With a background in early childhood education (PhD in Human Development and Family Studies), I feel it is my responsibility to respond to these changes. I feel these changes are not only appropriate but necessary. I would like to address several specific changes, including staff training, group size, director qualifications, and increased space requirements. It is well known that while childcare of poor quality is associated with poorer developmental outcomes, high-quality care is associated with outcomes that all parents want to see in their children, ranging from cooperation with adults to the ability to initiate and sustain positive exchanges with peers, to early competence in math and reading. The regulatory changes presented reflect what we would in the field consider characteristics of quality childcare.

The proposed changes highlight variables (e.g., the quality of child-caregiver relationship and the structural features of care) that have previously been examined in studies of childcare quality. First, we know that skilled/trained and stable childcare providers are necessary to promote positive development. Well-trained staff/providers are more likely to provide ample verbal and cognitive stimulation, be sensitive and responsive, and take part in more appropriate and engaged interactions with children in their care.

The ratio of children to caregiver has held up over time as one of the most sensitive indicators of quality care in all settings. The decrease in group size for two- and three-year-old children is in direct accord with ‘best practices.’ It is well known and accepted that “even small improvements in ratios and education are reflected in more sensitive, appropriate, and warm care giving, suggesting useful targets for investments in quality” (From Neurons to Neighborhoods, 2000, pg. 318).

Having taught future child care providers/directors/owners at a four-year higher education institution, I know how important it is for directors to have the appropriate managerial background to run a successful child care program. While most directors have the child development background necessary to meet the needs of the children in their care, some do not have the managerial skills necessary to plan and manage a budget and staff. These managerial skills may help decrease staff turnover, find external funding, maintain budgets, etc.

Lastly, the increase in space supports well-accepted research and theory (e.g., Piaget, Montessori) that children need adequate space to explore their world cognitively and physically. Young children learn through exploration and manipulation, which necessitates adequate space. Thank you for giving me the chance to comment and I hope my remarks can be helpful in the regulation process.