Virginia Regulatory Town Hall
Agency
Department of Social Services
 
Board
Child Day-Care Council
 
chapter
Standards for Licensed Child Day Centers [22 VAC 15 ‑ 30]
Action Revision from Periodic Review
Stage Proposed
Comment Period Ended on 1/2/2004
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12/30/03  12:00 am
Commenter: Tonya Hawker

Proposed standards for licensed child care centers
 

 

I am writing in reference to the changes being proposed for licensed day care providers.  I feel that some of the proposed changes are unfounded, and as a result, will negatively impact the children of this community, rather than improve childcare conditions.  Listed below are my concerns:

 

1-      Square Footage Increase Per Child

Currently, the amount of required activity space per child is set at 25 sq. ft.  Your proposal to increase the space by an additional 10 sq. ft. will result in drastic ramifications for my child’s daycare facility.   I have a wonderful childcare facility that is managed extremely well.  I wouldn’t want my child to be anywhere else.  I tell you this because this increase in square footage forces my child care facility to take extreme measures to remain open (i.e. significantly increasing internal expenses to fund for additional staffing and building expansions).  These costs will force my day care facility to make 1 of 2 choices-
            1- Close their doors

2-Pass the significant expense, associated with the increase in activity space per child, on to the parents. 

Council members, the parents already pay an enormous amount for child care expenses as it is.  And furthermore, I just DO NOT see how a 10 sq. ft. increase in activity space per child justifies the additional costs that the parents must bear.  I feel strongly that it is not a matter of square footage that makes a good child care facility.  It is how a director manages that space that is important.

 

 

2-      Decreasing the Staff-to-Children ratios

This proposal falls into the same opinion I have as noted above.  I feel that the current staff-to-children ratios are sufficient as they are.  What is important is how the day care director manages the staff and children.  Just adding an additional staff body is not what is important, and the additional expense involved in adding additional staff is not justified as a requirement for day care facilities.  How the staff is managed should be of more importance to this council.

 

3-      Requiring an additional staff-member to ride-along with a driver when 16 or more children are being transported in a vehicle.

My question here is this-  If school buses don’t need an additional person, why should child care centers need to have additional staff on the van.  In fact, day care centers have shorter routes to/from schools, seat belts and less children are on their vans then on regular school buses.  I feel my children are safer on the day care van with 1 driver than they are on our public school buses.  Again, I feel the focus should be on management of staff and children.  The easy way out of this situation is just to “add another person”.  HOWEVER, that is not the RIGHT ANSWER.

 

4-      Required Training

The proposal to require a LPN nurse to provide annual training to staff members regarding the observation of children’s health conditions is well noted.  In this situation, I feel that annual to bi-annual training would be appropriate.  In addition, I feel this, as well as additional child care training, should be offered by the state rather than passing the training expense on to the child care facility (especially through the use of an outside source). 

Please understand that I am all for additional training, but according to the standards, additional training is necessary at my day care’s expense, and appropriate/necessary courses such as CPR/First Aid, Health Screening and Medicine Administration will not even be counted as applicable credit toward the annual training requirements.  What exactly do you want in the form of annual additional training?  Again, this goes back to my point that the state should offer a career development plan with applicable training, that meets state guidelines, rather than regulate ineffective standards that do not benefit the child.

           

Let’s face it, it is unfortunate that a large proportion of child care staff are highly underpaid.  The fact that they take care of our children day in-day out should be reason to give them more training and higher wages for this type of career.  It would be much more prudent, in my opinion, to offer a state program that appropriately trains staff members to be “good” child care providers, rather than mandate irrelevant standards on day care facilities that really will not help the children of this community.  Here, dear council members, is where I believe your focus should lie.

 

Thank you in advance for hearing my views on this matter. 

 

 

CommentID: 73