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The table below shows comments received at this web site about the following rule:

New Licensing Rules
Family Engagement sections of aligned licensing rules that will replace current center and family home child care rules, chapters 170-295 and 170-296A. Weights that appear with the rules are only informational ... there is more work to be done before weights are finalized.

DEL uses these comments, and other input during the rule making process, to help us write and adopt the permanent rules. For proposed rules only, DEL will prepare one response to all of the comments received, in what is called a “concise explanatory statement” required by RCW 34.05.325. The department sends the concise explanatory statement to everyone who commented or testified on the proposed rule, and to anyone who asks for it.

Agree/Disagree: Disagree

Comment: We do most of these things in the course of discussions and parent teacher conferences. But to have it in the WAC and include mandated topics is an administrative nightmare. Please provide packets or templates for the information you expect us to share.

Date Submitted: 6/27/2018 10:22:03 PM

Agree/Disagree: Disagree

Comment: Overall, I oppose the draft version of the standards alignment for the following reasons: They are unduly burdensome, They are difficult to navigate, They stifle cultural and economic equity, They may push providers and members of the current workforce who have proven competency via Early Achievers or other assessment systems out of the field because of the set professional development requirements without a clear equivalency pathway, The economic impact (particularly true of the standards related to professional qualifications, furniture and facilities) will inevitably raise the cost of care to Washington families without a clear route to how the standards improve child outcomes. Combined, these factors threaten to push early learning sites out of the field at a time when many areas are already struggling with a shortage of early learning programs. The providers most impacted by these pressures are those serving low-income and diverse populations who already operate on thin margins with extremely limited resources. We do not need someone to regulate our every move. We know how to run our own businesses.

Date Submitted: 6/27/2018 9:48:48 PM

Agree/Disagree: Disagree

Comment: Overall, I oppose the draft version of the standards alignment for the following reasons: They are unduly burdensome, They are difficult to navigate, They stifle cultural and economic equity, They may push providers and members of the current workforce who have proven competency via Early Achievers or other assessment systems out of the field because of the set professional development requirements without a clear equivalency pathway, The economic impact (particularly true of the standards related to professional qualifications, furniture and facilities) will inevitably raise the cost of care to Washington families without a clear route to how the standards improve child outcomes. Combined, these factors threaten to push early learning sites out of the field at a time when many areas are already struggling with a shortage of early learning programs. The providers most impacted by these pressures are those serving low-income and diverse populations who already operate on thin margins with extremely limited resources. We do not need someone to regulate our every move. We know how to run our own businesses.

Date Submitted: 6/27/2018 9:44:46 PM

Agree/Disagree: Disagree

Comment: 0080 This is an Early Achievers requirement. Not all providers are participating in EA and should not be required to do this. Where will this form be available? 0085 Where are these forms available and resources? 0085-4-a-i This is an ECEAP standard and should not be required as a baseline WAC. Parents have been known to withdraw from child care when providers suggest a child may need help in a developmental domain such as social/emotional. We are not health practitioners and should not be suggesting screenings for any particular health issue. This should be addressed by the child’s health care professional.

Date Submitted: 6/27/2018 12:31:31 PM

Agree/Disagree: Disagree

Comment: Again, who is paying for these requirements and do the parents want "support" which may be considered a violation of their privacy rights? They may resent being parented by their children's providers, undermining the relationship between parents and providers. Providers must take time from other aspects of their business or take time away from their own families. Providers should not function as social workers or therapists.

Date Submitted: 6/26/2018 9:37:04 AM

Agree/Disagree: Disagree

Comment: This is not for family childcare. My clients/parents bring their children according to their childcare needs. Some come in right before lunch and pick up during outside time after nap. They bring their children 1 -5 days a week. They need affordable childcare not preschool. My private business shouldn't be required to do developmental goals or encourage regular attendance.

Date Submitted: 6/26/2018 9:02:53 AM

Agree/Disagree: Disagree

Comment: How did we get from licensing and certifying for the health and safely of children in out of home care to "foundational standards" with an incredible increase in the direct costs, administration, and bureaucracy of child care? This is such a regulatory overreach and an attempt to alter reality for families who are simply trying to have their children taken care of by loving, responsible providers at a cost they can afford. The state wanting to build a system and expand its prestige doesn't change the economic realities of parenthood.

Date Submitted: 6/25/2018 4:56:07 PM

Agree/Disagree: Disagree

Comment: P. 14 – WAC 170-300-0080 – Family support self-assessment ECEAP programs include a strong family support component with designated staff members who regularly meet with families. Request permanent waiver.

Date Submitted: 6/12/2018 11:58:07 AM

Agree/Disagree: Disagree

Comment: WAC 0340 Expulsion. We have the right to refuse service to anyone just like the local restaurant. Two things will happen if DEL insists on this WAC. First, the month before the WAC takes place, there will be many expulsions. Providers who have been working with parents on a behavior will just throw in the towel early so they don't have to jump through this one more hoop. Second, expulsions will continue. Providers will just not address the "behavior" with the parents, and when they've had enough, they will terminate the parent instead - for something as simple as being 2 minutes late. Meanwhile, the child looses because the provider won't want to openly address any behaviors for fear of being entangled in this WAC. The children are the losers here.

Date Submitted: 6/12/2018 11:26:43 AM

Agree/Disagree: Neutral

Comment: I think the state should provide any documents they expect providers to share with the parents.When I took the QRIS classes-the one on Family engagement in particular-I was struck by how much as a provider my teachers and I were supposed to listen to, support etc. the parents emotional state. My minimum wage teachers who have their own life struggles are not here to council or engage adults who make their own life choices. I do however, expect them to communicate with parents on behalf of the children. I expect conversations to focus on the needs and gifts of the child only. I agree that a yearly assessment to share with the parents and even at least one to two yearly offerings of parent meetings is necessary. We should provide developmental profiles(simple ones) and encourage parents. We should also expect the state to hold parents accountable to follow through on parenting responsibilities. We are not the parents-we are teachers.We are here to support the children.

Date Submitted: 6/8/2018 2:54:05 PM

Agree/Disagree: Disagree

Comment: You are asking us to interfere too much in the lives of clients and their children. Yes, if a child is in danger, I will report it. Yes, I will suggest programs to help a parent if their child may need it. But, the way these rules are worded indicates a Big Brother mentality in which I the provider am supposed to educate the parents in a rather obtrusive manner. This will cause many of them to change childcares frequently. It's better to develop a friendship and trust and then work together for the child. DEL is pushing the boundaries of what is morally and professionally right.

Date Submitted: 6/6/2018 4:16:17 PM

Agree/Disagree: Neutral

Comment: I agree with the rule changes except for the following: 170-300-0085 (2), (3), (4a) The department should provide a template document that can satisfy the information in these sections in order to support providers in obtaining the information needed to meet these requirements. 170-300-0085 (4)(c) Contact information for who? The center? The director, specifically?

Date Submitted: 5/20/2018 1:25:17 PM

Agree/Disagree: Disagree

Comment: Maybe the State can mandate DSHS families attend some parenting classes DSHS put on during their after hours. leave us alone!

Date Submitted: 5/18/2018 3:20:51 PM

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