V of the chapter and include (i) methods of active supervision of children; (ii) how the center will ensure that each group of children receives care by consistent staff or team of staff members; (iii) how the center will identify where children are at all times, including during group transitions and field trips; (iv) actions to take when a child arrives after scheduled activities have begun, including field trips or when the group is offsite or not in the assigned room when the child arrives; and (v) maintaining staff-to-child ratios.

  RESPONSE: 

(i) 8VAC20-781-270  Requires that staff provide for the safety of children and that staff remain alert to the needs of the children.  It also requires the licensee shall ensure sight and sound supervision by staff who are always physically present. 8VAC20-781-320 states the center shall provide a variety of daily activities for all age groups that are age and stage appropriate and based on the physical, social, emotional, and intellectual needs of the children.  It also states the center shall provide opportunities for staff-directed and self-directed activities; a balance of active and quiet activities; active outdoor play; and individual and group games.  This seems redundant to also write a procedure for active supervision.

(ii) Centers will certainly attempt to do this but with the ongoing staffing crisis, “ensuring” this is not a reasonable request.

(iv) Why is a written procedure needed for this?  Can the child just “join their group” whenever they arrive?  We do not object to a written procedure for when a child misses a field trip or when the group is offsite and not in the assigned room when the child arrives.

8. Records.  Such policies and procedures shall describe how records shall be kept confidential and secure; remain accessible, including during power outages or emergencies, and shall meet the requirements of 8VAC20-781-50 through 8VAC20-781-90.

RESPONSE:

8VAC20-781-50 A. Requires Staff and children’s records shall be treated confidentially. A written procedure describing how records are kept confidential is not needed.

9. Confidentiality.  Such policies and procedures shall describe how staff will maintain the privacy of children in care, including expectations for communications, use of technology, and social media.

RESPONSE:

Staff are required to sign a Confidentiality Statement at orientation per licencing regulations. A “procedure” is already in place.

15. Medication.  Such policies and procedures shall meet all the requirements of Part VIII of this chapter.

RESPONSE:

Medication policies and procedures are outlined in 8VAC20-781-520 through 8VAC20-781-570; this is another redundancy.

19. Preventing the spread of disease and infection control.  Such policies and procedures shall meet all the requirements of part VII of this chapter

RESPONSE:

All of the policies and procedures are clearly outlined in 8VAC20-781-480 through 8VAC20-781-510