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

New Licensing Rules
Interactions & Curriculum 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: If it's not related to the Health and Safety of children, the state needs to leave curriculum choices to the individual providers and parent choice. These new over-regulatory WAC's are burdensome and negatively impact the cost of providing services with no clear connection to child outcomes.

Date Submitted: 6/27/2018 9:42:38 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 9:42:21 PM

Agree/Disagree: Disagree

Comment: INTERACTIONS AND CURRICULUM WAC 170-300-0300 Individual care plan. If you implement this WAC as written, no one will take these kids, especially at state rates. This is a major increase in work for kids that may only be getting speech therapy 20 minutes a week. WAC 170-300-0305 Curriculum philosophy and planning. Are you looking for a multipage dissertation or a paragraph? The WAC reads like a dissertation. The following WACs are over reach the DEL and should be left to Early Achievers ratings. I believe enforcement of these WACs will be highly problematic and subjective. DEL Licensors don’t have the time or expertise to adequately administer these proposed WACs. I agree that these are best practice, which changes all time. Codifying them in a WAC will not allow for timely changes that will need to take place to keep up improved understanding of children’ growth and development. (How long did it take to get syrup of ipecac out of first aid kits?) WAC 170-300-0310 Concept development and feedback quality. WAC 170-300-0315 Language modeling and reasoning. WAC 170-300-0320 Facilitating child interests, learning, perspective, and productivity. WAC 170-300-0325 Creating a climate for healthy child development. WAC 170-300-0330 Positive relationships and child guidance. WAC 170-300-0335 Physical restraint. (2)(d) Only performed by early learning providers training in… “training” should be “trained”. WAC 170-300-0340 Expulsion. (4) The early learning provider must report to the department when children are expelled. Why? What is DEL going to do with this information? PROGRAM STRUCTURE AND ORGANIZATION WAC 170-300-0357 Center mixed age group capacity, ratio, and group size. I found this section to be confusing. So, DEL will be allowing mixed age groups during the full day?

Date Submitted: 6/27/2018 9:40:44 PM

Agree/Disagree: Disagree

Comment: 0305 this is an Early Achievers standard. It should not be required of providers who are not a part EA. This is too prescriptive and has the potential of creating an employer/employee relationship with DCYF. 0310 this is another EA standard (CLASS). Mandating EA for all programs does not make it a voluntary program. If a parent/family is paying for their own child care they have the right to choose a provider not enrolled in EA. If DCYF is going to mandate EA they need to pay all providers the tiered reimbursement and yearly grant. They must make available all resources that EA participants are given. This also has the potential of creating an employee/employer relationship. 0315, 0320 these sections are too prescriptive and are mandating EA standards. See previous comments.

Date Submitted: 6/27/2018 8:13:09 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.

Date Submitted: 6/27/2018 6:35:05 PM

Agree/Disagree: Disagree

Comment: 0265 #8 This wac should be sufficient. #8a should not be required. This will limit a provider the amount of children they can offer care to, or could close fcc due to not enough space between mats. Please keep just #8.

Date Submitted: 6/26/2018 2:50:07 PM

Agree/Disagree: Disagree

Comment: Providing additional person when doing water activities will cause a lot of family provider to stop water play. This is an unrealistic requirement. The outdoor play requirement is unrealistic for winter. 30 minutes a day is all that should be required. More outside time could be suggested but not mandated.

Date Submitted: 6/26/2018 10:05:20 AM

Agree/Disagree: Disagree

Comment: Family Childcare is childcare not preschool! We should not be required to do the curriculum piece. We are private business' that parent choose to care for their children and provide a loving nurturing, and safe environment. DEL/DCYFS should get back to WACs that are for Safety and health and stop trying to make us little Head Starts. Family childcare providers already work 10-12 hours a day with children plus the time it takes to do all the cleaning required then add the meal planning shopping for supplies. How do we have time for all the curriculum planning you want us to do? Many Family childcare providers have their own children at home, they need family time.

Date Submitted: 6/26/2018 9:54:03 AM

Agree/Disagree: Disagree

Comment: WAC 0340 Expulsion. This is a personal matter between parent and provider. It is not something that should be monitored by DEL. We are private business owners and have the right to exclude children who do not fit in our program, or are disruptive or harming other children in our care. Some children just need a different environment or more supervision or individual care. All children do not fit into the same mold.

Date Submitted: 6/25/2018 11:12:55 PM

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 4:54:29 PM

Agree/Disagree: Neutral

Comment: I am happy to see that it is giving a little more flexibility for long time providers who may want to concentrate on the very young group of children enabling them to have 4 under 24 months. However, going back to 2 year old's instead of 18 months is certainly a step backwards and is going to make it difficult once again for people to find spots for licensed daycare. I already have people waiting for their child to turn 18 months old so they can join their sibling. I guess they will have to remain in unlicensed care for another 6 months if this proposal goes through.

Date Submitted: 6/25/2018 3:36:25 PM

Agree/Disagree: Disagree

Comment: 0360 (c) For family home child care, how are we expected to keep some kids outdoors for 20 minutes and others outdoors for 30 minutes if we are working alone? Even if we stand right in the doorway that does not make us available to handle a situation that may occur inside or out. This is a classic example of rule makers not being able to relate to the challenges they are placing on home providers.

Date Submitted: 6/21/2018 5:38:49 PM

Agree/Disagree: Disagree

Comment: 0355 8(a) Working alone a provider with less than one year of experience can have 6 children with up to 3 children under the age of 2 as long as one can walk independently. That is a handful. I have had an infant that started walking at 7 months old and was very independent by 10 months of age. So theoretically this new provider could have 3 children under the age of 12 months. Yikes. 10 It seems to me that there is a piece missing in the proposed capacity. I do not see what ages a provider can have working alone with 8 children. Should there be a category that says they may have 8 children with a maximum of 4 between 2 and 3 years old or something to that effect?

Date Submitted: 6/21/2018 5:27:03 PM

Agree/Disagree: Disagree

Comment: I would like the ones making the rules to please visit the centers and see it from out point of view. Come and help us see how it is to try to implement these rules give us suggestions and feedback.

Date Submitted: 6/20/2018 9:50:38 AM

Agree/Disagree: Disagree

Comment: LET CHILDREN BE CHILDREN--- DO NOT FORCE THEM ANY STRUCTURED ENVIRONMENT... provider know their children in care better an what is best for them to learn. one side you say PLAY is most important and other side you gave curriculum that children are forced to follow--- does not make any sense..... provider can give best environment for children to learn through play NOT curriculum

Date Submitted: 6/13/2018 2:18:32 PM

Agree/Disagree: Disagree

Comment: P. 170 WAC 170-300-0335 Physical restraint 5a. Regarding notification to DEL – request variance. Notification within 24 hours seems like a tight timeline. Could guidance be to report to program manager and ECEAP contractor within 24 hours? P. 170 WAC 170-300-0340 Expulsion ECEAP standards require a no expulsion policy. Is this changing with these WACs? Otherwise, adjust language to be inclusive of ECEAP requirements in order to limit confusion on the ability of ECEAP programs to expel children. P. 172-175 WAC 170-300-0345 Supervising children • 1. Regarding who should have unsupervised access to child – expand to include that in a school district, staff with a legitimate educational purpose/reason for interactions with the child (such as the SLP, itinerant special education teacher, health room attendant, school nurse, principal or counselor) should also be allowed this access to the child. As a part of the school district, the requirements for unsupervised access to the child need to match the requirements from OSPI and the school district. • 5b.vi – Are school buses considered public transportation? If so, how is “actively supervise” children defined? We do not have the capacity to add a second person to buses for supervision. OSPI requirements for preschool age students receiving special education services are okay with one driver. ECEAP requirements for programs located in a school district need to match/follow the OSPI requirements. P. 178 WAC 170-300-0354 Indoor early learning program space capacity • 2c. Does this mean that 2 feet around any handwashing sink cannot be counted in square footage calculation? If so, we’ll likely need a waiver on square footage requirements for our portable classrooms that are tight on space as it is. • 2g. To operate a high-quality program, many materials, supplies, etc. are required. Classrooms have considerable space and storage issues as it is. I’m concerned about taking these out of square footage calculations (especially if they are under a countertop or still create usable space for student activities). We simply do not have the facilities available to store materials and supplies outside the classrooms. P. 185 WAC 170-300-0356 Center capacity, ratio and group size • How does this related/affect/connect with district facilities/space regulations from OSPI? • Would gyms, playgrounds, courtyards, libraries, cafeterias, and other travel paths, etc. need to be licensed/certified? • 2f. How do subs play into this? We access district paraeducator substitutes. Removing this as an option for subs would SIGNIFICANTLY impact our ability to gain coverage when staff are absent. • 3. Request waiver - Transportation is not provided by early learning program staff, but by school district/transportation staff or approved transportation contractor – regulated by OSPI. Ratios during transportation do not meet these requirements. • 4. Request waiver – Cannot meet ratios during transportation. This would be a major financial constraint in order to meet ratios for the MANY buses that provide services to ECEAP. Buses meet OSPI regulations for transportation of preschool age students. • I won’t be sending this one in my online feedback, but this is a question for you all ? How do these ratio requirements, space requirements, etc. impact family nights that provide childcare? P. 193 WAC 170-300-0360 Program and daily schedule 2c.ii – Request variance. This does not align with ECERS requirements which is 25 minutes for a 3 hour program (21 minutes for 2.75 hour program). Time is already VERY limited in programs and every minute counts. We want to have time to have an extended free choice to ensure we meet ECERS requirements for substantial portion of the day.

Date Submitted: 6/12/2018 12:04:03 PM

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 11:25:42 AM

Agree/Disagree: Disagree

Comment: Disagree. This is a free country and we should be able to have whatever curriculum works best with our daycare environment. It should not be mandated what we can and cannot do.

Date Submitted: 6/8/2018 12:46:36 PM

Agree/Disagree: Disagree

Comment: Each Family Childcare should be able to decide how they will provide for the families that CHOOSE their program. My families chose our childcare because of what we have to offer...not what DEL decides is right for us. You are taking choices away from the business owner and the parent. All children are not the same. All programs should not be the same. This is NOT a 'one size fits all' business.

Date Submitted: 6/7/2018 9:15:43 PM

Agree/Disagree: Disagree

Comment: I am to report anytime I expel a child from my program? I reserve the right to let go of any child I deem necessary. Now, in 35 years I have only let go of three kids, so this isn't something I do and the last the child was ten years ago. But, I am a self-employed business and some of the rules DEL is trying to shove down our throats may not even legal. There may be lawyers involved. I am self-employed and as long as children are safe and I have no problem with those rules, then it is not DEL's business if I let go of a client or not. And you want us to learn about play? My childcare is all about play, always has been. Curriculum is not what is needed, especially before the age of 5. A children should be allowed to explore and play all day long if necessary to what makes his/her brain feel good. I am a veteran of childcare and tomorrow I could put out an all-call to former parents and there would be 50 of them writing or standing behind me in a court of law if necessary. Really, give this up!

Date Submitted: 6/6/2018 4:11:21 PM

Agree/Disagree: Disagree

Comment: every program or business should be able to decide what they are going to teach or "service" they are going to provide.

Date Submitted: 6/4/2018 12:42:02 PM

Agree/Disagree: Neutral

Comment: 0356- Center capacities: It was my understanding Montessori programs were allowed to have a separate ratio/capacity and group size based on the type of program they provide. I do not see a separate section in regards to Montessori capacity, ratio and group size.

Date Submitted: 5/29/2018 9:20:26 PM

Agree/Disagree: Neutral

Comment: O agree with much of this proposed WAC, however, more clarification is needed on what "water activities" means. I am desparately hoping that a 1:1 staff to child ratio for infants is NOT needed to simply sensory play with water. If so, infants will never have exposure to this important sensory activity, as a 1:1 ratio is never yoing to happen.Sad. Likewise, parent/guardian permission required for water play is excessive and bizarre.

Date Submitted: 5/24/2018 3:01:25 PM

Agree/Disagree: Neutral

Comment: I agree with the rule changes except for the following: 170-300-0305 (1) “Curriculum philosophy” should be titled “Early care and education philosophy and planning” in order to include an emphasis on the care that is needed to support early learning development, not just a focus on what is “taught”, which is what a curriculum is for. “Planned daily activities” for young children need to be focused on responsive care and high-quality interactions and the title “curriculum philosophy” gives the impression that the “activities” should be academically driven. 170-300-0305 (4) An amount of time needs to be defined here, otherwise it is left to interpretation. There needs to be a minimal amount of time required, such as one hour per week. 170-300-0356 and 170-300-0345 (2)(a) Need to allow for larger group sizes on a large outdoor area. More than two groupings should be allowed as long as the teacher to child ratio is met and the required square footage determines the maximum number of children allowed in the outdoor space at one time.

Date Submitted: 5/20/2018 1:24:18 PM

Agree/Disagree: Neutral

Comment: LOOKS like WAC is forcing childcren to learn through curriculum--- As a home child care prrovider I can create better enviernment for children to learn through their own space NOT by doing curriculum activity- NOT all child learn same- EACH child is unique and same curriculum cannot provide same support

Date Submitted: 5/18/2018 2:22:30 PM

Agree/Disagree: Neutral

Comment: most of changes are feasible on ceters BUT not home child care---- please whatever decision making---- make it different for Homechild care---- ITS someones home they are opening to build future---- please understand their needs

Date Submitted: 5/18/2018 2:16:35 PM

Agree/Disagree: Disagree

Comment: I am concerned with the depth of knowledge displayed by this entire section. There is no such thing as a "curriculum philosophy." "Philosophy of Education" is different than "Philosophy of Learning" is different than "Philosophy of Teaching," HOWEVER, there is no such defined term as "curriculum philosophy." This is because "curriculum philosophy" is a contradiction. Curriculum is the means by which your philosophy is executed, and cannot therefore be both. There are extensive portions in this section that are biased toward academic philosophies of education. Please email me directly for specific WAC highlighting, as there are too many philosophical biases to include specifically.

Date Submitted: 5/15/2018 7:27:27 PM

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