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Texas Minimum Standards revisions

By Roberto Campbell,2014-04-20 19:20
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Texas Minimum Standards revisions

    Comments/Recommendations

    Texas Day Care Minimum Standards revisions

Texas Association for the Education of Young Children (TAEYC) is a state-wide advocacy organization representing over 2000 early

    care and education professionals across the state. We represent ECE teachers, administrators, higher education and other advocates in

    striving for high-quality early care and education for all children in Texas ages birth to 8.

    We would like to commend Texas Department of Family and Protective Services (TDFPS) Child Care Licensing (CCL) Division in their ability to achieve and maintain high quality in the following areas:

    Texas Minimum standards require a child:staff ratio of 1:4 for infants ages birth 11 mos. This ratio is in line with NAEYC national standards and very close to the 1:3 ratio required for National Health and Safety Standards. We congratulate TDFPS for ensuring a

    low ratio and better oversight of our youngest in center-based care.

TAEYC also commends CCL for requiring lower ratios during water activities and during field trips. As you well know, drowning can

    occur quickly in young children and only in 2 inches of water. Supervision is always an issue when you take children out of their

    familiar environment. Lowering the ratios during field trips better ensures the safety of the children and the staffs’ ability to

    appropriately supervise the children. Given the higher than nationally recommended ratios and group sizes overall, lowering these for

    water activities and for field trips is commendable.

TDPRS is commended on the education and experience requirements for Center Directors. While TAEYC would like to see all

    Directors having a minimum of a Bachelors degree in Early Childhood Education, minimum standards requirement of college credits

    in ECE and business management is a step in the right direction.

CCL should also be commended for incorporating best practices throughout the minimum standard guidelines. TAEYC realizes the

    challenges in having high quality standards across the board in Texas, but CCL is taking steps in the right direction by educating those

    in the field on what best practices are for particular standards. We applaud your efforts in this.

TAEYC has many recommendations for revisions to licensing standards in center based programs. We felt that by providing our

    comments in a table format, linking them to the current standards, may make it easier for not only for TDFPS staff but for those we

    represent across the state of Texas.

Affiliated with local Associations for the Education of Young Children, Southern Early Childhood Association and the National Association for the Education of

    Young Children

    TAEYC Comments on CCL revisions to Center Licensing Standards, Oct. 2009 Page 1 of 9

    Comments/Recommendations

    Texas Day Care Minimum Standards revisions

     ?746.1319 ?746.1319

    Research clearly shows the quality of training Does Licensing approve training resources or Does Licensing approve training resources or

    provided to classroom staff and administrators has trainers for training hours? trainers for training hours?

    Subchapter D, Personnel Subchapter D, Personnel a direct correlation to implementation of best Division 4, Professional Development Division 4, Professional Development practices in the classroom. The establishment of a 09/01/03 09/01/03 statewide Trainer Registry ensures a level of quality No. We do not approve or endorse training Yes. TDFPS requires that all training for pre-assurance in the training provided to the child care

    resources or trainers for training hours. You service and annual training come from a trainer industry. The Texas Trainer registry has been in should, however, ensure you and your employees approved by the Texas Early Care and Education existence for 5 years and has established procedures receive relevant training from reliable resources, in Career Development System or from a state for ensuring those listed in the Registry have a topics specified in this division, and that accredited college or university. Training should minimum level of education and experience in participants receive original align with topics specified in this division and, for training adults. Currently, there are 412 registered documentation of completion, as specified in this those working with preschool-age children, align trainers and 1342 courses in the Texas system.

    division. with the Texas Pre-K Guidelines. Participants must Trainers Registries are an integral part of a

     receive original documentation of completion, as statewide Quality Rating and Improvement System

    specified in this division. (QRIS). For more information on the Texas Trainer Recommendation: Since the Department does not

     Registry, please visit approve training

    http://www.uth.tmc.edu/tececds/ sources, it is very important that training for your OR

     employees come from a

    For more information on Quality Rating and reliable source that has experience in the topic Best practice: Since the Department does not

    Improvement Systems, please visit that they are presenting. approve training sources, it is very important that

    http://www.naeyc.org/policy/ecwsi We recommend you ask the trainer to provide you training for your employees come from a reliable

     with a résumé or vita source that has experience in the topic that they showing relevant experience and education, or be are presenting. Trainer Registries are one quality

    certain you are assurance measure that has been implemented in obtaining training through reliable sources in the 22 states, including Texas. We recommend you

    community who have ensure high quality training experiences by

    verified the presenter’s qualifications for you. utilizing trainers from the Texas Trainer registry Also, ask to see a copy of or ensure trainers have a statewide or national the certificate your employees will receive and to credential, such as Child Care Health

    preview the materials, Consultants. Additionally, ask to see a copy of the

    before entering into an agreement to purchase any certificate your employees will receive and to training. preview the training syllabus

    before entering into an agreement to purchase any Affiliated with local Associations for the Education of Young Children, Southern Early Childhood Association and the National Association for the Education of Young Children

    TAEYC Comments on CCL revisions to Center Licensing Standards, Oct. 2009 Page 2 of 9

    Comments/Recommendations

    Texas Day Care Minimum Standards revisions

    training. The Texas Trainer Registry can be

    accessed at http://www.uth.tmc.edu/tececds/

    Research has shown that high-quality early ?746.1327 ?746.1327

    childhood education (ECE) programs improve How many annual training clock hours may How many annual training clock hours may

    outcomes for children in school and in life. The caregivers obtain from self-instructional caregivers obtain from self-instructional

    quality of ECE hinges on teacher experience and materials? materials? 1Subchapter D, Personnel Subchapter D, Personnel qualifications. Staff training has shown to be an Division 4, Professional Development Division 4, Professional Development indicator of high quality in the classroom. 09/01/03 09/01/03

    A caregiver may obtain no more than one-half of A caregiver may obtain no more than 10 hours of

    the required 15 clock hours of annual training from the required 25 clock hours of annual

    self-instructional materials. We may ask to review training from self-instructional materials. We

    self-instructional materials to ensure self-may ask to review self-instructional

    instructional training criteria are met. materials to ensure self-instructional training

    Obtaining training in a group setting provides criteria are met.

    caregivers an opportunity to interact and share Obtaining training in a group setting provides

    knowledge about child-care practices and to gain caregivers an opportunity to interact and share exposure to different views and ideas about the best knowledge about child-care practices and to gain practices in child care. exposure to different views and ideas about the best

     practices in child care.

    ?746.1301 ?746.1301 What training must I ensure that my employees What training must I ensure that my employees have? have?

    Subchapter D, Personnel Subchapter D, Personnel

    Division 4, Professional Development Division 4, Professional Development

    09/01/03 09/01/03

    You must make sure that each employee has the You must make sure that each employee has the following training: following training:

    (1) Orientation to the child-care center for all (1) A minimum of 2 hours of Orientation to the

    employees; child-care center for all employees;

     1 Losing Ground in Early Childhood Education: Declining Workforce Qualifications in an Expanding Industry, 1979-2004. Retrieved from http://www.fcd-us.org/usr_doc/LosingGroundinEarlyChildhoodEducation.pdf

    Affiliated with local Associations for the Education of Young Children, Southern Early Childhood Association and the National Association for the Education of

    Young Children

    TAEYC Comments on CCL revisions to Center Licensing Standards, Oct. 2009 Page 3 of 9

    Comments/Recommendations

    Texas Day Care Minimum Standards revisions

(2) Eight clock hours of pre-service training, or (2) 40 clock hours of pre-service training,

    documentation of exemption, for inclusive of CPR, First Aid and orientation, or

    caregivers; documentation of exemption, for caregivers;

    (3) 15 clock hours of annual training for caregivers; (3) 25 clock hours of annual training for

    (4) 20 clock hours of annual training for the caregivers;

    director; and (4) 30 clock hours of annual training for the (5) CPR and first aid as specified in this division. director; and

    Employees, such as janitors and cooks, who do not (5) CPR and first aid as specified in this division.

    have responsibility in caring for a group of Employees, such as janitors and cooks, who do not children, do not have the same training needs as a have responsibility in caring for a group of

    caregiver who is responsible for the care and children, do not have the same training needs as a

    supervision of a group of caregiver who is responsible for the care and children. supervision of a group of

    children.

    NAEYC accreditation guidelines for child: staff

    ratio provides research-based ratios that ensure the ?746.1601 How many children may one ?746.1601 How many children may one

    health and safety of the children in care and caregiver supervise? caregiver supervise?

    decreases supervision issues. It also ensures Subchapter E, Child/Caregiver Ratios and Subchapter E, Child/Caregiver Ratios and

    children get more individualized attention from Group Sizes ,Division 2, Classroom Ratios and Group Sizes ,Division 2, Classroom Ratios and

    staff thus increasing the child’s ability to obtain Group Sizes for Centers Licensed To Care for Group Sizes for Centers Licensed To Care for

    higher quality individualization and care. 13 or More Children, 06/01/09 13 or More Children, 06/01/09

     NAEYC child staff ratios/ Headstart 0 11 months 4 0 11 months 4 0 11 months 4 4 12 17 months 5 12 17 months 4 12 17 months 4 4 18 23 months 9 18 23 months 4

     18 23 months 4 4 2 years 11 2 years 6 2 years 6 4 3 years 15 3 years 10

    3 years 10 2:10* 4 years 18 4 years 10

     4 years 10 2:17* 5 years 22 5 years 10 2:17* 6-8 years 26

     6-13 17 n/a 9 13 years 35

    * Head Start requires 2 teachers in every classroom. Affiliated with local Associations for the Education of Young Children, Southern Early Childhood Association and the National Association for the Education of

    Young Children

    TAEYC Comments on CCL revisions to Center Licensing Standards, Oct. 2009 Page 4 of 9

    Comments/Recommendations

    Texas Day Care Minimum Standards revisions

     5 years 10 6-13 17

    NAEYC /Headstart Group Sizes

    ?746.1609 ?746.1609 * Head Start and Early Head Start must What is the maximum group size? What is the maximum group size? have 2 adults in the room.

    Subchapter E, Child/Caregiver Ratios and Subchapter E, Child/Caregiver Ratios and Group Sizes , Division 2, Classroom Ratios Group Sizes , Division 2, Classroom Ratios 0 11 months 8 8 and Group Sizes for Centers Licensed To Care and Group Sizes for Centers Licensed To Care for 13 or More Children, 06/01/09 for 13 or More Children, 06/01/09 12 17 months 8 8 0 11 months 10 0 11 months 8 18 23 months 8 8 12 17 months 13 12 17 months 8 2 years 12 8 18 23 months 18 18 23 months 14 3 years 20 17 2 years (24 months) 22 2 years 16 4 years 20 17

     3 years 30 3 years 20 5 years 20 17

     4 years 35 4 years 28 6 8 years 30 n/a 5 years 35 5 years 30 9 13 years 30 n/a 6 8 years 35 6 8 years 30 9 13 years 35 9 13 years 30

     ?746.1305 ?746.1305

    Research clearly indicates that the higher level of What must be covered in the eight clock hours of What must be covered in the forty clock hours of

    training of those working with children, the higher pre-service training for caregivers? pre-service training for caregivers?

    level of care, thus children are more prepared to Subchapter D, Personnel Subchapter D, Personnel enter school ready to learn. The majority of people Division 4, Professional Development Division 4, Professional Development coming to work in child care have nothing more 09/01/03 09/01/03 than a high school education. Requiring more pre-(a) Before a caregiver can be counted in the (a) Before a caregiver can be counted in the service training better prepares caregivers to enter child/caregiver ratio, the caregiver must child/caregiver ratio, the caregiver must the classroom with the knowledge and skills needed complete eight clock hours of pre-service complete forty clock hours of pre-service to provide a quality program for children and training that covers the following areas: training that covers the following areas: impact outcomes and school readiness of the

    Affiliated with local Associations for the Education of Young Children, Southern Early Childhood Association and the National Association for the Education of Young Children

    TAEYC Comments on CCL revisions to Center Licensing Standards, Oct. 2009 Page 5 of 9

    Comments/Recommendations

    Texas Day Care Minimum Standards revisions

    (1) Child development knowledge and best children in care. (1) Developmental stages of children; practice, including knowledge about the (2) Age-appropriate activities for children; developmental stages of each child in care;

    (3) Positive guidance and discipline of (2) Age-appropriate activities for children; children; (3) Positive guidance and discipline of (4) Fostering children’s self-esteem; children;

    (5) Supervision and safety practices in the care (4) Fostering children’s self-esteem; of children; (5) Supervision and safety practices in the care (6) Positive interaction with children; and of children;

    (7) Preventing the spread of communicable (6) Positive interaction with children; and diseases. (7) Preventing the spread of communicable (b) If a caregiver provides care for children younger diseases. than 24 months of age, one hour of that (b) If a caregiver provides care for children younger caregiver’s pre-service training must cover the than 24 months of age, one hour of that following topics: caregiver’s pre-service training must cover the

    following topics: (1) Recognizing and preventing shaken baby

    (1) Recognizing and preventing shaken syndrome;

    baby syndrome; (2) Preventing sudden infant death (2) Preventing sudden infant death syndrome; syndrome; and and

    (3) Understanding early childhood brain (3) Understanding early childhood brain development development (4) Attachment in infancy and responsive care

    giving

    ?746.1309 ?746.1309 How many clock hours of annual training must How many clock hours of annual training must be obtained by caregivers? be obtained by caregivers?

    Subchapter D, Personnel Subchapter D, Personnel

    Division 4, Professional Development Division 4, Professional Development

    09/01/03 09/01/03

    Medium-High (a) Each caregiver must obtain at Medium-High (a) Each caregiver must obtain at Affiliated with local Associations for the Education of Young Children, Southern Early Childhood Association and the National Association for the Education of

    Young Children

    TAEYC Comments on CCL revisions to Center Licensing Standards, Oct. 2009 Page 6 of 9

    Comments/Recommendations

    Texas Day Care Minimum Standards revisions

least 15 clock hours of training each year. The 15 least 25 clock hours of training each year. The 25

    clock hours of annual training are exclusive of clock hours of annual training are exclusive of orientation, pre-service training requirements, CPR orientation, pre-service training requirements, CPR and first aid, and high school child-care work-study and first aid, and high school child-care work-study

    classes. classes.

?746.1311 ?746.1311

    How many clock hours of training must my How many clock hours of training must my child-care center director obtain each year? child-care center director obtain each year?

    Subchapter D, Personnel Subchapter D, Personnel

    Division 4, Professional Development Division 4, Professional Development

    03/01/08 03/01/08

    Medium-High (a) The child-care center director Medium-High (a) The child-care center director

    must obtain at least 20 clock hours of training each must obtain at least 30 clock hours of training each year. The 20 clock hours of annual training are year. The 40 clock hours of annual training are exclusive of CPR and first aid, orientation, and pre-exclusive of CPR and first aid, orientation, and pre-

    service training requirements. service training requirements.

     ?746.1317 ?746.1317

     Must the training for my caregivers and the Must the training for my caregivers and the

    Alignment with State or national Core Knowledge director meet certain criteria? director meet certain criteria?

    Areas, such as those used in the Child Development Subchapter D, Personnel Subchapter D, Personnel Associate (CDA) Credential, helps provide a career Division 4, Professional Development Division 4, Professional Development ladder and pathway for education for caregivers. 09/01/03 09/01/03 Texas Early Care and Development Career (a) Training may include clock hours or CEUs (a) Training may include clock hours or CEUs Development System (TECECDS) has Core obtained through: obtained through: Knowledge Areas for Practitioners (Classroom (1) Workshops or courses offered by local (1) Workshops or courses offered by local staff) , Directors and Trainers. These can be viewed

    school districts, colleges or universities, school districts, colleges or universities, at http://www.uth.tmc.edu/tececds/ckas.html

    Trainers in the Texas Trainer Registry or Trainers in the Texas Trainer Registry or

    Licensing; Licensing;

    (2) Conferences; (2) Conferences;

    (3) Self-instructional materials, excluding CPR (3) Self-instructional materials, excluding CPR Affiliated with local Associations for the Education of Young Children, Southern Early Childhood Association and the National Association for the Education of Young Children

    TAEYC Comments on CCL revisions to Center Licensing Standards, Oct. 2009 Page 7 of 9

    Comments/Recommendations

    Texas Day Care Minimum Standards revisions

    and first aid; and first aid;

    (4) Planned learning opportunities provided by (4) Planned learning opportunities provided by

    child-care associations or Licensing; or child-care associations or Licensing; or

    (5) Planned learning opportunities provided by (5) Planned learning opportunities provided by

    professional consultants or by a child-care professional consultants or by a child-care

    center director or caregiver that meets center director or caregiver that meets

    minimum standard qualifications. minimum standard qualifications.

    (b) All training must include: (b) All training must include:

    (1) Specifically stated learning objectives; (1) Specifically stated learning objectives;

    (2) Aligned with Core Knowledge Areas for the (2) A curriculum, which includes experiential or

    state of Texas; applied activities;

    (3) A curriculum, which includes experiential or (3) An evaluation/assessment tool to determine

    applied activities; whether the person has obtained the

    information necessary to meet the stated (4) An evaluation/assessment tool to determine objectives; and whether the person has obtained the

    information necessary to meet the stated (4) A certificate of successful completion from

    objectives; and the training source.

    (5) A certificate of successful completion from the training source

     ?746.2207 ?746.2207

    Television viewing by young children is not May I use TV/video and video games for May I use TV/video and video games for

    developmentally appropriate and the amount activities with children? activities with children?

    recommended by the American Academy of Subchapter F, Developmental Activities and Subchapter F, Developmental Activities and Pediatrics is most likely achieved in the home Activity Plan Activity Plan environment. Children best learn through hands on 09/01/03 09/01/03 experiences and activities to enhance social and

    emotional development through interactions with TV/video and video games may be used to TV may not be used with children under the age of others. supplement, but may not be used to replace, the 2. TV may be used for children ages 2 and older activities for children described in ?746.2417 provided the program being viewed is age and (relating to What activities must I provide for developmentally appropriate Video and video infants?); ?746.2507 (relating to What activities games may be used to supplement, but may not be Affiliated with local Associations for the Education of Young Children, Southern Early Childhood Association and the National Association for the Education of

    Young Children

    TAEYC Comments on CCL revisions to Center Licensing Standards, Oct. 2009 Page 8 of 9

    Comments/Recommendations

    Texas Day Care Minimum Standards revisions

    must I provide for toddlers?); ?746.2607 (relating used to replace, the activities for children described to What activities must I provide for pre-in ?746.2507 (relating to What activities must I

    kindergarten-age children?); and ?746.2707 provide for toddlers?); ?746.2607 (relating to What (relating to What activities must I provide for activities must I provide for pre-kindergarten-age

    school-age children?). If you use TV/video and children?); and ?746.2707 (relating to What video games as an activity for children, they must activities must I provide for school-age children?).

    be age appropriate.

    Best practice: The American Academy of

    Pediatrics (AAP) recommends no television

    viewing for children under age 2, and no more than

    two hours of daily media exposure for ages 2 and

    older. Because most children get this at home, no

    television viewing is recommended during the day

    at the child care center.

Thank you for this opportunity to provide comments. Please do not hesitate to contact us at the number below for additional

    information or questions.

Jackie L. Taylor Kris Curtis

    Program Director President

    TAEYC TAEYC

PO Box 4997 Austin, TX 78765-4997

    -800-341-2392 ~ Fax 512-419-1872 1

    Affiliated with local Associations for the Education of Young Children, Southern Early Childhood Association and the National Association for the Education of Young Children

    TAEYC Comments on CCL revisions to Center Licensing Standards, Oct. 2009 Page 9 of 9

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