Section A.  "...inform parents in writing when a pattern of behavioral problems emerges or persists....such notification shall include any actions taken..."  

Informing parents in written form can be detrimental given the assumption that centers are not comprised of individuals versed in legal jargon.  Any type of written communication presented to a parent(s) regarding "behavioral problems" of their child can easily be misconstrued/misinterpreted in a manner that is not favorable in the eyes of a parent(s) and problems inevitably might arise.

* Perhaps simply scheduling a meeting where verbal communication between both parties (center and parents) would better serve all parties involved (ie - center, parents and child)?

Section H.   "...staff maintain daily (infant) records required by subsection G....for 60 calendar days from the date of the report." 

• Unclear as to the necessity of keeping such records since parents are already given a record at the end of the day entailing the required information concerning their child.
• Additionally, SUBSECTION G.4 -   "A description and time of bowel movements." Please clarify the term "DESCRIPTION" 

Section J. 1-2. "...provide to parents of children, at least semiannually..."

    1.  "Written information about their child's development, behavior, adjustment. and needs.."   

     * A) Notations concerning development are included in each child's semi-annual assessment.

     * B) Behavioral and Adjustment - again, assuming the child has behavioral issues - this should be discussed in person - not be addressed on a piece of paper and handed to a parent.

             Respectively, "adjustment" issues concerning a child is not productive when presented in written form. 

    2. "Scheduled opportunities for parents to provide feedback.....this opportunity..... shall be documented."

      * Unnecessary.  It is highly unlikely any center in the Commonwealth is unwilling and unavailable to schedule a time to meet with parents concerning any aspect of any child enrolled in their care.