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 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.  Parents have D.O.E. contact information where they can report incidents or injuries which occurred while their child was in 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?