22VAC40-211-70 D This requires access to a working telephone.  Should not there be a telephone in the home (as opposed to next door or down the stairs)?  And will a cell phone meet this requirement?  If a cell phone is allowed, what happens when the cell phone is taken away from the home with its owner, while a caretaker at home with the child has no phone, or when the cell phone no longer has a charge or drops and breaks, etc? 

22VAC40-211-80 F  If a provider regularly transports the child...The requirement for a valid driver's license and liability insurance should exist no matter how often a provider transports a child.  Indeed the same requirement should be for any substitute care provider who transpsorts the child including teenaged members of the household, relatives, neighbors, friends.

22VAC40-211-100  B5  Requires reviewing confidentiality and corporal punishment requirements and completing new agreements seems redundant.  Why not just complete new agreements.  In the process of completing them, a review of the provisions must be read and signed.