8VAC20-781-40 Required Policies and Procedures
A. The licensee shall develop and implement the following written policies and procedures:
Response:
While the intent is to ensure clarity and cover all bases, there's a fine line between comprehensive documentation and drowning in repetitive details.
If a particular requirement has already been addressed elsewhere in the standards, it seems redundant to have to write 21 policies for how we plan to meet those requirements. This process will be labor intensive for centers that are already strained from being understaffed.
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 and 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.
It is again redundant to make Centers write a policy to explain HOW we will comply with the requirements already outlined elsewhere in the Standards.

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 when it is already addressed elsewhere in the standards.
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 licensing regulations. A “procedure” is already in place as outlined in the standards
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 and time consuming.

16. Stock epinephrine. Such policies and procedures shall meet the requirements of 22.1-289.059 of the Code of Virginia".
Response:
Being prepared for allergic reactions is of utmost importance, as it can be a matter of life and death. While the significance of readiness is widely acknowledged, the absence of clear guidance can create uncertainty and potential risks. Clarity in guidelines is crucial to ensure that individuals, caregivers, and relevant personnel understand the necessary steps to take in case of an allergic reaction.
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. Another redundancy.
8VAC20-781-40 B. “The center shall annually review all policies and procedures required by this section and shall document on the policy and procedure the date of such review.”
RESPONSE
Currently only injury prevention and the emergency preparedness plan must be reviewed. The list has gone from 2 to 21 policies, including policies that are highly unlikely to change such as confidentiality, swimming, drinking water, transportation, records, and behavior guidance. Those kinds of policies are pretty much set and there is no need for review or document review. It's a regulatory burden to add to the already difficult to maintain intensive paperwork requirements when we could otherwise be focused on working with children, teachers, and families.
8VAC20-781-50 General Recordkeeping
C. The licensee shall keep all records required by 8VAC20-781-60 and 8VAC20-781-70 in locked files or a secure electronic file, except for those required to be accessible pursuant to 8VAC20-781-600; and access to such files should be restricted according to a principle of least privilege.
RESPONSE:
This standard is already covered in section A, …Staff and children’s records shall be treated confidentially
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.
RESPONSE:
We do not support requiring staff (or asking parents) to record daily arrival/departure times. If parents are asked to do it, teachers will still have to closely monitor the process. Teachers track attendance of each child daily and are aware of each child via sight and sound supervision requirements. The priority must be child interactions during these transitions. We do not support unnecessary paperwork which takes the teachers' attention away from children, perhaps only for a few seconds, but multiple times every morning and every afternoon.

D. The center shall inform the superintendent as soon as practicable but not to exceed two business days after learning about any incident while a child is under the supervision of the center that required medical attention.
RESPONSE:
As currently written, we do not support this standard. This statement is much too broad. If a child is taken to a doctor’s office to have a splinter removed which occurred on a field trip to a public park, centers should not have to notify the superintendent. Often, parents do not notify us that their child received medical attention. Parents have D.O.E. contact information where they can report incidents or injuries which occurred while their child was in the care of a center if they believe the center’s staff, physical plant, or combination thereof resulted in their child being injured. Are public schools mandated to report such injuries to DOE or their local school boards?