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2/12/18 Child Care Commission Public Hearing Overview

Background on the Process:  When the Child Care Commission is involved in the rulemaking process, one of the requirements is that there is a period of public comment, 60 days at a minimum, where the public can give written input on the proposed rules.  During that public comment period the Commission is required to host a public HEARING, which is at a designated place, at a designated time, and allows members of the public to show up and personally speak about the rules.

 

On February 12, 2018 the Public Hearing will cover SEVERAL rules, and most of them are detailed and play a huge role in the operation of a child care center.  Below we will try to give you an outline, but we encourage you to submit questions you might have after you finish reading this page and the linked documents below.

 

How long do we have to give written comment?  Comment period ends April 3, 2018.

 

When are these rules proposed to be effective?  June 1, 2018

 

What else is in the rules (or NOT in the rules and should be) that we should be concerned about?

  • Would you like to be able to elect not to participate in the Two to Five Star program and have it noted on your license that it was your choice?  
  • Would you like to be able to designate two individuals to SHARE the qualifications for an on-site administrator?  Tell them to incorporate that language into this set of rules, maybe in .2819.
  • Is the staff shortage creating a hardship?  Would it help if a staff member could be “working toward” a certain educational level and still be counted in your current star level?
  • Would you like for early childhood educators who apply for jobs with you to have transcripts assessed overnight?
  • How do you feel about a mother complaining of her child’s nightmares leading to a claim against you of psychological harm to a child?
  • What number of incident reports should trigger an investigation at a facility?
  • Did you make a choice, back when CRCs were taking forever, to start an employee early rather than violate staff-child ratios?  When you made that choice did you know that if it happened twice you could receive an administrative action?
  • Did you know that the new Provider Compliance Unit audits around subsidy attendance may increase your chances of administrative actions?
  • Do you agree that two administrative actions over the course of your license should result in a probationary license?  (.2205)
  • Do you think it’s appropriate to get an administrative action when you’ve already been penalized by sanitation for a disapproved sanitation classification or two provisionals, regardless of what actions or equipment malfunctions might have led to them? (.2203)
  • Would it be helpful if language allowed new staff to be hired and complete employment and orientation paperwork prior to exposure to children if the qualifying letter has not yet been received? (.2703e)
 

When is the Public Hearing?  Monday, February 12, 2018 at 1:00 pm (as part of the Child Care Commission's quarterly meeting)

 

I don't know where to go in Raleigh.  We offer a "guided tour" for those who meet us at the NC Farmers Market Restaurant by 8:00 am.  Register for the "tour" and we'll let you follow us so you know where to go, where to park, where to sit, and more.  We'll even text you if there are road closings or traffic tips that we think might help you that morning!

 

I don't like public speaking.  Will it help at all if I show up?  YES!  Nodding heads help the ones who are speaking feel supported.  Sometimes a commission member will ask for a show of hands in the audience as to how many have a similar situation.  Simply having providers there to show there are concerns around the rules is powerful.  It helps them realize that when NCLCCA speaks on an issue, we truly are speaking on behalf of REAL providers.

 

What do I need to say?  You'll probably only have 3 minutes or less.  Give your name, tell the name, size and location of your center/school, and maybe one other piece of information, such as star level, subsidy/NC Pre-K participation, how long in business, etc.  Get straight to what you disagree with or would like to see changed, and what you think it should say.  Real life examples are helpful because many of the Commission members do not understand how rules "play out" in your world.

 

For example:

"I am Jane Doe.  I own two centers in Harnett County and we have 175 children enrolled, with 75% funded through the subsidy program. I would like to encourage you to change the 90 days to 6 months in rule .2830(c). I lost two 5 point lead teachers last fall.  I used my floater and our assistant director while we interviewed but it took 2 months to get both spots filled.  They both had AAS early childhood degrees but one left after 3 weeks to work for NC Pre-K and the other one stayed 2 months before she decided to go back to school full time.  The 2 I hired to replace them haven't started yet because one is waiting on a background check from New York and the other one has had to respond to some items on her record and the background checks are not completed for either of them.  We can't find people with degrees who want to work in child care, so 90 days is not enough time.  We need to be able to hire people who will agree to work toward the education level we need.  Years ago when we were able to be more selective in hiring, we found candidates who were good with children and a good fit for our center, and we could encourage them to enroll in classes. Again, please consider changing 90 days to 6 months in rule .2830(c)."

 

What if I can't say everything in 3 minutes?  Put all your comments in writing, bring a copy (or 18 copies if you can) to leave with DCDEE staff, and use your 3 minutes to convey a personal example or make a comparison to something they can relate to, so that your story stands out.  Or bring a colleague and divide up your topics between you.  Or do both - bring a colleague AND submit all your thoughts in writing but just highlight your topics when you speak.

 

Will NCLCCA help me?  We will be honored to review your written comments and make suggestions!  We would need them by 5:00 pm on Thursday before the Commission meeting.

 

Do I need to be there all day?  No, you need to be there by 12:45 to sign in if you plan to speak but you may leave after your speak or at the end of public hearing, or anytime you wish.  People come and go all during the meeting with no problem.

 

What written resources do you have for me to review?

Here is the public notice that tries to explain the rule changes and shows the new rule language (underlined) and the rule language being removed (strike through).  It also gives important dates and the location of the hearing.  Because they have reformatted some of the rules (charts and tables instead of text) it is difficult to follow what's changed in the rated license section.

 

Here is the Fiscal Impact Analysis showing the cost to members of the public as well as the state, to implement the Rated License Rules.

 

Here is the Fiscal Impact Analysis showing the cost to the public as well as the state, to implement the Administrative Action Rules.

 

Please let us hear from you!

 

 

 

 

 

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