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

New Licensing Rules
Professional development 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: The state is interfering at a level that goes way beyond regulating to ensure the children are in a healthy and safe environment. Furthermore, the state is granting access for the colleges to dictate that the employees of this industry be forced into the college system. At whose expense? Sure, EA may have some scholarship dollars, but not enough. AND what about those that are not interested in attending college? Well, the parents and children will lose out on their trusted caregiver who will have to leave the industry. The centers will lose employees - who will replace everyone that chooses to leave and find work that doesn't force them to spend evenings taking college classes?? There aren't enough people entering this workforce as it is - now they'll be told they must be on a professional development plan with college on the horizon?? No - they'll just go work in another industry. It may be less fulfilling for them, but it pays the bills.

Date Submitted: 6/27/2018 9:54:53 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 9:36:10 PM

Agree/Disagree: Disagree

Comment: Centers must be allowed to continue on-the-job training for Assistant teachers, with no college requirement. These employees work directly with a qualified LEAD teacher. Early Childhood Core Competencies can be acquired through ongoing STARS training provided by community providers, like the Early Learning Action Council who does an excellent job of providing engaging and relevant content.

Date Submitted: 6/27/2018 9:21:06 PM

Agree/Disagree: Disagree

Comment: Directors and administrators support the education goals staff members have chosen to pursue. The state should not be FORCING staff into the college system if they are not interested in that path for themselves. Entry level (assistant teacher) positions are critical in this under-valued industry. Some assistants work towards career advancement, while others are content to remain an assistant - AND THEY SHOULD BE ALLOWED TO DO THAT.

Date Submitted: 6/27/2018 9:14:41 PM

Agree/Disagree: Disagree

Comment: Requiring all staff attend college level classes, without ANY funding for non-EA participating employees places the financial burden on those currently qualified staff members who in many cases have YEARS of relevant training and experience that make them valued members of the Early Childhood workforce. State agencies seem to have a bias against providers that have opted to not participate in Early Achievers, when the biggest reason providers give is budgetary issues with accepting the lower subsidy rates. There is NO funding for those employees.

Date Submitted: 6/27/2018 9:05:01 PM

Agree/Disagree: Disagree

Comment: The Professional Development requirements will 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.

Date Submitted: 6/27/2018 8:59:01 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 6:33:59 PM

Agree/Disagree: Disagree

Comment: 170-295 and 170-296A Another example of increasing the minimum education requirements for ECE workers but doing nothing to raise pay. Our program relies on student and part time staff to not only meet ratios and provide time outside of the classroom to the lead and assoc teachers to do planning, but to also provide an enriched and high quality program. The pay should match this. Students and part-time workers do not have the time and money to go out and get degrees. Why isn't one of the licensing requirements to pay teachers 6 figures - a salary they earn and deserve!

Date Submitted: 6/27/2018 4:26:34 PM

Agree/Disagree: Disagree

Comment: WAC 170-300-0100 General staff qualifications. ECE requirements. Teacher and Assistant Teacher required to earn an ECE initial certificate & ECE short certificate within 5-7 years. I polled my staff of 17 and only one would be willing earn these college credits for a job that only pays minimum wage. Two-thirds of my Center’s income comes from WCCC. Without a significant increase in State rates and an increase in who qualifies for WCCC, I will never be able to pay more than minimum wage or just above it. My staff also had concerns of who would pay for this. I cannot afford to pay my staff’s tuition nor can they afford to pay the tuition. Nor is the State likely to provide enough scholarship funding to pay for over 3,269 providers who don’t have the ECE educational requirements. Also with the rate of turnover in childcare employees (also related to low pay) this would effectively be a meaningless requirement and only penalize those who find this field to be a calling. I have taken ECE classes from my local community college. I was very disappointed in the quality of the teaching and the educational experience. WAC 170-300-0107 In-service training. (1) (a) enhancing quality of early learning (EQEL) What is this? I was unable to locate this on any of DEL’s websites.

Date Submitted: 6/27/2018 3:27:46 PM

Agree/Disagree: Disagree

Comment: I just believe these new changes will lead to the demise of the Early Childcare Profession as we know it. I have been in the field for 38 years. I think there will be many folks that are well qualified lead and assistant teachers that will leave the field, because they will no longer meet the standards. This is a real pity to see all of their hard work for many years go to waste. Where will this leave our children.

Date Submitted: 6/27/2018 12:58:18 PM

Agree/Disagree: Disagree

Comment: 0100 Within this document there is not matrix for equivalencies. The public cannot clearly make comments on something that is not published in this proposed WAC. The equivalencies need to be included for this public comment. 0115-1-b It states that paper records can be discarded once documentation is entered into MERIT. However, in 0115-1-d it states that these records must be kept on site. This is confusing and needs to be rewritten. 0120-1-a In a Family Home program staff personal belongings would all have to be kept in a locked area. This is impossible. These are our homes and there are personal items everywhere. This is why the definition of inaccessible needs to be amended. Lead teachers in a Family Home program would possibly need to leave licensed space to access their personal belongings, which would result in a program being out of ratio.

Date Submitted: 6/27/2018 12:36:28 PM

Agree/Disagree: Disagree

Comment: For childcare facilities finding and retaining staff is difficult, those of us that operate in rural communities this proves to be even more challenging. We are concerned that there has not yet been made available either a definition of equivalency measures for teacher training and requirements. There are many highly skilled, long term childcare providers whom will be deemed ineligible based on the new regulations, without providing for equivalency. Losing experienced providers in an already under supplied industry will only further exacerbate the issue. Further, the identified path towards meeting the requirement is also problematic, especially for rural areas. There is not enough existing capacity, some of the required trainings don't yet exist or are offered in locations that are difficult to access, and the cost of achieving the required level of training is a significant deterrent.

Date Submitted: 6/27/2018 12:24:55 PM

Agree/Disagree: Disagree

Comment: It is unbelievable to me that the lowest paid workers in the state, who are living in poverty as is, would need to take on the financial burden of obtaining additional training and education when college credits already taken are not considered valid and there is no proposed funding for these classes nor opportunity to be paid more. Whomever wrote these policies should be ashamed of themselves and I am horrified and embarrassed that it is even necessary for me to leave a comment for this.

Date Submitted: 6/27/2018 11:14:47 AM

Agree/Disagree: Disagree

Comment: WAC 300-170 Definitions. The definition for a "toddler" and "preschooler" in this document do not match Caring for Our Children 3rd edition or Caring for Our Children Basics. These documents which describe best practices for health and safety in early learning settings define a toddler as a child 13-35 months of age and a preschooler as a child 36 months- 5 years of age. The definitions described in WAC 300-170 are used to determine adult-child ratios which then do not support the safety of young children in early learning. Adult-child ratios are the most important factor in assuring the health and safety of young children in early learning settings.

Date Submitted: 6/27/2018 9:45:37 AM

Agree/Disagree: Disagree

Comment: What a shock, Washington State is putting the burden of some poorly thought out initiative entirely on the backs of low wage, largely female workers. Glad that you have found yet another way to make children and the poor suffer in this state.

Date Submitted: 6/27/2018 5:33:42 AM

Agree/Disagree: Disagree

Comment: Without any provided funding for these classes or an expansion of the public college infrastructure, this just amounts to a giant hand-out to for-profit online colleges. These schools have shown little efficacy as far as training goes, but have been able to use their ill-gotten money to influence plenty of state legislators and bureaucrats to force their classes on others. Childcare workers are extremely poorly paid already, don't steal money from them just to give it to online universities that already make huge profits.

Date Submitted: 6/26/2018 6:47:51 PM

Agree/Disagree: Disagree

Comment: This is an intolerable burden to place on some of the lowest paid workers in the state. If you want to pretend you actually care about early childcare and education why don't you work on increasing childcare workers' wages and increasing state funding to childcare generally to make it actually affordable. It should be a scandal that childcare workers are paid so poorly that they can't afford childcare for themselves. Higher wages and better benefits would go a lot further to improve early childcare than 12 credit hours.

Date Submitted: 6/26/2018 6:21:07 PM

Agree/Disagree: Disagree

Comment: 170-300-001 Professional Development, Training and Requirements The short version: DEL proposes retraining or replacing the entire child care work force in the state. All lead and assistant teachers will have to have an initial ECE certificate (12 college credits) within five years, leads will need a short certificate (8 additional credits) two years later, in order to continue working in the field. CDAGS is concerned that this proposal and its ramifications have not been well thought out and will push many child care providers to leave the field rather than enroll in college level courses to prove they are qualified to do the work that they already do well. I agree with CDAGS on this issue. In an industry that struggles to maintain experienced, qualified staff, we cannot require more and more education in order to keep our schools open. Perhaps there can be a way to allow current, successful teachers to continue, while gradually increasing education requirements for those entering the field. I think there needs to be more time and discussion on this point. Thank you Lisa Lukas Director UW Children's Center at Radford Court

Date Submitted: 6/26/2018 3:51:18 PM

Agree/Disagree: Disagree

Comment: I have been teaching for over 33 years at the same school. My best staff may not have their degree, but they have the experience. I have had staff that come with their degrees. That need to be taught what the real world of childcare is. They can have their paper degree. Give me a staff member with experience any day. DEL needs to stop with all the rules and paperwork. It is killing our love of teaching the children. Give us back our time to do this.

Date Submitted: 6/26/2018 2:58:23 PM

Agree/Disagree: Disagree

Comment: 170-300-001 Professional Development, Training and Requirements DEL is proposing to replace or retrain the entire child care workforce of the state. Experience in the field will not matter. Consider the consequences of trying to require college level education of child care providers working for minimum wage throughout the state. Practically speaking, without government support for higher pay, these requirements will effectively shut down many home care providers and small centers, will leave child care desserts in some low population areas and will push providers out of the field. Once college education opens doors for employment child care providers classically leave the field for better pay. The real world consequences to this rule are less access to quality care and more expensive child care in general, which hurts children, especially those in low population areas or the state and families with low incomes.

Date Submitted: 6/26/2018 12:13:42 PM

Agree/Disagree: Disagree

Comment: While I am always for being more knowledgeable and trained, we do not get paid enough for this. Working in this profession already has a 5 year burn out rate because it is emotionally and physically challenging. When you aren't compensated correctly, it is easier to get an office job that will pay twice as much.It's hard enough to find good teachers and to retain the ones we have with the standards now and we pay for all the trainings necessary and work really hard to give them time on clock. I went to UW and got my degree for ECFS because this is my passion, but it put me in more debt than necessary to have a job I already had. If DEL is going to make more work, we need to then be compensated for that.

Date Submitted: 6/26/2018 9:38:55 AM

Agree/Disagree: Disagree

Comment: A commitment to transparency demanded the proposed required trainings and classes be fully developed and available for providers to review before these WACs were even proposed. Too many of them are not necessary for the safety and health of children in care and seem to fulfill some special interest;s political agendda or have economic incentives for training providers. As with every regulation, these impose time and money burdens on providers which must be passed on to families.

Date Submitted: 6/25/2018 10:41:17 PM

Agree/Disagree: Disagree

Comment: WAC 0180 Toothbrushing is very time consuming and can be unsanitary in large groups. This should be the responsability of the parents not the provider. Tooth brushing is not done at school while in K-12.

Date Submitted: 6/25/2018 10:32:45 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 4:52:48 PM

Agree/Disagree: Disagree

Comment: EQEL isn't necessary for Family home childcare. We are not preschool.

Date Submitted: 6/24/2018 4:35:28 PM

Agree/Disagree: Disagree

Comment: Will the prevention of exposure to blood and body fluid training replace our blood born pathogen training? Family childcare is in our home.

Date Submitted: 6/24/2018 4:32:16 PM

Agree/Disagree: Disagree

Comment: There are too many mandated trainings. I agree with first aid/ CPR and food handler's card. Safe sleep should only be once and updated when new information is given. Child abuse class should be included in the 30 hour class. An additional class on shaken baby seems over kill. Maybe combining it with safe sleep might work. Homeless children training seems to be unnecessary. Emergency preparedness training is a sore subject as our childcare association tried to get one approved with a qualified trainer and was shot down because it could be attained in the community. Now you are say we need to take yours. We don't need more online classes to take. A child restraint training isn't needed.

Date Submitted: 6/24/2018 4:30:33 PM

Agree/Disagree: Disagree

Comment: Family childcare shouldn't be mandated to provide Early learning curriculum or developmental screenings. Parents need and want safe, loving home environments when choosing us for childcare. These proposed WACs are taking the home out of childcare and making us Preschools. If parents wanted the early learning environment they would choose that. You are talking away the parent's right to choose what they feel is right for their children. Family home providers are also small business owner not DEL/DCYF employees. Majority are women. These WACs are taking away our ability to run our business with the philosophies we believe. Early Learning can't be legislated.

Date Submitted: 6/24/2018 4:20:47 PM

Agree/Disagree: Disagree

Comment: Family childcare homes are not Early learning programs. We offer early learning activities through our play based home environment. The ECE certificate/degree requirement is going to force a lot of experienced providers out and the childcare openings will decrease while cost increase. Parents already have a problem finding affordable childcare and these regulations will make it even harder for them. It will force parents to turn to unregulated and sometimes unsafe unlicensed care. A college certificate or degree doesn't mean better care. We have family childcare providers who have been in this business for 15 - 40 years and they are retiring because of these WACs. That is a lot of experience and expertise we are loosing.

Date Submitted: 6/24/2018 4:10:34 PM

Agree/Disagree: Disagree

Comment: Childcare is not part of K-12, but these knew requirements make it seem that the State is moving in that direction. As providers, we already have education requirements we must follow. We spend our days in the classroom with nights and/or weekends already being used to gain the required education. With the addition of MORE, where will the time and money come from? We have a difficult time finding/retaining employees because of the requirements to basically have a minimum wage job. From a Center standpoint, being mostly state subsidized creates a whole different situation. Minimum wage continues to rise, but what we receive per child remains the same. ' This whole situation is frustrating.

Date Submitted: 6/19/2018 11:15:36 AM

Agree/Disagree: Agree

Comment: You must add a path for curriculum to be approved so that those programs who have access to a nurse who happens to be a STARS trainer can teach these classes. It much more cost effective for large programs to hire someone to teach the class than it is for them to filter people through an online class. And, more learning occurs in person when the discussion and case studies can happen. And, for medication administration, when the participants can actually get their hands on the materials needed for proper medication administration. I taught safe sleep with the contents of your curriculum long before you implemented your online version. My class is great because we have the discussion and we talk about ways to help children sleep in group care who have been swaddled and co-slept at home. You must provide a way for those of us who do these trainings to get our curriculums approved.

Date Submitted: 6/19/2018 9:27:35 AM

Agree/Disagree: Disagree

Comment: WAC 170-300-0105 I feel the teachers do not make enough money nor do they have time to get a ECE. We work nine to ten hours a day and do our best to care for the children in our center. We only make minimum wage and we barely have time with our family let alone be in a classroom. We go through enough hoops to be a Child Care Provider. I do not mind doing the 10 hour annual classes and I did the 30 hour basic training last year. If you want me to do 20 annual classes fine, but please make the classes affordable.

Date Submitted: 6/13/2018 8:01:19 PM

Agree/Disagree: Disagree

Comment: people with NO DEGREE does better job than people with DEGREE-- real time experiance is more than degree- BE practical

Date Submitted: 6/13/2018 2:13:50 PM

Agree/Disagree: Disagree

Comment: P. 32 – WAC 170-300-0106 Training requirements • ECEAP is not child care. Modify Child Care Basics course to ensure relevance for ECEAP providers. • ECEAP staff will be unable to complete all of the trainings 4-10 prior to unsupervised contact with students. The following can be completed: o Recognizing child abuse/CPS reporting o Emergency preparedness – school district and OSPI training should also count toward this requirement. It is critical that staff know and understand the policies and procedures of the district, thus this should be the training they are required to complete, vs. a DCYF training that may not align with district policy. o Serving homeless students (depending on format of training – online or presentation provided by program manager will be do-able) o Medication management (depending on when the student enrolls who requires medication training) – training is provided by district school nurses when a health plan/medication authorization is needed. Not provided annually unless a student enrolled requires medication administration. The following cannot be completed prior to unsupervised contact: • Child restraint training – currently this is a two day training that staff complete during their first year working in ECEAP. Perhaps a refresher could be provided (or a brief video training), but requiring ALL staff to complete this two day training EVERY YEAR prior to classes beginning is unrealistic, due to financial, contractual and available work day constraints, as well as would impeded on staff members ability to conduct home visits and meet ECEAP standards regarding parent teacher contact and enrollment timelines. • Safe sleep training is not applicable to ECEAP staff and should not be required. • A variance may be needed re: a staff member having a CPR/First aid card prior to being alone with children. Staff are offered free CPR through the district, but staff must sign-up for the next available class, which may or may not be before they begin work with students. P. 36 WAC 170-300-0107 In-service training • What will EQEL training included? What will approved alternative trainings be? • Considering allowing district provided training (ie: PreK-K connection events) that are approved for STARS hours, count toward these training requirements. • B.ii.2 – requiring college courses again feels like a ploy to generate income for state colleges and postsecondary institutions. What funding will be available to support staff members/directors/etc. in meeting this requirement? Also, if we have to have principals as center directors, this is an unrealistic requirement for them to meet given the other requirements for PD they have to meet for their admin credentials. o This requirement, combined with the center director requirements re: on-site 50% of the time and the education/experience requirements, does not honor or acknowledge the diverse systems that support ECEAP within a school district to provide high-quality services to students that are aligned with the K-12 system. These requirements feel like they are trying to drive a wedge between ECEAP and the K-12 system and move us further away from alignment and enriched P-3 opportunities. Frankly, with these requirements, our district would not have the capacity to meet the center director requirements and would have to reconsider our capacity to provide ECEAP services within our district. I don’t think the intent of these WACs was to close ECEAP classrooms, but this could likely be the result of such requirements.

Date Submitted: 6/12/2018 11:48:45 AM

Agree/Disagree: Disagree

Comment: P. 20 – 27 – General staff qualifications – 3. Center directors or assistant directors •For ECEAP operating in school facilities, administration of ECEAP program is centrally managed. Site principals provide some support and oversight, especially related to emergencies, building procedures, etc. If central administration will not be “permitted” principals should be qualified as center directors. An OSPI administrative credential/certification should be sufficient for this. If they can run a P-5 school that includes preschool for children with special needs, they should be able to qualify as the center director for ECEAP without having to take additional classes/requirements. Also, considering the importance of P-3 alignment, principals are in a unique position when serving as center directors to support these efforts, an important consideration when evaluating a center director requirement. •For ECEAP, family support services are equally as important as early childhood education. Therefore, experience and education qualifications related to FSS services should also count toward center director requirements as ECEAP center directors/managers likely come from EITHER a FSS or ECE background, both of which are valuable experience for leading ECEAP programs. •Based on these requirements as written, very few ECEAP managers will actually meet these requirements, yet currently demonstrate the skills, knowledge and experience necessary to successfully operate and support program growth. Requirements need to be reevaluated to include the broad diversity of experiences that provide for successfully program management of ECEAP programs. •An OSPI teaching certificate (K-8, ECE or ECE special ed) should count toward education requirements. •Having met ECEAP credit requirements for instructor or FSS should be sufficient toward education requirements. •Requiring a specific degree/certificate feels like a ploy to generate tuition, revenue and income for state colleges. If such large changes will be required, provide full tuition/funding and paid release time for center directors to meet these requirements. •Provide more inclusive/descriptive information on what “equivalent” means. •Provide a provision for central management of personnel – especially re: training, curriculum philosophy, resources and professional development plans of staff •RE: WAC-170-300-0105 – does “Child care basics” course really apply to ECEAP staff? Consider alternate ECEAP orientation. 4. Center program supervisors •Requiring a specific degree/certificate feels like a ploy to generate tuition, revenue and income for state colleges. If such large changes will be required, provide full tuition/funding and paid release time for center directors to meet these requirements. •Provide more inclusive/descriptive information on what “equivalent” means. •For ECEAP, family support services are equally as important as early childhood education. Therefore, experience and education qualifications related to FSS services should also count toward center director requirements as ECEAP center directors/managers likely come from EITHER a FSS or ECE background, both of which are valuable experience for leading ECEAP programs. •RE: WAC-170-300-0105 – does “Child care basics” course really apply to ECEAP staff? Consider alternate ECEAP orientation. 5. Lead teachers •RE: WAC-170-300-0105 – does “Child care basics” course really apply to ECEAP staff? Consider alternate ECEAP orientation. •What will “equivalent” mean re: education/ECE initial certificate? The 30 credits required and counted toward ECEAP staff qualifications, no matter when earned, should be sufficient to meet the “equivalent” requirement. 6. Assistant Teachers •RE: WAC-170-300-0105 – does “Child care basics” course really apply to ECEAP staff? Consider alternate ECEAP orientation. •What will “equivalent mean re: education/ECE initial certificate? The 12 credits required and counted toward ECEAP staff qualifications, no matter when earned, should be sufficient to meet the “equivalent” requirement •P. 27 – 6b. Does not align with ECEAP requirements regarding the lead teacher being present for all ECEAP service hours

Date Submitted: 6/12/2018 11:45:25 AM

Agree/Disagree: Disagree

Comment: If the PBC has to be approved prior to a candidate starting work, licensed programs will not be able to find staff. Sometimes, the required FBI check literally take months to be completed, it is hard enough for providers to keep these staff in positions to be supervised at all times. Qualified candidates will find a job elsewhere if the process takes this long to complete..

Date Submitted: 6/12/2018 6:59:06 AM

Agree/Disagree: Disagree

Comment: Credentialism Run Amok. The Institute for Justice in Washington DC just filed suit against this very thing. DC apparently wants providers to have a degree, not just the 12 credits. Washington State is run amok with their belief we will be better providers with 12 credits. Just let us do our job. Look up IJ at dot org. This page won't let me put in website addresses.

Date Submitted: 6/11/2018 1:56:22 PM

Agree/Disagree: Disagree

Comment: rules that require the same rules for home and centers do not make sense h0me day cares have all different ages and a teaching certificate does not mean that children in early years need a teacher the parents bring them to home care as they want their children in a home environment not a school regimentation and home providers can teach and give a home atmosphere and putting all children into the same rules where there are different curriculums that are chosen by the parent cannot be taught the same way

Date Submitted: 6/10/2018 10:11:07 AM

Agree/Disagree: Disagree

Comment: (3) Early learning providers, including volunteers and household members in a family home early learning program ages fourteen and over, must provide documentation signed within the last twelve months by a licensed health care professional of tuberculosis (TB) testing..... I strongly disagree with the necessity of this testing. Please explain why child-care providers need this in comparison to the fact that teachers in the public school system do not. Also, my family members living in my house (one who has a phobia of needles) should be subjected to this test in the first place. My daycare space is separate from my living space (separate floors) and my family members make little to no contact with the children. The parents of the children who hang around and talk spend more time in the daycare space, breathing the same air as the children. The rules do not make sense to me when they are not universally enforced within different agencies that are all run by the same state. Are children in classrooms less susceptible to TB than in a daycare sitting? Do daycare providers travel overseas more than school teachers? Please explain your reasoning for this requirement.

Date Submitted: 6/8/2018 9:17:40 PM

Agree/Disagree: Agree

Comment: WAC 0120 says a provider would have to stay away if there was an infectious disease. Thank you for taking out the language that required staff to be immunized. As an owner, I would have had to pay for this since my staff would threaten to leave rather than pay for one more DEL requirement.

Date Submitted: 6/8/2018 2:49:38 PM

Agree/Disagree: Disagree

Comment: WAC 0115 requires annual observation..... of staff. For family programs this is ridiculous. We work side by side with our staff. If we see something we talk about it right then. You want stuff in the file so you have something to look at when you come for your visit. This is a waste of time.

Date Submitted: 6/8/2018 2:47:24 PM

Agree/Disagree: Disagree

Comment: WAC 0107 (1) requires us to notify DEL when we make substantial changes to our staff policies and training. This is crazy. The local grocery store doesn't report to any government agency when they change their policies. We are a small business. Leave us be. And what is "substantial"? This is so vague that a licensor can write us up for what we think is minor and she thinks is substantial.

Date Submitted: 6/8/2018 2:34:29 PM

Agree/Disagree: Disagree

Comment: WAC 0100 requires certificates for almost all people working in child care. This is an over reach of expectations. We work long hours, for little pay. When will we have time to take these classes, and who will pay for it? The cost will have to be made up with increased daycare costs. You are trying to run us out of business so you can set up "schools" for infants, just like K-12. Parents will rebel and more children will be in unlicensed care.

Date Submitted: 6/8/2018 2:30:52 PM

Agree/Disagree: Disagree

Comment: WAC 170-300-0185 Menus, milk, and food. (2) An early learning provider must serve a fruit or vegetable as one of the two required components during at least one snack per day. Disagree with requirement to provide a fruit or vegetable during at least one snack IF provider is providing breakfast and lunch (already required during those meals).

Date Submitted: 6/8/2018 1:44:42 PM

Agree/Disagree: Disagree

Comment: Preservice? DOES THIS MEAN A BACKGROUND CHECK MUST BE RETURNED APPROVED BEFORE STARTING TO WORK IN A LICENSED FACILITY OR DOES THE PBC ONLY NEED TO BE SUBMITTED TO START WORK? If the PBC has to be approved, licensed programs will no be able to find staff. By the time someone waits the weeks or months required for an FBI check to be completed, a job candidate will take another position. (2) Early learning providers and household members in a family home early learning program must complete a department background check, pursuant to chapter 170-06 WAC, as hereafter recodified or amended.

Date Submitted: 6/8/2018 1:30:33 PM

Agree/Disagree: Disagree

Comment: Disagree. We have the initial hours of training, on going training, and now you want a degree. There will be no one in the daycare profession in two years because of this requirement. We should not need a degree to be a professional in our profession. We can home school children without a degree, why do we need a degree to teach age 0-6? Get real DEL. This will only discourage and close more daycare homes and centers if the needed help is not there. Minimum wage they can work at taco bell instead of working in child care all togerther.

Date Submitted: 6/8/2018 12:45:09 PM

Agree/Disagree: Disagree

Comment: Please do not cause us to close our family home childcare of over 30 years! I cannot afford to pay for this schooling nor can my parents afford to pay more for childcare! Even if i could afford it...WHEN would this schcooling happen? I provide care 12 hours per day! DEL is regulating us out of business. How will that help our children?!

Date Submitted: 6/7/2018 8:28:54 PM

Agree/Disagree: Disagree

Comment: It is already hard enough for families to find quality care. Home daycares are becoming more scarce due to over-regulation. We already work with no benefits (where is the State in trying to at least let us buy into a group rate?) We work over 50 hours a week, with our benefits paid in hugs. Where would an average daycare provider find the time for schooling? How would it be paid for? I am actually only doing before and after school care now, as I had considered leaving the field due to over-regulation, but my families really needed me. I do work in an ECEAP facility part-time after my kids get to school. I can tell you the Early Achievers is paying for my education through ECEAP, but I have my entire afternoon free to do on-line classes. Every quarter, there is an email stating they are not sure if, or how much funding there will be for the next quarter. They have even limited classes some quarters due to lack of funds being available. It does not look like that state, nor the daycare providers will be able to pay for this. My vote is to back off and let the families make the choice on who they trust to watch their children, or you will end up with a greater shortage of providers than are already out there. Yes, my education has been enlightening and refreshing. I am just not sure it would change myself as a teacher. Most times the assessments done in ECEAP pretty much just get tossed aside once they attend kindergarten at this point anyhow. It is frustrating for the ECEAP staff.

Date Submitted: 6/6/2018 6:44:08 PM

Agree/Disagree: Disagree

Comment: This is ridiculous. I have a degree from SFCC which has a lot of Spanish and Humanities in it and Health. I have a Summa Cum Laude from Whitworth College with more Humanities and Diversity Classes and Children's Literature, and other classes that aid in creating a well-rounded environment. DEL approved all of these classes for continuing education while I was attending. NOW! DEL is saying that is not good enough! That only 4 years from retirement after a 35 year career in childcare with a no-complaint record and daycare children who have gone on to be surgeons and all sorts of important things, NOW, I am being told my education and EXPERIENCE is not good enough. Where is the grandfather clauses for those of us in the business over 20 years! Does DEL plan on going back to the mailroom and start over too?! This is horrible.

Date Submitted: 6/6/2018 4:06:04 PM

Agree/Disagree: Disagree

Comment: DEL approved my continuing hours every year for several years while I was going to Whitworth University and SFCC. So, now my credits in diversity, humanities, sociology, and children's literature etc are no longer good enough? DEL approved them each time for my continuing hours every year! I do believe I could prove this information and perhaps even sue for unfairness in making me have more education at a high cost and I am only 4.6 years from retirement.

Date Submitted: 6/6/2018 12:47:53 PM

Agree/Disagree: Neutral

Comment: WAC 170-300-0005 Definitions What does this mean? This statement does not qualify what a "Heightened standard of care beyond supervision refer? New wording: a heightened standard of care beyond supervision. This standard requires an early learning provider to see and hear the children they are responsible for during higher risk activities. The provider must be able to prevent or instantly respond to unsafe or harmful events.

Date Submitted: 6/5/2018 2:21:52 PM

Agree/Disagree: Disagree

Comment: The trickle down effect of this WAC is that you are projecting a huge increase in childcare cost, and you are saying there is only one way to run a daycare which there is not. Many providers do not take college courses because of their learning disabilities yet they provide care and guidance for their young ones. There are many ways to learn.

Date Submitted: 6/4/2018 12:22:40 PM

Agree/Disagree: Disagree

Comment: This is yet another example of special interest groups getting hold of DEL.. When does it stop. When they have us all out of business??? As a daycare operator for over 25 years, these increasing changes are only putting more hardships on the owneres trying to provide services. As a owner, I believe I can monitor my staff and their education needs without help from DEL telling me how to train my staff. My parents don't object to my programs and I feel very confident that my staff without their forced college ece classes are providing a loving safe environment for our kids.. Enoung DEL.. back off.

Date Submitted: 5/30/2018 7:28:50 PM

Agree/Disagree: Disagree

Comment: Bring back funding for the Career Wage Ladder in childcare. That way we can afford to compensate teachers for increasing their education. The funding was solely for staff salaries and benefits and was a huge asset in early learning. It allowed us to hire and retain high quality staff who were paid livable wages. The teacher turnover rate declined by over 50% for centers that participated! It was a huge success but funding was cut when the state began Early Achievers. Big mistake! Now more providers are leaving the field and we are experiencing a childcare shortage. We do not need more requirements without the funding to support them.

Date Submitted: 5/30/2018 12:17:15 PM

Agree/Disagree: Disagree

Comment: I strongly disagree with the proposal to require teaching certificates for any staff. This would put a tremendous burden on already poorly paid and hard working employees. The ultimate effect would be many employees leaving the industry and an increased demand for staff deemed qualified under the new standards. This will all result in child care becoming more expensive in our state, which is already nearly unmanageable for the average family.

Date Submitted: 5/29/2018 11:07:38 AM

Agree/Disagree: Disagree

Comment: This is a death sentence for in-home childcare. What this will do is force those providers who don't go to school or cant go to school to go underground. Where is the sense in that?? We are trying to make the world better for children not make criminals out of child care providers. I believe in Education. I am getting my BA in ECFS, it is not easy especially working 60 hours a week. Most providers will find it hard to do this.

Date Submitted: 5/25/2018 7:40:59 AM

Agree/Disagree: Disagree

Comment: As with most commenters, I strongly disagree. Centers who select to participate in Early Achievers, choose to align to their standards because they either A. Have the fudning and resources to educate their staff or B. Already require this level of education from their staff. Making the minimum standards (WACs) now reflect the higher standards of Early Achievers is not only impracticable and unrealistic, but irresponsible and damaging to the families that need care for their children and the hardworking teachers who have spent their careers working in a field that is not valued, respected or paid a living wage. I run a center that requires all of our staff to have a minimum of a CDA, but we have the money and resources to fund this rquirement and many centers do not. While I highly value education for both children and teachers, I think this proposed WAC is absurd and exemplar of the way that government is out of touch with reality.

Date Submitted: 5/24/2018 1:47:20 PM

Agree/Disagree: Disagree

Comment: I am extremely worried that if the WACs begin requiring daycare teachers to get their teaching certificate, child cares in the state of Washington will begin to crumble. First of all, we don't have a very big pool of people to choose from when hiring. Not many people want to work in a place that pays minimum wage and doesn't offer benefits (small-town businesses). I understand that there may be an allotted time for teachers to earn these credentials, but is the state prepared to pay for the schooling? Minimum wage teachers can't afford student loans, much less miss the work it would require to go to classes. On top of that, small daycares are not magically going to have the money to pay teachers much more if they DO get credentialed. This idea may have been good in theory, but it is literally a death sentence to small child cares. Please do not do this.

Date Submitted: 5/23/2018 3:31:07 PM

Agree/Disagree: Disagree

Comment: 170-296A. FCCPs already work 50-60 hours a week, when are we supposed to find time to attend classes and do homework. The practicium will require us to close, lose income and work in an ECEAP facility for no pay for a college quarter. Where will our families go for three-four months? Who will be caring for my children during this process and at what cost. I have 22 years experience teaching social skills, providing developmentally appropriate curriculum, prioviding a warm nurturing play based environment, potty training, providing nutritious meals and engage daily with my families. Early achievers has not changed the outcomes or improved the environments children are being raised in....the providers have, These new requirements will give parents less choices as providers will quit. You are overreaching what is needed in this field. How about expecting preschool teachers to have a certificate or degree? They get these kids before they go to kindergarten.

Date Submitted: 5/23/2018 2:58:34 PM

Agree/Disagree: Disagree

Comment: Higher education does not mean better care in all cases. I have a wonderful staff and not one of my preschool teachers is willing to go back to school in order to work at barely above minimum wage. Experience should count, Grandfathering in existing staff is a must.

Date Submitted: 5/23/2018 1:35:57 PM

Agree/Disagree: Disagree

Comment: Does the state plan on paying for the further education they're imposing and making it available online for providers? A 50 hour work week that occurs during normal business hours is not conducive to sitting in a classroom and being taught how to do a job we have already been doing for years. Also, a CDA should be equivalent to more than the initial step in the stackable certificates.

Date Submitted: 5/23/2018 12:55:28 PM

Agree/Disagree: Disagree

Comment: Strongly DISAGREE!!! I understand the need for education, but when you are requiring an employee to work for minimum wage, or just above, and now they have to have an ECE certificate too, but the lady working down at McDonald's makes more money and doesn't have to have the degree, then where do you think our employees are going to go? Thankfully many people in this industry have a passion for working with children, but passion doesn't pay the bills. These new rules and requirements will knee-cap multiple providers across our state, both in-home and centers. Some of my best teachers have been one's without formal training, and I am able to train them how I need them to be trained. Likewise, some of my worst teachers have been ones who looked great on paper, but it did not translate to in class work. My point is that there is not a strong enough correlation between education and how well a teacher teaches, and there never will be. I know plenty of well-educated teachers who need to be out of this field altogether. Please, if this is going to be a rule, then the state needs to step up and provide the funding for these programs and higher wages, instead of putting it back on the small business owners, who are already struggling to make ends meet, and middle class citizens who are already paying some of the highest tuition rates in the U.S.

Date Submitted: 5/23/2018 11:59:07 AM

Agree/Disagree: Disagree

Comment: I absolutely do not agree with this! If these requirements are passed through I will no longer be in business. A degree does not always make for a good teacher and I don't understand why you need a degree to change a diaper. I have had teachers with nothing more then a high school diploma perform better then teachers with a masters. My center is in a very low income area and we have a waiting list a mile long it would be unfortunate if we had to close our doors due to this new requirement. These children would have no where to go.

Date Submitted: 5/23/2018 11:37:21 AM

Agree/Disagree: Disagree

Comment: DISAGREE is not a strong enough word. Be prepared for more places to close down, and more children to be in unlicensed care with the mom down the street. You cannot continue to regulate businesses out of business and not have negative consequences. Middle income families can hardly afford care as it is, this will only increase the cost of childcare even more. You will push people with heart and passion out of this field. We will loose valued teachers because they cannot or will not go back to school. I have interviewed people with their ECE degree who walk in to my program and have no idea what they are doing or how to even talk to a child. I have teachers currently working with no more than a high school diploma that dance circles around people with an ECE degree. A degree or stackable certificate does not make a good teacher. Instead of new requirements, why don't you fix what is broken. If you do not feel like STARS is adequate, then hire better STARS trainings and require more out of the instructors and the classes they present. The consequences of these PD requirements will be severe. YOU WILL REGULATE CHILDREN OUT OF GOOD LICENSED CARE.

Date Submitted: 5/22/2018 4:42:45 PM

Agree/Disagree: Disagree

Comment: 170-300-0220.a.ii It is unreasonable for current ECEAP sites in schools to have the square footage needed per child and have 2 toilets in the classroom.

Date Submitted: 5/22/2018 2:46:09 PM

Agree/Disagree: Disagree

Comment: I have had people put in applications that I feel would be good pre- school teachers, but they do not have a high school diploma. I think that this wouldn't effect if the the applicant is good with children or not.

Date Submitted: 5/22/2018 12:31:57 PM

Agree/Disagree: Disagree

Comment: This makes it really hard to keep staff. I think that there is a lot of training that is required of someone that just starts. I understand some of the requirements, but some don't make sense and we are already a state that has more requirements then others.

Date Submitted: 5/22/2018 12:27:46 PM

Agree/Disagree: Disagree

Comment: In the 11 years I have owned a childcare facility I have lost numerous people because they have not completed child care basics within 6 months of employment so make the requirements even more stringent is going to make a challenging staff problem impossible. And frankly they can go work for what they are making elsewhere with no education requirements. Figure out how to pay them more to make education worth their while. While I understand and agree that more education can make a difference in childcare it is not worth the cost of the education for what people will be making in this already challenging field. Suggestion would be if the STATE paid for this education, paid them for their time to attend this education and then paid them increased wages based on completion. This would be an incentive to actually get the education to improve childcare

Date Submitted: 5/22/2018 9:31:35 AM

Agree/Disagree: Disagree

Comment: I disagree with all of the extra schooling needed. Hard to find staff with the correct education. Asking Assistant teachers to take yearly classes is a lot to ask of them. Also Early Learning staff do not get paid much and having to pay for classes can get expensive. I understand there is reimbursement money but that only goes so far. Too much to ask! As a director I don't have time to take on more.

Date Submitted: 5/22/2018 9:20:46 AM

Agree/Disagree: Neutral

Comment: 170-300-0111 (1)(b) This is not specific. To what extent does the “early learning provider who oversee staff” “be aware of what staff members are doing”? Does this mean all lead teachers have to be immediately supervised, must they be within visual or auditory range, must there be cameras, or must the “early learning provider who oversees staff” be on the premises? A director can’t always “be aware of what staff members are doing” of all staff members at all times. Shouldn’t it instead of requiring “be aware of what staff members are doing” be “monitor staff throughout their working hours” or “be aware of where staff members are at”?

Date Submitted: 5/20/2018 1:12:38 PM

Agree/Disagree: Neutral

Comment: 170-300-0107 (3) “Fiscal year” needs to be defined. Is it the calendar year January through December?

Date Submitted: 5/20/2018 1:11:11 PM

Agree/Disagree: Disagree

Comment: I agree with the rule change except for the following: 170-300-0106 (1) “Or volunteering” should be “Or volunteering, except for occasional volunteers as defined under 170-300-0100 (9)(d)”. 170-300-0106 There needs to be an additional training in this section. In the DEL training database there is already a training titled “Executive Function”. This training is listed under the “DEL Trainer Approval” section. However, executive function is a topic that all early learning providers need to be aware of and to know how to support children’s development of executive function skills from infants through school age. Children are starting school with less executive function skills than ever before which is not only impacting their ability to learn, but it is impacting their experiences before they even get to school. According to the National Center on Early Childhood Health and Wellness, preschoolers are expelled at 3 times the rate of children in K-12 and WaKIDS found that only 30% of low income children are ready for kindergarten. Children need executive function skills to be successful through preschool and be prepared for kindergarten and for life. Early learning providers can directly support these skills in children. Since the largest window of development for executive function skills to develop is between the ages of 3-5 years, early learning providers can’t miss this opportunity to support children’s growth! According to research, including from the Center on the Developing Child, executive function skills are the most important for children to learn. These skills must be taught. Children can’t develop them on their own. Providers need to be required to know, to understand, to be to able to support children’s growth of executive function skills. The only way to ensure this happens is to include this section in the mandated preservice trainings for early learning providers and to require it annually to ensure early learning providers develop a clear and continued ability to support children’s development of executive function. 170-300-0001 (3)(c) has the intent to promote strong school readiness. The early learning providers are the ones that teach and promote these skills in children, but early learning providers need up-to-date information and training to ensure this happens. Without mandating this requirement, we cannot ensure all providers are up to date on the importance of fostering these skills in children and preparing children for school and for life. 170-300-0106 (4) This training should be completed annually. 170-300-0106 (5) This training should be completed annually. 170-300-0106 (6) This should include providers licensed to care for infants or toddlers. Although the Center for Disease Control and Prevention states that children under one year of age are most at risk, children under five are still at risk. Therefore, all programs that provide care for children, at least for infants and toddlers should be required to take this training. This training should be completed annually, or at least every three years. 170-300-0106 (7) This training should be completed annually, or at least every three years. 170-300-0106 (10) This training should be completed annually.

Date Submitted: 5/20/2018 1:10:24 PM

Agree/Disagree: Neutral

Comment: 170-300-0105 (3) This needs clarification. “Early learning providers…must provide documentation signed within the last twelve months…” from the time the chapter becomes effective? All early learning professionals? Or, is it upon hire, an early learning professional must provide documentation? The current section reads as though everyone currently working, who already has a TB test pursuant WAC 170-295, must go get a new TB test.

Date Submitted: 5/20/2018 1:06:46 PM

Agree/Disagree: Disagree

Comment: I agree with the rule changes in this section except for the following: 170-300-0100 (3)(ii) The term “or equivalent” needs to be defined within the section. The definition to be “approved and verified in the electronic workforce registry by the department” has previously taken months to verify. Either verification of “equivalent” education must be completed in a timely manner, or it must be outlined in a list of acceptable “equivalent” standards. When a new director is needed, centers can’t wait for “or equivalent” to be determined in order to know if the director’s qualifications meet the requirements. 170-300-0100 (3)(a)(B) There should be an exception to have an educational plan in place if a director hired after the chapter becomes effective does not have an ECE state certificate upon hire. If this WAC goes into effect, and current directors quit because they don’t have ECE state certificates or equivalent, where will licensed centers find new directors that already have the ECE state certificate at time of hire? Current WAC only requires at minimum a CDA, so when these WACs go into effect, there must be more time for the workforce to obtain ECE state certificates before we can expect them to have it “upon hire”. 170-300-0100 (6)(b) “on-the-job classroom training from the classroom’s assigned lead teacher” needs to include “or program supervisor, assistant director, or director”. Lead teachers do not always receive their “on-the-job classroom training” from lead teachers and this requirement needs to allow for flexibility of “on-the-job classroom training” to be provided by individuals other than the lead teacher. 170-300-0100 (7) Aides over the age of 18 should be allowed minimal access to work alone with children, while a director, assistant director, program supervisor or lead teacher is on the premises. This allows for opportunity to meet staffing requirements in opening/closing shifts, nap time, or times when the ratios are low. To require someone to have at least an ECE initial certificate in each age group with children from open to close at all times will be difficult to staff. Centers are open, some 14 hours per day or more. There needs to be flexibility to have aides help during opening/closing, nap time, or when ratios are lower such as: Aides can be alone with children if the number of children does not exceed half the ratio for the age group, for the first and last hour of business hours, and during nap time when all children are sleeping. 170-300-0100 (8) Definition need to be expanded. Does this mean “other personnel” have access while children are on the premises or in the same room as children? What if the “other personnel” do not have access to children directly and are only in licensed spaces when children are not present? For example, does this include a cook, maintenance person, lawn care, or housekeeping staff?

Date Submitted: 5/20/2018 1:05:19 PM

Agree/Disagree: Disagree

Comment: WAC 170-300-0100 General staff qualifications: there is no need to change the requirements! What accommodations are being made for center directors, assistant directors, lead staff, and assistant staff who have worked for 10 plus years in this field? The WAC already requires Early childhood professionals to have 10 hours of continuing education courses annually. Will those hours be considered when determining someone’s education qualifications? As a parent I would rather someone with actual childcare experience care for my child then someone who has minimal experience with children but a piece of paper saying they work well with children. In theory we want everyone to have higher education but, higher education isn’t always affordable. Also, staff putting in this time and money into a required education will want to be paid more and rightfully so. Not all centers can afford to pay higher then minimum wage right now especially since it is steadily increasing over the next few years. Families cannot afford higher rates or Rate increases every year. Many centers have already received push back from families having a rate increase and have had to deal with lower enrollment because families cannot afford to place their children in care. Most of these families do not qualify for DSHS and the state subsidy rate has not been increasing to keep up with the rate increases of centers. This education requirement is like expecting a Lamborghini for the price of a Kia Rio. You want all the bells and whistles but are not willing to pay the price. I have searched for the equivalent to the ECE certificate and have found nothing. These equivalents should be clear and well defined. If there is no equivalence to this requirement or you are not willing to compromise and perhaps “grandfather in” existing staff I know we will lose many high-quality care providers.

Date Submitted: 5/19/2018 9:55:51 PM

Agree/Disagree: Disagree

Comment: WAC 170-300-0100 General staff qualifications What accommodations are being made for center directors, assistant directors, lead staff, and assistant staff who have worked for 10 plus years in this field? The WAC already requires Early childhood professionals to have 10 hours of continuing education courses annually. Will those hours be considered when determining someone’s education qualifications? As a parent I would rather someone with actual childcare experience care for my child then someone who has minimal experience with children but a piece of paper saying they work well with children. In theory we want everyone to have higher education but, higher education isn’t always affordable. Also, staff putting in this time and money into a required education will want to be paid more and rightfully so. Not all centers can afford to pay higher then minimum wage right now especially since it is steadily increasing over the next few years. Families cannot afford higher rates or Rate increases every year. Many centers have already received push back from families having a rate increase and have had to deal with lower enrollment because families cannot afford to place their children in care. Most of these families do not qualify for DSHS and the state subsidy rate has not been increasing to keep up with the rate increases of centers. Also asking new staff to have these qualifications upon hire is going to make hiring for all people impossible. its already hard to find quality people with this education requirement places will not have workers and WILL shut down! This education requirement is like expecting a Lamborghini for the price of a Kia Rio. You want all the bells and whistles but are not willing to pay the price. I have searched for the equivalent to the ECE certificate and have found nothing. If you are making this a requirement it should be made easily assessable to people and clearly defined. If there is no equivalence to this requirement or you are not willing to compromise and perhaps “grandfather in” existing staff I know we will lose many high-quality care providers. Staff training and in-service trainings: It would be beneficial to have more than a few options for providers to choose from. Looking through trainings for Professionals they are mostly 100+ miles from my town. I do not expect my provider to have to take time off from work or miss out on time with their own family to take a required training 2 hours away. This is not helpful to them nor do I see it benefiting my child.

Date Submitted: 5/18/2018 4:42:00 PM

Agree/Disagree: Disagree

Comment: Pretty much the same response as everyone else. More training, more requirements, THIS IS NOT A SCHOOL!!!!! We are trying to teach children the basics. Preparing them for school, we do most of that through playful interactions. I am a LICENSED DAYCARE FACILITY! Retaining and hiring staff is hard enough already, the more you throw at people they are either going to quit or ask for money that's just the truth behind it. You may just sit there and say too bad but what happens when there are no more quality daycare facilities left or has that always been the plan to get rid of everyone? This is why you have a bunch of people posting adds on craigslist taking care of children for $10 a day because the reward is no longer worth the risk for most providers. We do our jobs because we love children but it is also a business, one where we need to make money to survive.

Date Submitted: 5/18/2018 4:04:22 PM

Agree/Disagree: Disagree

Comment: NO!!! DO NO AGREE WITH THIS. A degree does not always make for a good teacher. I worked with someone who had a Master and he didn't know any thing-except he was book smart/reality dumb. DEL wants quality, so do the rest of us who already have dedicated and great teachers who do marvelous activities with children. And they are happy with where they are at. CDA's don't count? To ask them, after working 8 hrs. with children (exhausting),to go back to school - they will be quitting- I can't force them to do so. We won't be able to find people who want to work in this field with those expectations. Whatever happened to "learn by experience"? We also learn from each other. Reconsider this dumb WAC.

Date Submitted: 5/18/2018 3:19:32 PM

Agree/Disagree: Disagree

Comment: Forcing providers with experience and age discrimination is what i call it. you will never get new providers in this field and the seasoned ones will be leaving the field. We already have a huge shortage for infants in District 1 and I turn away about 6 calls a month for infant care. Have you noticed more preschools popping up? Providers are leaving for the preschool business if we have to provide all this EA curriculum i plan to join them and actually get paid a decent wage.

Date Submitted: 5/18/2018 3:19:23 PM

Agree/Disagree: Disagree

Comment: NO WAY--- We gain experiance working with children more than just sitting in classroom... I own masters degree in other academic which is consider higher education. WHy need to have all certificate for those who have higher education?-- YES I agree for need who does not have any degree.... This is making more difficult for home child care provider-- which in future will FORCE more home child care provider to close their facility PLease dont take our bread from us making complicated rules

Date Submitted: 5/18/2018 2:10:32 PM

Agree/Disagree: Disagree

Comment: I have a small center with one teacher who has worked in the field for over 20 years. She completed the initial STARS training to be a lead teacher and has over 250 hours of ongoing STARS training. Why don't those years of experience and training count? She is a remarkable teacher but she would rather retire than go back to school at this point in her life. Years of experience is more valuable in this field than just the education. There are many professionals working in the field without certificates & degrees. They should be grandfathered in and not required to meet the new educational WAC's. Too many skilled & valuable providers are leaving the field due to Early Achievers and changes in WAC's. There will soon be a child care crisis and the state only has itself to blame!!

Date Submitted: 5/17/2018 6:23:39 PM

Agree/Disagree: Agree

Comment: Thank you for allowing teens to volunteer. (9) Volunteers help at early learning programs. Volunteers must meet the following qualifications: (a) Be at least fourteen years old (volunteers must have written permission to volunteer from their parent or guardian if they are under eighteen years old);

Date Submitted: 5/17/2018 6:15:00 PM

Agree/Disagree: Disagree

Comment: Instead of forcing providers to be flipping back and forth between WACs, just list those vaccine preventable contagious diseases which require exclusion and combine 3 and 4 into a single paragraph. WAC 170-300-0205 in this WAC. WAC 170-300-0120 (3) If a staff person has not been vaccinated, or has not shown documented immunity to a vaccine preventable disease, that person may be required by the local health jurisdiction or the department to remain off-site during an outbreak of a contagious disease described in WAC 246-110-010, as now and hereafter amended. (4) An early learning program's health policy, pursuant to WAC 170-300-0500, must include provisions for excluding or separating staff with a contagious disease described in WAC 246-110-010, as now and hereafter amended.

Date Submitted: 5/17/2018 6:12:45 PM

Agree/Disagree: Disagree

Comment: Instead of forcing providers to be flipping back and forth between WACs, just list those illnesses and condition which require exclusion WAC 170-300-0205 in this WAC. WAC 170-300-0120 Providing for personal, professional, and health needs of staff. (2) An early learning provider must be excluded from the early learning premises when that provider's illness or condition poses a risk of spreading a harmful disease or compromising the health and safety of others. The illnesses and conditions that require a staff member to be excluded are pursuant to WAC 170-300-0205…

Date Submitted: 5/17/2018 6:08:38 PM

Agree/Disagree: Disagree

Comment: An I-9 form is required for any employee. Just having a copy of a social security card is not adequate. If the intent is to make sure providers follow the law, DEL must be certain the WAC is correct. WAC 170-300-0115 Staff records. (3) A licensee, center director, assistant director, or program supervisor must maintain the following records for each early learning provider and staff in a confidential manner. These records must be reviewable by the department and must include at a minimum: (e) The licensee's Social Security number, federal EIN, or a written document stating the licensee does not possess either. U.S. Citizenship and Immigration Services 10.5 Retaining Copies of Form I-9 Documentation You may choose to copy or scan documents an employee presents when completing Form I-9, which you may retain with their Form I-9. Making photocopies of an employee’s document(s) does not take the place of completing Form I-9. Even if you retain copies of documentation, you are still required to fully complete and retain Form I-9. If you choose to retain copies of an employee’s documents, you must do so for all employees, regardless of actual or perceived national origin or citizenship status, or you may be in violation of anti- discrimination laws. Copies or electronic images of presented documents must be retrievable consistent with DHS’s standards on electronic retention, documentation, security, and electronic signatures for employers and employees, as specified in 8 CFR Part 274a.2(b)(3). If you make copies or electronic images of the employee’s documents, they must be either retained with the corresponding Form I-9 or stored with the employee’s records in accordance with the standards for electronic records retention as specified in 8 CFR 274a.2(b)(3). However, if copies or electronic images of the employee’s documents are made, they must be made available at the time of a Form I-9 inspection by DHS or another federal government agency.

Date Submitted: 5/17/2018 6:04:05 PM

Agree/Disagree: Disagree

Comment: There are many, many examples of Compliance Agreements which cite not having paper copies of documents in personnel files which are entered in MERIT, specifically the PBC. Don't say paper documents supporting MERIT entries aren't needed and then punish providers for not having them upon inspection. Also, MERIT is not error free nor is child care check as DEL has "upgraded" the systems. WAC 170-300-0115 Staff records. (1) An early learning provider must establish a records system for themselves, household members, staff, and volunteers that complies with the requirements of this chapter.... (b) Entered and maintained in the electronic workforce registry, if applicable. Paper records may be discarded once entered into the electronic workforce registry and confirmed by the department;...

Date Submitted: 5/17/2018 5:53:36 PM

Agree/Disagree: Disagree

Comment: How is the term “work plan” pertinent to what teachers should be doing in early learning? It is used in project management to control timelines and budgets. Highly inappropriate in what should be a child centered environment. WAC 170-300-0111 Staff oversight. (1) An early learning provider who oversees staff must: (a) Establish a work plan with clear expectations; (b) Be aware of what staff members are doing; and (c) Be available and able to respond in an emergency as needed to protect the health and safety of children in care.

Date Submitted: 5/17/2018 5:43:54 PM

Agree/Disagree: Disagree

Comment: I am horrified and offended that the word "oversee" would be used rather than "supervise" when referring to staff. DEL wants sensitivity to equity and bias and wants a professional workforce but uses such a term in 2018? It reveals the actual lack of respect with which DEL views those who work in early learning. WAC 170-300-0111 Staff oversight. (1) An early learning provider who oversees staff must:

Date Submitted: 5/17/2018 5:11:05 PM

Agree/Disagree: Disagree

Comment: Does this take the place of “orientation” in previous WAC? WAC 170-300-0110 Program based staff policies and training. (4) An early learning provider must develop, deliver, and document the delivery of early learning staff training specific to the early learning program and premises. (a) Training topics must include: (i) Staff policies listed in subsections (2) and (3) of this section;

Date Submitted: 5/17/2018 4:58:35 PM

Agree/Disagree: Disagree

Comment: This is very poorly written. Do you mean that when the staff members working with a group of children change during the day, they should share child specific information and be prepared to speak with the family? WAC 170-300-0110 Program based staff policies and training. (3) An early learning provider must have and follow written policies requiring staff working, transitioning, or covering breaks with the same classroom or group of children to share applicable information with each other on a daily basis regarding: (a) A child's health needs, allergies and medication; (b) Any change in a child's daily schedule; (c) Significant educational or developmental information; (d) Any communications from the family; and (e) Information to be shared with the family.

Date Submitted: 5/17/2018 4:55:50 PM

Agree/Disagree: Disagree

Comment: Why would DEL need to know if employer/employee policies change? Does DEL have the staff time to keep abreast of all changes in employment law and review provider policies? What does "substantial" mean? If this WAC were in place this year, would the state mandated sick leave policy require every provider to submit the change to DEL and DEL devote staff time? WAC 170-300-0110 Program based staff policies and training. ….Providers must notify the department when substantial changes are made.

Date Submitted: 5/17/2018 4:36:02 PM

Agree/Disagree: Disagree

Comment: Why would DEL have the authority to approve employer/employee policies? Are DEL employees reviewing staff policies licensed to practice law in the State of Washington and are they employment law specialists with extensive knowledge of case law? Does DEL intend to insert itself in employment disputes? WAC 170-300-0110 Program based staff policies and training. (1) An early learning provider must have and follow written policies for early learning program staff. Staff policies must include those listed in subsections (2) and (3) of this section and must be reviewed and approved by the department...

Date Submitted: 5/17/2018 4:27:57 PM

Agree/Disagree: Disagree

Comment: Is the "fiscal year" the State of Washington fiscal year or the employer's fiscal year or the Federal Government's fiscal year? Only five in-service training hours may be carried over from one fiscal year to the next fiscal year.

Date Submitted: 5/17/2018 4:21:12 PM

Agree/Disagree: Disagree

Comment: Has the Enhancing Quality of Early Learning (EQEL) class been developed yet? Where can we view a copy of it? WAC 170-300-0107 In-service training. (1) An early learning provider must complete ten hours of annual in-service training after twelve months of cumulative employment. (a) Family home licensees, center directors, assistant directors, program supervisors, lead teachers, and assistant teachers must complete the department enhancing quality of early learning (EQEL) inservice training within thirty-six months of being hired in a licensed facility, unless the provider has completed a department approved alternative training. EQEL hours may count towards the ten hours of annual in-service training.

Date Submitted: 5/17/2018 4:17:35 PM

Agree/Disagree: Disagree

Comment: Complete within three months of this section becoming effective. If approved versions of these classes already exist, where can we review them? Child abuse/neglect. Emergency preparedness. Shaken baby/head trauma. Homeless children. If you are not serving homeless children do you have to take the training? WAC 170-300-0106 Training requirements. (1) Early learning providers licensed, working, or volunteering in an early learning program before the date this section becomes effective must complete the applicable training requirements of this section within three months of the date this section becomes effective unless otherwise indicated. (4) Early learning providers must complete the recognizing and reporting suspected child abuse, neglect, and exploitation training as approved or offered by the department according to subsection (1) of this section. (5) Early learning providers must complete the emergency preparedness training as approved or offered by the department (applicable to the early learning program where they work or volunteer) according to subsection (1) of this section. (6) Early learning providers licensed to care for infants must complete the prevention and identifying shaken baby syndrome/abuse head trauma training as approved or offered by the department according to subsection (1) of this section. (7) Early learning providers must complete the serving children experiencing homelessness training as approved or offered by the department according to subsection (1) of this section.

Date Submitted: 5/17/2018 4:10:01 PM

Agree/Disagree: Disagree

Comment: WAC 170-300-0107 In-service training. (1) An early learning provider must complete ten hours of annual in-service training after twelve months of cumulative employment. Cumulative? Continuous? What if someone takes a break from early learning for two or three years? Does a provider receive a Compliance Agreement if a new employee did not complete required training while employed with a different provider or employed outside of the field? What will this look like in the real world.

Date Submitted: 5/17/2018 3:32:44 PM

Agree/Disagree: Disagree

Comment: WAC 170-300-0100 General staff qualifications. "Or equivalent" is not defined. When will this be made available and who will be making the decision that something is equivalent?

Date Submitted: 5/17/2018 3:01:49 PM

Agree/Disagree: Disagree

Comment: These new educational requirements are ridiculous. It is already hard to hire qualified staff. This will make it even harder and force many people to leave the field. I feel that experience should count for something. Many things you can’t learn in a class.

Date Submitted: 5/17/2018 12:09:09 PM

Agree/Disagree: Disagree

Comment: I do not like that after this goes into affect that upon hire teachers must have schooling (even though it is the lower degree). It is already hard to hire competent teachers, with or without a certificate/degree. I think it should be acceptable to hire an Assistant or Lead with no degree as long as they set up an acceptable education plan.

Date Submitted: 5/16/2018 10:53:30 AM

Agree/Disagree: Disagree

Comment: This is an impossible task. I am not running a preschool or an ECAP. I am running a daycare. We learn thru play. I have gone to school for early childhood education and I am finishing up my certificate but I do not intend to go further. I have five children. I work 50 hours a week. I already find it hard to juggle family and work. Now more schooling too? There isn’t enough time. Plus doing EA stuff? I just don’t know how it can be done. My area has so few licensed daycares. I get multiple calls daily. I have a waiting list a mile long. I have families whose children come for 30-45 min because they need SOME kind of care for their child because there are not enough daycares. We have two more licensed daycares closing over here in June. These WACS are pushing providers out. I can’t say I plan on staying much longer myself at this rate.

Date Submitted: 5/15/2018 11:08:26 PM

Agree/Disagree: Disagree

Comment: I became a Family Home Licensed Childcare Provider for my love of children. If I wanted to be a preschool teacher I would have chosen to do so. I work 55 hours a week plus prep time. I pay all of my own bills, buy all my supplies. I am a individual who loves what I do and work very hard. I do not work for the Department of Early Learning, they do not pay my salary, pay my rent or buy my supplies. My families love having their children here which can be proven by no turnover and openings reserved up to a year in advance. You are smothering us, Please let us breathe.

Date Submitted: 5/15/2018 1:24:17 PM

Agree/Disagree: Disagree

Comment: Regarding WAC 170-300-0105 (proposed education requirement): As a daycare provider it was never my intention to run a preschool. I provide childcare in my home in a loving, safe environment where we encourage and facilitate learning through play. I work hard to ensure all of the children in my care learn daily. I am 45 years old, have 4 children of my own, and work 50 hours per week in my daycare (not to mention the prep time I spend outside my open hours). I also have have a family to care for. I do not have the time or financial resources to go back to school. I work hard, every day, to be present for my family, to give my all to the children in my care. This proposed WAC does not give more to my kids in my daycare, it takes from my family, it adds tremendous stress to my professional and personal (and financial) life. It will essentially drive me out of business. It is unreasonable. Think about the providers and what you are really asking. We are not running preschools. We are people who love what we do. We love children and we love helping families raise their little ones while they are working hard to provide for them. Forcing us into this corner does not enhance opportunities. It will limit the amount of licensed care available as providers are forced to close when they cannot meet the requirement. Thank you.

Date Submitted: 5/15/2018 11:37:41 AM

Agree/Disagree: Disagree

Comment: I said in 1994 you wanted Family Home Daycare closed down. You resent that we are self-employed and out of your sight. I have a 33 year of perfect performance and that is not enough. I will be exiting family home childcare when I turn 66 which is four years away. You have finally done it! This is ridiculous!

Date Submitted: 5/15/2018 6:53:30 AM

Agree/Disagree: Disagree

Comment: Seriously? I had planned to work until I was 70 years old in my highly successful before and after school program. And at age 62 with 33 years under my belt, educated, no-complaint record, you are asking me within five years to get an ECE along with EA? This is crazy. I will quit as soon as this requirement is enforced upon me, which means I will quit providing quality care three years earlier than anticipated. I say this is horrible for family home childcare. You have already run many of us out. YOU WANT FAMILY HOME CARE TO CEASE TO EXIST!!!

Date Submitted: 5/15/2018 6:35:55 AM

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