Clearance Details and Comments

CCN# : 8850 - Five Year Review and New Rating Model for the Step Up To Quality Rating and Improvement System Date Sent for Review: 03/12/2024 Comment Deadline 03/26/2024 TRANSMITTAL(S)/COVERSHEET : CCMTL Five Year Review and New Rating Model for SUTQ    No Comment -- 3/12/2024 4:15 PM    Hello, For the standard regarding the continuous improvement plan, it never mentions completing a program self assessment (like the program administration scale). Classroom self assessments are mentioned in the previous standards (like the environmental rating scales) but there is no mention of the program self assessment. If it is not explicitly stated, programs will assume that it doesn't have to be completed. But if it's not completed, then what is the continuous improvement plan based on? I think it needs to be explicitly spelled out. -- (Internet) 3/12/2024 4:17 PM    The decreased ratio requirement for Gold is counterproductive. Our industry has been suffering and underfunded for a long time. Just when we are trying to get in compliance and increase rates to allow more resources for centers the requirement for those that are highly rated to reduce ratio basically eliminates spots and takes the increased revenue for increased tuition reimbursement right back out of our programs. This is a bad idea and is not helpful. -- (Internet) 3/12/2024 4:56 PM    I wanted to add a comment pertaining to the Ratio requirements for Gold Rating – Centers Only. The current proposal states that the requirement would be to have 50% of classrooms that are serving infants through school age, to meet lower ratios and group size. Quality standards are costly especially in an inflationary time and would prohibit Center providers from capturing additional dollars. I would offer programs the additional flexibility to pay for quality staff/higher education requirements, without tying the hands of center-based providers. This isn't a health and safety issue, it's a clear economic disadvantage and should be removed. -- (Internet) 3/12/2024 5:29 PM    These new payment standards is going to be detrimental to our budget. Not only are we going to have to let go some of our children to meet the lower ratio requirements but we also are going to suffer a loss in payment since we are moving from a 34% enhancement to a percentage in the 20's.It is regrettable that while highly rated centers would suffer a pay decrease when the 50th percentile is applied, centers without stars will see an increase in remuneration. That's akin to rewarding those who perform the bare minimum and penalizing those who go above and beyond the requirements of ODJFS license standards. The childcare industry has been financially struggling for some time, so when we learned that we will be pushed up to the 50th percentile in July 2024, we were all overjoyed. Our children deserve the best, therefore we calculated how to use these extra monies to pay our staff what they deserve and to modernize our classrooms. When we discovered that the new standards would ultimately result in a reduced payment, it was like a final kick in the face and left us childcare providers feeling like no one cares for the industry at all. Finally, I hope that a better solution can be implemented for gold-rated centers. Thank you for reading, and I hope you have a wonderful day. -- (Internet) 3/12/2024 6:34 PM    These new requirements, namely lower ratios, assessments, curriculum, and professional development will create a financial burden on many centers. A center can be high quality and have their own assessment process and documented curriculum without having to buy a program or boxed set from a list. OCCRRA is already behind on approving professional development on an employees profile, this is going to create a bigger burden on them as well. These proposals are going to hurt centers, and in turn make it more difficult for families to find care (less spaces in child care centers due to lower ratios, higher tuition rates because the difference has to be made up somewhere for the costs of new curriculum, assessments, professional development and less revenue due to lower ratios. -- (Internet) 3/12/2024 8:42 PM    No Comment -- (Internet) 3/13/2024 5:19 AM    Regarding ratios: – Centers Only : 50% of classrooms, serving infants through school age, meet lower ratios and group Are the 50% of classrooms designated that the same classrooms are always at the lower ratio or are they rotating 50% based on attendance? -- (Internet) 3/13/2024 5:24 AM    How will the new topic areas for professional development be assessed? Will this be assessed during inspections, on the Program Summary Report, and/or ERC? To ensure that a topic areas is addressed - Will it be the entire content that will be assessed? The title? Does it have to align with the CKCs and Ohio ELDS? What content encompasses "Trauma" or "Critical Conversations" etc? How will the professionals in the field know what PD they will need regarding selecting 2 topic areas? What are the guidelines? How will approved college coursework be assessed to align with the new topic areas? Appendix B for rule 5101:2-12-10 lists Professional Development Training Topics - how are these being assessed? Will these be relevant to rated programs and their PD? Will the varying CKC, ELDS, PD topics, and Step Up topics be combined at any time? -- (Internet) 3/13/2024 9:30 AM    Regarding the rule to have administrators train for an additional 5 hours per year: Why would we require the person with the most education and in most cases - experience ( I have been doing this 36 years) to take additional training? This is absurd. With the amount of work we must do as administrators this is the last thing we need - additional burden on our time. -- (Internet) 3/13/2024 10:08 AM    I would like to encourage the Department to find additional alternatives to the "lower ratio" requirement for Gold standard, so that there are more options for reaching the higher rating without reducing the number of high quality enrollment slots for children and their families. Additional education or professional development requirements or additional parent teacher conferences or family educational engagement opportunities could be added to allow Centers the choice on how they desire to achieve higher rating while maintaining higher quality. (FCC are exempted from this proposed lower ratio, so what is rational for requiring it for Center based operations?) -- (Internet) 3/13/2024 11:10 AM    I think the ratio reduction is not something that should be in the new model. Not only does it lessen the money the providers will receive, it's also limiting spots to enroll children in the current child care crisis we already have. My waitlist is 2-3 years long! We don't have enough spots for the families who need care, why would we reduce the spots we already have now? It will force center's to drop Step Up To Quality all together. -- (Internet) 3/13/2024 11:56 AM    No Comment -- (Internet) 3/14/2024 8:48 AM    If we are truly trying for ODE & ODJFS programs to work hand and hand, PLEASE get all Early Education (ODJFS) form on a system like the schools have (Final Forms). Parents could create and account when starting into early education and continue into primary schooling. This system works so much better than what ODJFS has us doing - Nothing is automated. Having an automated system would be more convenient for parents, save time, reduce the number of mistakes and missing documents for medications and health conditions. If we are trying to generate more spaces for an already limited access to quality childcare, why lower the ratios. It is not financially feasible for most programs to lower ratios when they are trying to increase wages for workers. -- (Internet) 3/14/2024 10:16 AM    5101:2-17-01 (6) "Instructional Time" (b) My suggestion is to include the language of "assigned" to the classroom so that if a teacher is off or a substitute is used in the classroom for that assigned "lead" or "assistant" teacher we are not out of compliance for not having them that day. -- (Internet) 3/14/2024 11:05 AM    There needs to be more clarity with the star rating for programs that are designated to be "continous rating" If we don't expire then we wouldn't need to apply but how will the visits work for us? Will they occur annually or will they be desk reviews? If I am currently a 5 star continous rated program will I automatically roll into a gold status? -- (Internet) 3/14/2024 11:09 AM    As you look at changing the SUTQ program, I would like to request that you include a way that NAEYC and Conscious Discipline training would count as part of SUTQ moving forward in 2025. It literally was keeping me awake Saturday night because NAEYC accreditation is a way to receive points for SUTQ yet their trainings do not count as anything. Conscious Discipline is recognized by the Substance Abuse and Mental Health Administration's National Registry of Evidence-based Programs and Practices (NREPP), which promotes the adoption of scientifically established behavioral health, yet we do not get credit for these trainings. I found myself unable to sleep and thinking about this subject because I do not know how much longer we can continue to send our teachers to these trainings without it counting for anything. Our program has grown significantly in the quality care we provide because of our teachers attending training by these two organizations. We are a very small preschool licensed for 30 kids that use Conscious Discipline and are NAEYC accredited. We choose to invest in NAEYC and Conscious Discipline because we have seen the change in our families and the children enrolled in our program learn Conscious Discipline skills. However, our teachers do not receive any credit when they take the courses. It even stated in Phase 3 and 4 of the Stabilization Grants that we could use the funding for Conscious Discipline trainings and materials; however, the teachers did not receive any credit for these trainings on the OPDN. The same is true for the NAEYC trainings. I urge you to please address this problem as you are realigning the SUTQ program. It is time to recognize trainings by both nationally accredited organizations as quality and give our teachers credit for their training hours because both these organizations bring quality into the classroom because of what they have learned in trainings provided by NAEYC and Conscious Discipline. Lastly, the other topic that keeps me awake at night is the misalignment in our state over how teachers in childcare cannot renew their Pre-K teacher license in Ohio with CEU’s while those in the public schools can renew the same degree with CEU’s. Teachers in Childcare work all year, are paid less, and have college debt that will take longer to get paid off because the lower salary they are paid. Yet, Ohio makes them accrue more debt to renew their license because they work in a childcare. Please give the teachers working in childcare the same option to renew their teaching license with CEU’s instead of building more debt to renew their teaching license. I had $80,000 in student loans when my teaching license expired in 2018. Adding more debt to renew my teaching license was not an option for me because I couldn’t afford to take more college courses to renew it. Many teachers are in the same boat who work for ODJFS licensed organizations. -- (Internet) 3/14/2024 11:19 AM    No Comment -- 3/14/2024 3:02 PM    No Comment -- 3/14/2024 3:02 PM    The new ratio requirement is going to make a big financial negative impact on childcare and preschool programs. I am a smaller center. My license is for 37 children, and if I want to be a Gold center then I have to lower my ratios by 4 children. This would bring me down to 33 children. I would have to lower my infant class by 2 children, toddler class by 1 child and preschool class by 1 child. This would financially cause me to lose $42,574.48 each year. I have taken into consideration the 50th percentile increase. Losing this amount of money will be very difficult and cause a major burden on my new center. This will make it harder for me to pay my highly qualified staff a higher wage. You want us to provide a high quality program, but how do we do this when we can't pay and sustain higher quality staff? Making programs lower their ratios, especially smaller programs could be financially devastating for them. Families need more childcare throughout Ohio, but yet by making us lower our ratios will make it even harder for families to find availability in childcare programs. This will have an overall negative impact on our families and cause even more of a gap to provide higher quality childcare. -- (Internet) 3/14/2024 3:34 PM    5101:2-17-01(A)(1) - Please consider adding “or” between (c) and (d) to clarify that an administrator does not need to meet all definitions listed. Appendix A CA1 - Please consider more clearly defining what “availability of curriculum materials” means. Does each classroom need its own set of curricular materials, or can the materials be stored in a common location and shared among teachers? Appendix A CS2 - Please consider more clearly defining what “refer” means. Does this mean referral to a school district, community agency, or something else? What if the program’s first step is MTSS paired with a rescreen in 2-3 months? Does that count as a referral? Appendix A PD1 - Since we are in the middle of the biennium, will staff who already completed 20-30 hours of PD this school year be exempt from the requirement next year? Appendix A Staff/Child Ratios - Please consider holding Centers to a lower ratio standard for gold ratings. 5101:2-17-03(B)(1) - Is it possible for everyone just go through the same review process rather than requiring programs to apply for a certain level beforehand? -- (Internet) 3/15/2024 9:25 AM    I just review Appendix A to Rule 5101:2-17-01 regarding the new SUTQ levels. I really don't care for the divisions; bronze, silver, gold. I really don't have a good suggestion other than to stick with the 5 star rating with the "gold" level, make the 3 star rating the "silver" and the 1 star rating the "Bronze" so it would be three levels at a 1,3,or 5 star rating. I like the simplification of the benchmarks. I believe the Curriculum and Assessment for the school age group to align with the K-12 Learning Standards is not practical. We have the children for 2.5 hours each morning before school and then 3 hours after their school day. In my 48 years of experience in Early Childhood Education the children that come to us need to play board games, card games, do crafts, learn to sew or embroider, crochet, have pretend play, and just "hang out". We try to focus on social skills, accepting each other's differences, expressing themselves appropriately, and sharing with each other without being judged. During the full day of the summer we run our program like a day camp with themes and visitors. I believe our school age children need time without electronics and to be with each other. Another item I would like to address is the additional 5 hours of PD time per staff member on the gold level. This will cost my center an additional $800.00 a year which does not account for registration fees. The last item that has been a concern is when my staff with their CDA can be on a CPL 3 June 30th and then drop back to a CPL 2 July 1st. It is like we are out of compliance until we can get then 10 hours of PD to be move back up to the CPL 3 again. -- (Internet) 3/15/2024 1:42 PM    Thank you for looking deep into Step Up to Quality and deciding some changes are needed. While I prefer to use most of the previously required forms there have been occasions that a form with additional information suits by program better. I appreciate that you are removing the requirement of required forms however I would like to see those forms still available as a template in Forms Central for those of us who prefer to use them. While I am a family child care provider and thankful that the lowering the ratio for the level Gold is not required for us. I do feel that it puts a huge loss of funding for those centers who are barely getting by now. There are so many children out there needing childcare, I feel this is a step backwards in getting them placed. As far as the mention of the Assessment Tool from the aligned list, when will information that be made available to us? I think that it is great that we are doing referrals for families and children but 30 days just is not enough time for families to reach out to the various service providers to get their needs met. I have a family that has been on the waiting list for services since August and there is not projected date for when they will receive services needed. A sixty-to-ninety-day follow-up time would be a better time-frame. Will there be a template provided for referrals where we can add follow-up information to it or shall we begin creating our own document for this? When it comes to identifying the needs of the family, I have a family needs survey for my families and have just begun to utilize it. How are we to keep track of whether or not families respond to this and what their needs are? Will a template be provided for this also or shall we begin creating our own system to track this? With the requirement of professional development requiring at least two of the specific listed topics, how are we to determine that our employees are all meeting this goal? Are we to individually search each titled PD for each employee for the topic or the PD or will this be broken down in OCCRRA. And can this be added to the Employee Checklist or broken down by topic in the training summary? Will a template be provided for tracking this information if not? Again, I am a family child care provider which means I am the owner, administrator and lead teacher. With that being said, is this saying that family childcare providers will need an additional 12 hours for a PD2 and 15 hours for a PD3 in addition to or in place of the current 20 hours over the biennium for a 5 Star program? If so, how will this administrator training be separated from the above-mentioned required PD and those topics? When it comes to identifying the needs of the family, I have a family needs survey for my families and have just begun to utilize it. How are we to keep track of whether or not families respond to this and what their needs are? Will a template be provided for this also or shall we begin creating our own system to track this? Thank you for taking our comments into consideration, Tammy G -- (Internet) 3/15/2024 2:08 PM    Thank you for giving early care and education professionals an opportunity to review and provide comments on the proposed changes to Step Up to Quality in chapter 5101:2-17. Focusing on the benchmarks that have the largest impact on child outcomes is what we all want and is ultimately why we do what we do. I appreciate the proposed removal of required forms and extra points for 4 and 5 stars. These changes simplify the program and reduce time spent on administrative tasks. I also love that all rules for all early care and education professionals have been consolidated into the same chapter. This will help unify the different environments and field overall. My main concern with the changes is that lowering ratio requirements for Gold puts many programs in a position to have to choose between high quality programming and financial stability. Without more funding, many programs will simply not be able to provide lower ratios even though we all know this will lead to better child outcomes. Additionally, lower ratios means fewer children being cared for. With the national child care crisis, staffing is a major challenge and programs will not be able to keep all of their current students enrolled if they choose to Gold. Page 1 of Appendix A, CA2 states “verification that the assessment tool is aligned from the verified list,” but no list is attached and the website list is blank. Where can I find the verified list? https://education.ohio.gov/Topics/Early-Learning/Early-Learning-Content-Standards/Standards-Curriculum-Assessment-Alignment Page 2 of Appendix A, CS3 states “follow-up with families within thirty days from date of referral to determine if the family/child’s needs are being met for services.” We often find it takes families this long to even get in touch with a school district or specialist for a first meeting. Ideally 30 days would be plenty of time, however, a 60 day follow up would be more realistic. Page 2 of Appendix A, SC1 states “Centers: complete an annual self-assessment for each group of children.” Does this mean centers need to do an OCOT for each room or is this referring to the previously required environmental rating scales such as ITERS/ECERS? Will there be an approved list of tools provided for this benchmark? Page 4 of Appendix A, PD1 states “PD topics must include at least 2 of the following:” Will OCCRRA/OPR track this or will this be an additional task for administrators to track? Either way, administrators can only see when a training or uploaded document has been verified which can take up to 45 days. It is imperative that administrators have more access to viewing the OPR accounts of our employees such as when a training or document is waiting to be verified. Page 4 of Appendix A, PD2 states “Administrators…12 hours annually.” And PD3 goes up to 15 hours. Typically, administrators already have higher levels of education than teachers. Can you explain why you then want administrators to have more training than teachers? Teachers with less than 5 years’ experience should be required to have the most training so that they feel confident in their role. More training for these individuals will be beneficial for retention purposes. If this change stands after the clearance period, how will you ensure that additional OA leadership trainings are offered? Page 4 of Appendix A, PD2 states “Professional’s choice of OA training on the additional 2 hours.” Can you explain what this means? How is this different than the choices we have on the first 10 hours or training? Page 5 of Appendix A, FCP1 states “Programs utilize a tool that identifies the needs of the whole family…” Will there be a list of approved tools or can it be self-made? Will community resource contact information be provided by county? It would be helpful to have a website that we could point families to as a one stop shop experience for common referrals to meet this requirement. Page 5 of Appendix A, Ratio Requirements for Gold states “Centers Only: 50% of classrooms…” Does that mean that ODE programs are required to meet these ratios at 100%? Why would they not have the same requirements as centers? Thank you again for working to unite our field and focus on child outcomes. -- (Internet) 3/15/2024 3:04 PM    Professional Development 1. Annual PD Requirement – please define what the year schedule is. 2. 8 PD Topic Areas a. Consider aligning to Core Knowledge and Competencies b. Consider identifying at least two Ohio Professional Registry (OPR) Available Trainings (AT) for each of the 8 proposed topic areas. When a professional completes these trainings, they will automatically be added to their OPR profile, which will return the “yes” statement to the Employee Record Chart (ERC) for licensing/SUTQ reviews. 3. Acceptance of College Coursework to meet the PD requirement. a. This should be included for all level (Bronze, Silver, and Gold) and for Administrators. b. We want to encourage professionals seeking higher education. Consider not trying to align individual courses to PD topics and streamline the process. Professionals provide a transcript with their declared major and includes the grades received during that year. If the major declared is early childhood education or child development, that is all that is needed. If they have a related degree, degree course plan may be needed to show there is at least 12 credit hours expected in early childhood/child development. 4. Changing to annual requirement vs. every other year a. Consider that the past professional development biennial process now becomes an annual process. For the current PD Certification process the state continues to provide extensions for the professionals to complete their new PD requirement after the biennium closes. b. This change means that our systems, reporting and extensions that occur every other year happen every year. This may cause an administrative burden as programs struggle to remain compliant and while one year is winding up, the next year notifications may begin. Ratios 1. Consider removing the Ratio Requirements for Gold Rating – Centers Only: 50% of classrooms, serving infants through school age, meet lower ratios and groups sizes statement. At the department has proposed exempting Family Child Care programs from this lower ratio requirement for the SUTQ Gold level, it would make sense to offer the same exemption/consideration to center-based licensed child care programs by maintaining ratio and group size requirements per the child care licensing rules for ratio and group size. 2. As center-based licensed child care programs are currently still rebounding from the drop in enrollment from the COVID Pandemic, most programs are operating at reduce capacity and ratios. This requirement adds administrative burden and oversight to both the licensed child care programs and the state. The proposed SUTQ standards move the use of curriculum and assessments into the SUTQ Bronze level, the intention behind this requirement is no longer needed. -- (Internet) 3/18/2024 1:12 PM    Professional Development 1. Annual PD Requirement – please define what the year schedule is. 2. 8 PD Topic Areas a. Consider aligning to Core Knowledge and Competencies b. Consider identifying at least two Ohio Professional Registry (OPR) Available Trainings (AT) for each of the 8 proposed topic areas. When a professional completes these trainings, they will automatically be added to their OPR profile, which will return the “yes” statement to the Employee Record Chart (ERC) for licensing/SUTQ reviews. 3. Acceptance of College Coursework to meet the PD requirement. a. This should be included for all level (Bronze, Silver, and Gold) and for Administrators. b. We want to encourage professionals seeking higher education. Consider not trying to align individual courses to PD topics and streamline the process. Professionals provide a transcript with their declared major and includes the grades received during that year. If the major declared is early childhood education or child development, that is all that is needed. If they have a related degree, degree course plan may be needed to show there is at least 12 credit hours expected in early childhood/child development. 4. Changing to annual requirement vs. every other year a. Consider that the past professional development biennial process now becomes an annual process. For the current PD Certification process the state continues to provide extensions for the professionals to complete their new PD requirement after the biennium closes. b. This change means that our systems, reporting and extensions that occur every other year happen every year. This may cause an administrative burden as programs struggle to remain compliant and while one year is winding up, the next year notifications may begin. Ratios 1. Consider removing the Ratio Requirements for Gold Rating – Centers Only: 50% of classrooms, serving infants through school age, meet lower ratios and groups sizes statement. At the department has proposed exempting Family Child Care programs from this lower ratio requirement for the SUTQ Gold level, it would make sense to offer the same exemption/consideration to center-based licensed child care programs by maintaining ratio and group size requirements per the child care licensing rules for ratio and group size. 2. As center-based licensed child care programs are currently still rebounding from the drop in enrollment from the COVID Pandemic, most programs are operating at reduce capacity and ratios. This requirement adds administrative burden and oversight to both the licensed child care programs and the state. The proposed SUTQ standards move the use of curriculum and assessments into the SUTQ Bronze level, the intention behind this requirement is no longer needed. -- (Internet) 3/18/2024 2:12 PM    For the new guidelines for SUTQ, I have a couple of questions. For the referrals of children based on screenings and needs, the new guidelines say that a Gold level will have to follow up within 30 days to ensure that the needs are being met??? Can you please elaborate on this? How are we to ensure needs are being met? Do we just take parents/families at their word? We can't force families to take the help we offer. For Professional Development for a Gold level. 15 hours of training will be required annually. Will we have access to more trainings? It's rather difficult to find trainings on OCCRRA that I have not already completed. It's impossible to attend live trainings without having to take time off, which causes a hardship for families. Our JOB is to be here FOR the families NOT to cause hardships for them. Can some new trainings be made available to us online? -- (Internet) 3/18/2024 2:18 PM    Ratio requirement: There is currently a childcare crisis in Ohio, and not enough centers to provide open slots to children. By lowering the ratio for Gold rated programs you are: 1) Making it so there is less childcare options for families. Every center in our area has a waiting list. We cannot cut slots and put families at risk of not finding childcare. 2)Forcing some programs to release families from care. We are 100% fully enrolled and to become a gold program we would have to "fire" families from the center. 3)Possibly cutting income to centers, as the loss of children will not always make up for the income differential. -- (Internet) 3/18/2024 3:33 PM    Thank you for giving early care and education professionals an opportunity to review and provide comments on the proposed changes to Step Up to Quality in chapter 5101:2-17. Focusing on the benchmarks that have the largest impact on child outcomes is what we all want and is ultimately why we do what we do. I appreciate the proposed removal of required forms and extra points for 4 and 5 stars. These changes simplify the program and reduce time spent on administrative tasks. I also love that all rules for all early care and education professionals have been consolidated into the same chapter. This will help unify the different environments and field overall. My main concern with the changes is that lowering ratio requirements for Gold puts many programs in a position to have to choose between high quality programming and financial stability. Without more funding, many programs will simply not be able to provide lower ratios even though we all know this will lead to better child outcomes. Additionally, lower ratios means fewer children being cared for. With the national child care crisis, staffing is a major challenge and programs will not be able to keep all of their current students enrolled if they choose to Gold. Page 1 of Appendix A, CA2 states “verification that the assessment tool is aligned from the verified list,” but no list is attached and the website list is blank. Where can I find the verified list? https://education.ohio.gov/Topics/Early-Learning/Early-Learning-Content-Standards/Standards-Curriculum-Assessment-Alignment Page 2 of Appendix A, CS3 states “follow-up with families within thirty days from date of referral to determine if the family/child’s needs are being met for services.” We often find it takes families this long to even get in touch with a school district or specialist for a first meeting. Ideally 30 days would be plenty of time, however, a 60 day follow up would be more realistic. Page 2 of Appendix A, SC1 states “Centers: complete an annual self-assessment for each group of children.” Does this mean centers need to do an OCOT for each room or is this referring to the previously required environmental rating scales such as ITERS/ECERS? Will there be an approved list of tools provided for this benchmark? Page 4 of Appendix A, PD1 states “PD topics must include at least 2 of the following:” Will OCCRRA/OPR track this or will this be an additional task for administrators to track? Either way, administrators can only see when a training or uploaded document has been verified which can take up to 45 days. It is imperative that administrators have more access to viewing the OPR accounts of our employees such as when a training or document is waiting to be verified. Page 4 of Appendix A, PD2 states “Administrators…12 hours annually.” And PD3 goes up to 15 hours. Typically, administrators already have higher levels of education than teachers. Can you explain why you then want administrators to have more training than teachers? Teachers with less than 5 years’ experience should be required to have the most training so that they feel confident in their role. More training for these individuals will be beneficial for retention purposes. If this change stands after the clearance period, how will you ensure that additional OA leadership trainings are offered? Page 4 of Appendix A, PD2 states “Professional’s choice of OA training on the additional 2 hours.” Can you explain what this means? How is this different than the choices we have on the first 10 hours or training? Page 5 of Appendix A, FCP1 states “Programs utilize a tool that identifies the needs of the whole family…” Will there be a list of tools available or can it be self-made. Will community resource contact information be provided by county? It would be helpful to have a website that we could point families to as a one stop shop experience for common referrals to meet this requirement. Page 5 of Appendix A, Ratio Requirements for Gold states “Centers Only: 50% of classrooms…” Does that mean that ODE programs are required to meet these ratios at 100%? Why would they not have the same requirements as centers? Thank you again for working to unite our field and focus on child outcomes. Sincerely, Leah Anastasakis, M.Ed. Child Care Manager University Hospitals Parma Medical Center -- (Internet) 3/19/2024 10:38 AM    The new SUTQ rating system would group 1 and 2 star rated programs together and lower their paid percentage above base rate for PFCC vouchers to 10%. Currently 2 star rated programs receive 18% above base rate. That's almost a 10% reduction in payments for students who receive PFCC vouchers. In addition to lowering the incentives for a provider to continue to climb the SUTQ ladder towards higher ratings, this will continue to increase the ever growing challenge for providers to be able to afford the cost of maintaining a daycare center. The cost of adequately staffing the center with qualified and educated lead teachers and assistant teachers has risen very sharply in the past few years and due to the challenge of funding, maintaining the requirements of SUTQ has become extremely burdensome. We worry that this may affect the ability for centers to continue to provide quality care for children. -- (Internet) 3/19/2024 6:39 PM    I am writing to voice my concern about the gold ratio requirement in the new SUTQ system. Lowering the ratio requirements in the new SUTQ system could have several potential consequences. First, it could exacerbate the current staffing crisis in childcare by making it even more difficult for centers to find and retain qualified staff. Second, it could increase financial hardship for centers as they would need to allocate more resources to hire additional staff. Lastly, lowering the ratios would result in a decrease in the number of children that centers can accommodate, ultimately limiting access to high-quality early education for many children. This would further contribute to the existing disparities in access to quality childcare, with lower-income and minority families being the most impacted. I ask that you reconsider this requirement to allow more centers to obtain the highest rating and still be able to care for the same number of children as they do currently. This would help ensure more families are able to access quality childcare, and that childcare providers are not put at a disadvantage. Additionally, this would help ensure the highest standards of care for all families. Thank you for your time and consideration. -- (Internet) 3/20/2024 9:10 AM    Appendix A: Staff/Child Ratios - consider change in ratio requirements for preschool special education programs / classrooms due to the severity of needs potentially outweighing the max ratio. Also, all programs should have to meet the ratio's at 100%. Consider, reducing the ratio's along the NAEYC guidelines to improve quality. Child Screening: Clarify the word "refer". Is it the same as a special education referral or is it providing access to additional school and community resources (interventions)? Also, revise the timeline for suggestions to families to allow more time to meet, interact and observe children along the same lines of the ELDS developmental continuum as a support (intervention) and not a push to over identify children for special education before they are allowed time and space to be exposed, learn and grow. 5101:2-17-01 Item 6b - clarify if the lead teacher must be present each day the class is in session or the entire day on the days they are present. Item 9 - Clarify the requirements of a substitute especially when in the classroom for longer than just day to day assignments. Also, define "substitute". Item 6b and Item 6c - Clarify the setting and who qualifies as a co-lead teacher i.e. in the co-taught setting, both the general education teacher and the intervention specialist are highly qualified professionals and collaboratively teach and are responsible for supporting the needs of all students. Staff: Child/Adult Interactions - Include OCOT for Bronze. Clarify the difference between Silver and Gold. Implementation or achievement is lacking. Consider explicit clarification instead of implying this difference to prove quality. Consider a continuum for each step and the frequency of on-site visits. -- (Internet) 3/20/2024 11:13 AM    5101:2-17-01(A)(1) - Add “or” between (c) and (d) to clarify that an administrator does not need to meet all definitions listed. Appendix A CA1 - More clearly define what “availability of curriculum materials” means. Does each classroom need its own set of curricular materials, or can the materials be stored in a common location and shared among teachers? Appendix A CS2 - More clearly define what “refer” means. Does this mean referral to a school district, community agency, or something else? What if the program’s first step is MTSS paired with a rescreen in 2-3 months? Does that count as a referral? Programs should be required to comply with their screening material “next steps.” If the screening states interventions are put in place or further assessment data is needed. Programs should need to provide documentation of those steps which may include referral to SPED. Appendix A SCI2/SCI3 - There is no difference between a silver and gold rating. Should the options for this standard just be bronze or gold? Appendix A PD1 - Since we are in the middle of the biennium, will staff who already completed 20-30 hours of PD this school year be exempt from the requirement next year? Appendix A Staff/Child Ratios - Centers should be held to a higher standard for gold ratings. Twenty-six children in a 48 month classroom is too high. Ohio already scored low on the NIEER Standards, a bronze, silver and gold rating should be better than state max ratios. Ratios of this size don’t allow teachers to meet the individual needs of students nor does it support an inclusive environment for children with IEPs that need more support. 5101:2-17-03(B)(1) - Why do programs still need to apply for a rating level at registration? Can’t everyone just go through the same review process? 5101:2-17-01(6)(a) The lead teacher is to interact with children a minimum of three and on-half hours daily for at least half the days of each week the program operates. Language needs clarified. This reads that if a child attends 4 days a week a lead teacher would only need to be present 3.5 hours 2 days/week. Language needs to be specific to require planning time for lead teachers weekly or daily. 5101:2-17-01(6)(b)(c) Co-lead teacher needs to be defined. Co teacher may also need to be defined as it’s used in specifically in Special Education as an LRE. 5101:2-17-01(7) Again this states that lead only needs to be there for more than half-of the days in operation each week. Leads should be present daily for the duration required. General Questions/Comments (may need to be categorized): On the second page first bullet, it states that “benchmarks should result in better child outcomes. Increasing ratios, or only requiring 50% of classrooms to maintain those lower ratios does NOT improve child outcomes. Are districts required to participate? What rating level will districts be required to sustain? On the rubric for Admin and Leadership practices: The OCOT should be conducted at all levels. How can quality be judged if classrooms haven’t been observed. SUTQ should not be about the paperwork. Observation should be the most highly weighted. Science of Reading Training should be required in some fashion for all programs seeking SUTQ ratings. ELDS Standards Training should be required for all programs seeking SUTQ rating. ELA Training and completion of the priority SKBs should be required for all programs seeking SUTQ rating This would allow the state to monitor impact on student learning. SUTQ Approved curriculum should be aligned with research and evidence based practices. Just because something is aligned does not deem it quality. 100% of classrooms should have a reduced ratio at the gold level. This creates inequities in the classroom level. There should be a continuum for how often programs are observed. For example a gold program is observed every 5 year, silver every 4 years, bronze every 3. -- (Internet) 3/20/2024 11:15 AM    Ratios: We are concerned that only 50% of the classrooms need to maintain the appropriate ratio for level 3. Lesson Planning: The requirement could use more details about planning. Substitutes: The requirements for short-term subs should be more clear. Why do we require our subs to have CPR and First Aid when there is someone in the classroom with that training? There is a significant shortage of subs across the state. -- (Internet) 3/20/2024 11:23 AM    Family And Community Partnerships: Family Partnerships/Community Resources. The follow up with families on referrals provided, within 30 days from the date of referral, to determined if needs are met is an impossible task for districts serving hundreds of preschoolers. We don't have staff to manage this. -- (Internet) 3/20/2024 11:38 AM    Having substitutes with a licensing file is nearly impossible. Requiring all staff in ratio to have CPR and First aid is a challenge. As long as 1 person in the ratio has the training it should suffice. Financially, the staff turnover within the program or the district is nearly impossible to include teachers of specials which can change from trimester to trimester or year to year. Also, related service providers vary and are frequently contracted out and follow different guidelines according to their organization. -- (Internet) 3/20/2024 1:19 PM    Pg. 9 6(a) is not clear. Does the teacher only have to be in the classroom for half of the week? Definition of Substitute is not clear... Too difficult to find in the Administrative Code. Several of us have been looking but we can't find the definition. Very confusing. Do they need a degree, training, etc? If not, that would be great. Appendix A to Rule 5101:2-17-01 : We use Creative Curriculum Fourth Edition. I've contacted Creative Curriculum to see if they would align the fourth edition. They didn't answer but rather wanted me to purchase a new curriculum with them totalling over $15,000 and up to $30,000 with yearly fees... To me, this is a money grab on the part of the distributors. They see this as an opportunity to make money off of us. Would there be a way to use our previous alignment which was aligned to the old standards? Pg. 13 Child Screening: for Silver and Gold are you asking districts to refer these children for a developmental screening to determine if the children have a suspected disability and then move to an evaluation or are you requiring us to provide RTI? This is confusing to me. We would normally provide interventions within the classroom and document progress unless a referral for an evaluation for special education is necessary. With the shortage of substitutes, would it be possible to refrain from requiring substitues to have a complete file even if they are counted in ratio as long as the other adult has all of the requirements completed? This question for Speech Therapists, Occupational Therapists, and physical therapists as well. Often times, these people are contracted out and it becomes a burden to send a staff member with the therapist due to staff shortages and maintaining ratio. Can there be a tiered visit schedule as well? For example Bronze gets an onsite visit every 3 years, Silver every 4 year, Gold every 5 years? Page 16: Family & Community Partnerships: The requirements in this standard would require an entire staff memeber -- (Internet) 3/20/2024 2:06 PM    you guys need to leave sutq alone.... EXCEPT fcc type b they are not considered type a or centers why does a CKC have to be done its not geared for type b -- (Internet) 3/20/2024 3:40 PM    Hello I wish you guys would involve the provider's in this decision process. I'm not happy with the changes. -- (Internet) 3/21/2024 1:50 PM    I appreciate the work done to balance the needs for federal compliance, the support of and guidance towards high quality programming, and minimizing the administrative burden on programs. Some of the changes are very positive with meaningful impacts for children. The meaningful, quality requirements (curriculum, screening, self-assessments, and improvement planning) for a bronze rating will significantly increase the quality of care that children receive in these programs. The removal of the biennium structure, the support of quality training through topic requirements, and increased administrator hours at higher level strengthens the Professional Development of teachers and administrators in the field. I am concerned that some of the changes are counterproductive to ensuring that quality programming is available to all of Ohio’s children. What is the structure to ensure that current CPL3 teachers (with CDAs or unrelated degrees) will maintain their qualifications without the PD certificate and additional points? The ability to reach the required teacher credentials without this structure is contradictory to the current system and the partnership between CDAs and on-going training to ensure quality teachers stay on the ECE space. The lower ratios and group sizes in the current proposal decreases the number of children that have access to the highest quality care. This is in direct opposition to the goal of providing high quality care to as many children as possible. Proper classroom design, materials, and management allows for extremely high-quality care with the state of Ohio ratios. The current proposal also does not have a double ratio for School Age children at the gold rating, which would decrease the available School Age spaces by more than half. Lower ratios and group sizes hinder a program’s financial viability while providing reasonable wages for employees and reasonable tuition for families. The requirement that the curriculum and assessments used by SUTQ programs be on a verified list is vague without the availability of the list and requirements to submit these systems for approval. The requirement of high-quality, established classrooms to change their curriculum and assessment processes is extremely detrimental to quality education. I work with 47 schools throughout Ohio, and I would like to know the best contact for questions and support. Thank you. -- (Internet) 3/21/2024 7:12 PM    Please further define referrals and the 30 day referral follow up for the child screening and family/community partnerships community resources sections. Regarding raising the administrator's professional development to 15 hrs annually, this may be hard for school districts due to teacher contracts and the main administrator overseeing classrooms in many buildings. Please change to this not needing to be the "onsite" administrator who has 15 hrs vs 10. rating a new program: If we're moving one classroom from one school building to a new building, but there are still preschool classrooms in both buildings, can the new SUTQ rating stay with the initial building AND go to the new building? -- (Internet) 3/22/2024 8:31 AM    This may be an opportune time to add language that specifies the following: Child Care providers are required to provide care 40 hours a week/5 days a week to achieve and maintain the Gold Rating award. This would assist many to reenter the workforce and maintain full time employment. -- 3/22/2024 8:47 AM    I am opposed to the new proposed changed to the five star rating system for childcare educators and would like to see it remain the same. -- (Internet) 3/24/2024 9:58 PM    Thank you for the opportunity to comment on proposed changes to SUTQ. I have several comments and questions. 1.I am pleased to see a ratio requirement for the Gold level. Ratios are an indicator of quality. It’s better for children and for staff. 2. I am disappointed about the lack of requirements around staff supports/benefits. Retention of staff is important and eliminating requirements that encourage staff to stay in the field is concerning. 3. For PD2 and PD3 I would suggest that teaching staff have a PD requirement 10, 12, 15 like administrators. 4. I would like clarity about things that are no longer requirements. Are any of the following required: staff formal observations, annual review for staff, ELA, staff PD plans, family engagement plan? A document listing things that are no longer needed would be appreciated. 5. For the new requirement, FCP1, the tool that identifies family needs, will there be a sample? 6. For the FCP3, a 90 day follow-up would be better. 7. For the education training or event in FCP3, would having two events or two workshops meet the requirement? 8. Programs that are accredited by organizations like NAEYC should be at a Gold rating as the requirements are much more rigorous than SUTQ. -- (Internet) 3/25/2024 11:22 AM    Is there a possibility of preschools located in a school building apleady approved for educational services and taught by a teacher with a BA or MA in early childhood education, to just report to the DEW and not also JFS. It seems like the evolving nature of preschools now being a function of K-12 education in so many cases, are still subject to the same rules as in-home preschools taught by individuals with a high school diploma. This creates a duplicate bureaucracy. Thank you -- (Internet) 3/25/2024 11:27 AM    As always it is appreciated anytime increase are made to reimbursement rates for PFCC. As a 5 Star center that provides care for primarily PFCC families these changes are necessary and tremendously needed, however, with changes to the structure of the SUTQ program these changes virtually wipe out most of the increases to the base rates. At my center if I transition to a Gold center, which I plan to do, I will see a 6% decrease to infant full time rates, 3% decrease to infant part time rates, 10% decrease to infant hourly rates, 7% decrease to toddler full time rates, 1% increase to toddler part time rates, 6% increase to toddler hourly rates, 6% decrease to preschool full time rates, 3% increase to preschool part time rates, 8% increase to preschool hourly rates, and no real change to school age rates. When I decrease ratios to 50% of my classrooms to maintain the gold level any small increases in these categories is completely wiped out and my center will experience a loss due to the changes. In addition, my center will have less available spaces because we will be forced to decrease ratios to provide the highest level of quality care. Once again the staff that works so hard to maintain and improve ECE will have to suffer. Through the use of stabilization grants I was able to increase staff wages by approximately 25%. We are still struggling to hire new staff, as our starting wages are $12.50-$13.00/hr. My hope was to increase starting wages to a minimum of $15.00/hr to at least compete with what 16 year olds are now paid at fast food restaurants. With this decrease to revenues I can only foresee the staff shortages we are experiences in this industry as a whole to be further exacerbated. At this point my center is already having to consider not filling available spaces to maintain ratios with the staff I have available. The only way this changes makes sense is to either increase the percentage offered for gold level programs or eliminate the mandate for lower ratios at the gold level. -- (Internet) 3/25/2024 6:07 PM    To whom it may concern: I would like to thank you for giving early care and education professionals an opportunity to review and provide comments on the proposed changes to the Step Up to Quality Rating System. Professional Development 1. Annual PD Requirement – please define what the year schedule is. 2. 8 PD Topic Areas a. Consider aligning to Core Knowledge and Competencies b. Consider identifying at least two Ohio Professional Registry (OPR) Available Trainings (AT) for each of the 8 proposed topic areas. When a professional completes these trainings, they will automatically be added to their OPR profile, which will return the “yes” statement to the Employee Record Chart (ERC) for licensing/SUTQ reviews. 3. Acceptance of College Coursework to meet the PD requirement. a. This should be included for all level (Bronze, Silver, and Gold) and for Administrators. b. We want to encourage professionals seeking higher education. Consider not trying to align individual courses to PD topics and streamline the process. Professionals provide a transcript with their declared major and includes the grades received during that year. If the major declared is early childhood education or child development that is all that is needed. If they have a related degree, degree course plan may be needed to show there is at least 12 credit hours expected in early childhood/child development. 4. Changing to annual requirement vs. every other year a. Consider that the past professional development biennial process now becomes an annual process. For the current PD Certification process the state continues to provide extensions for the professionals to complete their new PD requirement after the biennium closes. b. This change means that our systems, reporting and extensions that occur every other year happen every year. This may cause an administrative burden as programs struggle to remain compliant and while one year is winding up, the next year notifications may begin. 5. Administrators needing 15 hours of Professional Development. a. Since most administrators already have more education, training and experience than child care staff, what is the goal/purpose? Family Community Partnership 1. What does this tool look like? How is this geared towards families? Is this based on PFCC or all children and families? Will this be an invasive collection of information for PFCC and private families? Income, Housing, family home visits? What does this look like? Separation of Licensing and SUTQ 1. Funding: It is imperative that there NEEDS TO BE A SEPARATION OF LICENSING AND SUTQ. These two entities are intertwined with funding. A childcare center CANNOT and SHOULD NOT be put into a category to allow a business to lose funding due to an impending serious risk. 2. The complete process in which a Center or family child care self-reports needs an overhaul. The online process does not necessarily fit the actions of the occurrence more often than not. If the result of self-reporting is continuously results in punitive action, why report? Annual 1. The word annul around ANY type of documentation becomes burdensome. For example: ECERS/ITERS, evaluations, any type of documentation if not done on the exact date of the previous year is considered out of compliance. It does not matter if it is one day or one week. Any documentation should reflect like the Child’s medical statement …. 13 months. On a final note, please consider the idea of the culture change between Licensing and any type of childcare. It is extremely important to have structure and regulations for the safety of all children. Administrators, teachers and staff should never have the fear of licensing coming into any facility, ever. The relationship needs to be a partnership. All moments should be for the betterment for the children, staff and facility. It should be teachable moments, not got you! In turn, it has been an amplitude of years of punitive action as opposed to care-ative action. Thank you for the opportunity to respond to the items in clearance. Kindest regards, Michelle Bieber Over the Rainbow ELC Sylvania & Toledo -- (Internet) 3/25/2024 8:29 PM    I have been working in Childcare since 1982, I love teaching the children helping mothers to get affordable education for their children while they work and go to school to provide for their children. To better them selves provide their families to live off assistance. -- (Internet) 3/25/2024 9:39 PM    I have been working in Childcare since 1982, I love teaching the children helping mothers to get affordable education for their children while they work and go to school to provide for their children. To better them selves provide their families to live off assistance. -- (Internet) 3/25/2024 9:39 PM    I disagree with the new changes to SUTQ going to bronze, silver and gold. I have been doing childcare for five years and I was thinking about going up to a star five. Yet with the changes in pay it is not worth it. I hope you sincerely consider keeping SUTQ as it is. -- (Internet) 3/25/2024 10:24 PM    I disagree with the new changes to SUTQ going to bronze, silver and gold. I have been doing childcare for five years and I was thinking about going up to a star five. Yet with the changes in pay it is not worth it. I hope you sincerely consider keeping SUTQ as it is. -- (Internet) 3/25/2024 10:24 PM    The Ohio Association of Child Care Providers (OACCP) represents the directors and business owners of over 600 licensed child care centers. We are Ohio’s collective voice of childcare providers committed to supporting the State of Ohio’s effort to improve quality that leads to school readiness. Our members educate and care for over 50,000 of Ohio’s youngest citizens, including private pay and publicly funded children, who are served in faith-based, for-profit and non-profit programs. Many of our members serve the most vulnerable high-needs children, infants through school age children, whose families struggle financially and are among the poorest of Ohio’s citizens. We thank you for giving early care and education professionals an opportunity to review and provide comments on the proposed changes to the Step Up to Quality Rating System. Our work as a field is to provide the highest quality early care and education for Ohio’s youngest citizens. To that end, we thank you for considering streamlining the components of SUTQ and reducing administrative time so that child care professionals can spend more of their time on quality interactions with children. We appreciate that you are proposing to remove the required forms and extra points from 4 and 5 stars. Our main concerns are as follows: 1) Ratios. Please consider removing the new lower ratio requirements for Gold Rated Centers only. As this proposal includes exempting Family Child Care from the ratio requirements, it would make sense to offer the same exemption/consideration to center-based licensed child care programs by maintaining ratio and group size requirements per the child care licensing rules for ratio and group size. *As center-based licensed child care programs are currently still rebounding from the drop in enrollment from the COVID Pandemic, most programs are operating at reduce capacity and ratios. This requirement adds administrative burden and oversight to both the licensed child care programs and the state. *Without additional funding, many centers will simply not be able to achieve lower ratios without seriously impacting their financial viability and sustainability. The child care workforce crisis has strained finances by forcing centers to raise wages, often beyond their ability, in order to hire and retain staff. *By mandating reduced ratios at the Gold level by even one child, the center will have a $10-12,000 loss. Multiply that by 50% of a center’s classrooms, and the loss becomes very significant. Centers cannot absorb that type of loss, and still offer increased wages to hire and/or retain quality staff *The new rates in July will lower reimbursements for Gold level as shown here: 5 star 1/24/2024 5-star 2/24/2024 5-star 7/24/2024 % Increase $343.98 $372.06 $368.75 -1% -$3.31 Because the rates will be slightly lower, adding in the lower ratios can be devastating to centers, and impossible to sustain, especially because ARPA money is done. The example above is for Category 3 Five star/Gold. The differences in Category 1 Five Star and Category 2 Five Star are even greater, and these are usually rural counties who often struggle more financially. *Lower ratios means even less capacity and fewer slots for children. With the national child care crisis, we need to increase capacity in any way possible. Being forced to reduce ratios may threaten the children already enrolled, and limit any new enrollees. *Lower ratios for 50% of the classrooms can present a licensing nightmare. For instance, if a specialist visits a center and one of the classrooms is over the lower ratio for one of the designated classrooms, would that center drop from Gold to Silver? That is a devastating loss of income. What if that center had 3 call offs and had to cover classrooms with office personnel, etc. and it couldn’t be helped on that day? The potential complications could be confusing and time consuming to licensing as well as providers, and all for 1 child lower?? *In addition, the lower ratios should be in effect for how many hours per day for licensing purposes for the Gold level? For instance, if a center has Head Start or ECE, does that count for lower ratios? Or does the Gold ratio have to be in effect during the regular licensing hours? 2) Professional Development. * 1. Annual PD Requirement – please define what the year schedule is. Is it the state fiscal year? Or some other year? Also, rather than one year, consider making it 13 months, in alignment with Child’s Medical Statement. In some cases, you have to wait until after one year to renew the document. This would cause a non-compliance. The 13 month window is much more effective. * 2. 8 PD Topic Areas a. Consider aligning to Core Knowledge and Competencies b. Consider identifying at least two Ohio Professional Registry (OPR) Available Trainings (AT) for each of the 8 proposed topic areas. When a professional completes these trainings, they will automatically be added to their OPR profile, which will return the “yes” statement to the Employee Record Chart (ERC) for licensing/SUTQ reviews. * 3. Acceptance of College Coursework to meet the PD requirement. a. This should be included for all level (Bronze, Silver, and Gold) and for Administrators. b. We want to encourage professionals seeking higher education. Consider not trying to align individual courses to PD topics and streamline the process. Professionals provide a transcript with their declared major and includes the grades received during that year. If the major declared is early childhood education or child development, that is all that is needed. If they have a related degree, degree course plan may be needed to show there is at least 12 credit hours expected in early childhood/child development. * 4. Changing to annual requirement vs. every other year a. Consider that the past professional development biennial process now becomes an annual process. For the current PD Certification process the state continues to provide extensions for the professionals to complete their new PD requirement after the biennium closes. b. This change means that our systems, reporting and extensions that occur every other year happen every year. This may cause an administrative burden as programs struggle to remain compliant and while one year is winding up, the next year notifications may begin. c. If possible, most professionals would prefer not to have ‘designated trainings’. Because of the variety and diversity of backgrounds of professionals in our field, it is a much better idea for the provider to have choice over what training is most appropriate and helpful. *5. Family Community Partnership----what will this look like? Will this be a specific tool? If it is only for PFCC children, is this invasive? *6. Since many centers are required to obtain a National Accreditation of some kind, especially national centers with locations in Ohio, we respectfully request that DCY would consider accepting certain National Accreditation tools as being equivalent to SUTQ. By establishing reciprocity between National Accreditation tools and SUTQ, centers could obtain SUTQ status and reimbursements from their national accreditation achievement. This flexibility would be beneficial to owners and directors who must achieve national accreditation, or who would choose to achieve national accreditation. *7. Centers participating in SUTQ put in a lot of effort to achieve the benchmarks required to move to Star One, and all the way through to Star Five. They are proud of their accomplishments, and children benefit greatly from the additional quality elements. Parents are also proud that their child’s center is highly rated. The additional enhanced reimbursements allow Star rated centers to pay higher wages to staff, offer benefits and training, and improve materials and equipment for staff. When an inspection occurs and there is one or multiple infractions, please consider giving the center consultation as well as a time frame to improve and remove the infractions. Please consider de-linking serious risk infractions from the loss of stars and subsequent loss of revenue for that center. We request that there be an opportunity for that center to correct the infraction or to have an opportunity to appeal and have a due process hearing before removing any stars and reimbursements. Loss of income will affect not only the center, but all its staff as well as the children. Appendix A 1) Follow up with families within 30 days. Families often take that long just to get to know us. Sixty days would be a better time frame to allow for true connection and assessment of needs. 2) Centers complete an annual assessment for each group of children. What assessment is required here? OCOT, ITERS/ECERS, or another approved tool? 3) Administrators need 15 hours PD each year. Since most administrators already have more education, training and experience than child care staff, why do they need more training hours than teachers? Please consider the following: Masters Degree----PD optional Bachelor’s Degree-----5 hours PD required annually CDA or AA---10 hours required annually Sincerely, Mary Ann Rody OACCP Executive Director 419-367-4409 -- (Internet) 3/25/2024 11:10 PM    I am concerned that the new rating model will diminish the quality in child care centers. The changes to staff qualifications, professional development, and ratios are particularly concerning. I am a director with over 35 years of experience and a Master's degree in ECE. There have been so many challenges since COVID and we are dealing with unprecedented levels of trauma. This is not the time to hire less qualified administrators and teachers without requiring them to get a degree or credential within a year or two. My program has needed to hire more employees with only a high school diploma. However, they cannot work in a classroom unless they agree to get a CDA or enroll in an AA program in ECE within a year of hire. I would not be an effective director for my center without my credentials and years of experience. I am also concerned that lowering the professional development requirements for staff in highly rated centers and increasing the requirements for directors sends the wrong message. Only directors with no credentials or limited experience need to take additional training. Our teachers and floats need the additional hours because they are the ones spending the majority of their time with children. It is also disturbing that in the categories listed for SUTQ, that topics like adult resiliency, compassion fatigue, and self-care are not permitted. Our teachers need to learn how to take care of themselves while dealing with more children with severe disabilities, who are impacted by traumatic events, and living in unstable households. My center already follows lower ratios of 1:3 for infants, 1:4 for toddlers, and 1:10 or 1:12 for preschool. I have also worked in programs that follow state ratios and I don't believe that highly rated centers should be "striving" to meet minimum requirements. There are many centers who only follow the ratios when a licensing specialist is present and this is not prioritizing quality. Until centers are held more accountable for not following ratios, I believe those who do limit class sizes should be rewarded with higher ratings and receive more funding than those who do not. -- (Internet) 3/26/2024 11:14 AM    YES PLEASE CHANGE IT -- (Internet) 3/26/2024 11:31 AM    For the section SCI 1, can you clarify for FCCs if we can use the NAFCC self assessment tool, or do we have to use the FCCERS tool? For section FCP1, will the department be creating a tool to be used to identify the needs of the whole family, that is mentioned here? -- (Internet) 3/26/2024 11:35 AM    My name is Marquita McClendon, I have been an early childcare educator for 19 years. I am a childcare administrator for a family childcare program, as well as a center program in the Hamilton County area. A little background about me, I purchased my first daycare center in Ludlow, Kentucky when I was 22 years of age. My mother passed of breast cancer and I took part of her life insurance policy to purchase a fully functioning childcare center program. I started with 66 children enrolled and 9 employees. I was still attending Northern Kentucky University for business administration at the time trying to build a foundation for my program. I had so many milestones from me starting my early childcare career in 2005 until the current days and it wasn’t until 2021 and 2022 is when I receive my degrees in early childhood education. Which takes me into my first issue with the proposed change for the step up to quality 8850-Five Year Review and New Rating Model for the Step Up To Quality Rating and Improvement System. Proposed Changes Administration & Leadership Practices: Bronze Staff Education SE1 Child Care Centers/School Based Programs: On-site Administrator meets licensing requirements. • FCC Provider: has CDA, CPL 1 or SA Administrator Professional Development Endorsement (if only serving school-age children) • Center/School Based Programs: 50% of lead teachers have CDA or CPL2, or one lead teacher has a minimum of AA*, CPL 3, or School Age (SA) Lead Teacher Professional Endorsement (if school-age only group) • FCC Lead teacher: has CDA, CPL 1 or SA Administrator Professional Development Endorsement (if only serving school-age children) *In an approved related field Silver: SE2 On-site Administrator AA*, or CPL 3, SA Administrator Professional Endorsement (if only serving school-age children), or Administrator Credential 2 • FCC Provider has CDA, or AA*, or CPL 2, Administrator Credential 2 • Child Care Centers/School Based Programs: 25% of lead teachers have a minimum of AA*, CPL 3, or SA Lead Teacher Professional Endorsement (if school-age only group) • FCC Lead teacher (if not the provider): has CDA or CPL 2 or SA Lead Teacher Professional Endorsement (if school-age only group) In an approved related field Gold: SE3 On-site Administrator has AA*, CPL 3, or SA Administrator Professional Endorsement (if only serving school-age children) FCC Provider: has CDA, CPL 1 or SA Administrator Professional Development Endorsement (if only serving school-age children) • FCC Provider has AA*, CPL 3, or SA Administrator Professional Endorsement (if only serving school-age children) • Child Care Centers/School Based Programs: 50% of lead teachers have a minimum of AA*, CPL 3, or SA Lead Teacher Professional Endorsement (if school-age only group) • FCC Lead Teacher (if not the provider): has AA*, CPL 3, or SA Lead Teacher Professional Endorsement (if only serving school-age children) *In an approved related field By requiring family child care and center administrators to require an associate’s degree or higher to operate their child care centers when maintaining a quality program (the changes are not required for the Bronze tier which is consider quality improvement) at the Silver/Gold tier programs. There are so many challenges with this proposal. • Majority providers in Ohio have been providers for years without having to obtain a higher degree level so to put them back into a college/university/technical school for 2-3 years is a lot • Our pay will be declining after we have the pay adjustments take place with the changes even at the 50th percentile due to the SUTQ incentive decline • How would we be able to pay an employee with the associates degree when we will be making less money? • The Teach Grants that are available require a person to obtain a CDA first before they will assist with funding. So a provider would have to either obtain a CDA which will add more class instructional time on top of obtaining the CDA or pay for tuition out of pocket which will be over $20,000 for those 2-3 years As you see, this changes will strongly effect programs and would make them either lose their tier levels or have to close their centers all together. We have enough centers closing. I just opened my center in 2022 and we are just getting started. We definitely want to make sure we are on the most successful track for our business capacity. -- (Internet) 3/26/2024 11:48 AM    I go by the name of Zandra Phillips, serving as a Childcare Center in Dayton, Ohio. I'm deeply concerned about the alterations proposed for the Step Up to Quality childcare programs by the new department. These changes risk financial losses for many, with some not benefitting at all despite federal funding. It's imperative that we bolster funding for reimbursement rates to safeguard the provision of high-quality services by our indispensable childcare providers for Ohio's children and their families. -- (Internet) 3/26/2024 12:43 PM    Kathryn Poe, Michael Shields, and Ali Smith Against a rule to collapse Step Up to Quality’s rating system Family Child Care (FCC) providers and child care centers serve foundational roles in their communities but are once again being asked to provide more for less. The Ohio Department of Children and Youth (DCY) and the Ohio Department of Job and Family Services (ODJFS) have proposed a rule that would change the Step Up to Quality (SUTQ) system from a five-star system to bronze, silver, and gold (a three-tier system). Through this process, one- and two-star providers would be grouped into a new bronze tier, three-star providers would become silver, and four- and five-star providers would become gold. Ohio child care providers are not fooled and know that this will result in more administrative work and less funding, but parents might be. The proposed collapse to a three-tier system also flattens opportunities to earn higher enhancement rates. That’s why, even apart from the direct loss of revenue from enhancements, taking away quality rating indicators that providers have worked hard to earn will result not only in a loss of morale among providers, but also tangible losses in pay and lost investment in earning a specific SUTQ tier. Providers take pride in their work and contribution to their communities, but this move undercuts that commitment by providers. Step Up to Quality’s long-established rating system is familiar to families and aligned with best practices under professional child care governing bodies including the National Association for the Education of Young Children, National Association for Family Child Care, and others. Family child care providers display these ratings to reassure families that they are entrusting their child to a top quality provider. By collapsing the five-tier SUTQ program into a nebulous three-tier system, Ohio would lose those quality indicators now clearly mapped out in the profession and knock programs down in their rating that parents see. In addition to changing the tier system, the new rules increase the burden on providers with no corresponding increase in funding or support. Providers will need to do a needs assessment within thirty days of enrollment and then annually, and they will be required to refer families to services within 30 days. Those providers maintaining gold ratings will have to follow up with families after the referral to determine if needs are being met for services and document these efforts. Under the proposed rule, gold-rated providers will have to plan and host more annual educational trainings, workshops, or events for families. Providers will also be required to do more professional development annually, at a time when finding trainings that meet the SUTQ requirements and the providers’ schedules is already a challenge. Providers have invested work and resources into earning their Step Up to Quality stars. The state of Ohio has an obligation to do right by their providers and early childhood educators by ensuring that they can care for themselves, their families, and communities. Lawmakers must add money to Department of Children and Youth (DCY) and Publicly Funded Child Care (PFCC) budgets for higher provider reimbursement rates. Without adequate funding, Ohio’s child care system will remain in crisis with early childhood educators, parents, and kids left to deal with the consequences. -- (Internet) 3/26/2024 12:51 PM    Rate Clearance: Can you please clarify why the rates for Star 5 providers will be decreasing when we move to the new 50th percentile in most of the age groups and categories across the state? Some providers are losing amounts like $14.00 per child per week. Also, can you clarify why type A centers are paid almost double than Type B Providers when we are licensed under the same rules??? Yes, they have to have an employee when providing care over 6 children, but they are paid for each child, so it shouldn't matter. Some home providers work all three shifts and have more children on their roster than some type A's but make less per child. We still have to pay our utilities, purchase food for the children and supplies, etc. We also have to pay our substitutes for back up care so we can maintain our responsibilities with administrative duties. So there for our pay rate should be more equal. I also strongly feel that in the past and now type B"s have been discriminated against about the pay rate and licensing. All families deserve equal care! -- (Internet) 3/26/2024 1:28 PM    Please reconsider making it mandatory for lower ratios to achieve a gold rating. If a lower ratio is necessary, please consider raising the payment amount for a gold rating to compensate for the loss of spots. My center is currently a 5 Star center and we take great pride in this. However, the amount of money my center will lose a year if we are forced to lower our ratios is even half of our classrooms is detrimental. Mandating lower ratios for gold ratings is also working against the goal of trying to get more spaces for children in high quality centers. In addition, the centers that got the infant/toddler grant will not be able to meet their requirement of adding spaces if the ratios get lowered. -- (Internet) 3/26/2024 1:29 PM    Good afternoon DCY, My concern for the implementation of the proposed new sutq model is that programs are going to LOSE money in a system where we are currently already severely underpaid. The proposed new changes and requirements will make it impossible to provide quality ece or increase access to quality ece. Thank you -- (Internet) 3/26/2024 2:16 PM    Starting Point is Northeast Ohio's Child Care Resource and Referral agency. We support and guide child care providers in our service delivery area. We are submitting responses to the Step Up To Quality clearance items for clarity and to continue providing optimal coaching and mentoring services to the child care community. Curriculum and Assessment 1: Will a free curriculum be eligible for a bronze-level rating? Will there be additional information available on the Science of Reading? Curriculum and Assessment 2 & 3: "Please clarify the duration of an assessment cycle. In the past, it has been 6 months. Child Screening 1: Will language be provided to describe a "comprehensive screening tool"? Child Screening 2: Correction: Should the first sentence read "Refer families of children" instead of "Refer families"? Staff Child Interactions 1: Could you please specify the type of annual self-assessment needed? Is it for the classroom or for the program? Staff Child Interactions 2 & 3: Will there continue to be an interview portion on the OCOT? Staff Child Interactions 3: Do we need to update our self-assessment goals from SCI2 to SCI3? Continuous Improvement 1: Is a program assessment tool necessary to complete the CIP? Continuous Improvement 2 or 3: Will updates be needed on action plans for the Continuous Improvement Plan from CI2 to CI3? Staff Education 1: Will a new Career Pathway Level Model be created? If so, when will the CPL be available? Professional Development 1, 2, 3: Suggest adding Business Practices, this is a much sought-after topic by administrators and owners and a huge need, especially after COVID. How many hours must be devoted to the two topics on the list, for teachers and administrators? Will an OPR report show which training meets the required topics? Family Partnerships Community Resources 1: What tool will be used to assess the needs of the whole family? -- (Internet) 3/26/2024 2:17 PM    Hi - my wife and I own 3 daycares in Cincinnati. Our largest center, which also happens to be 5 stars, is our highest functioning center. We are completely full at current ratios. I don't think lowering ratios would have any effect on the classroom environment. We have smaller classrooms at the other centers that don't run as well as our classrooms at our largest center. All this will do is decrease the amount of kids we can have at our center. Thank you for listening. Alex Kummer -- (Internet) 3/26/2024 2:22 PM    Professional Development changes: -Requiring administrators to obtain extra PD hours for silver or gold rating seems ineffective. -Administrators have the most knowledge and advanced degrees of all early childhood staff. -Taking administrators out of the building/center for extra PD is stressful for the program. -Ohio-approved PD is not at the level that is informative for administrators typically. -Requiring additional hours of training for assistants and/or teachers would be more impactful to Ohio's young children, as these people can most readily change their teaching practices. -Many assistants only have high school diplomas, and could benefit from ongoing training at the level offered from Ohio-approved PD. -I suggest either doing away with the extra PD hours for administrators and requiring 10 hours per year across the board, or increasing the required PD hours for all staff (including assistants and teachers) to get the silver or gold rating. -- (Internet) 3/26/2024 2:41 PM    Ratio requirements for gold rating: I FULLY SUPPORT THESE LOWER RATIOS! This is so needed for job satisfaction of early childhood staff members and for the safety/comfort of the children. Kids' social emotional well-being will be positively impacted by lower ratios. Whatever can be done to mandate lower ratios is wonderful! Thank you! -- (Internet) 3/26/2024 2:44 PM    Hello! Thank you for the opportunity to review and comment on the proposed revisions. My lens is as an administrator of 5 (currently) ODE licensed school age child care programs. 5101:2-17-01 (1)&(7) - ODE programs do not currently name administrators on the license. Is this going to change? And, can an individual have more than one role at a center? For example, most SACC programs are structured with a Site Manager or Site Director who is also in charge of the responsibilities listed for a "Lead Teacher" including activity planning and implementing the curriculum. So could the Site Manager hold both the Administrator and Lead Teacher roles? 5101:2-17-01(2) - please consider including the following fields as approved related fields under (a): social work, child & youth studies, youth development and under (b): Community leadership, business administration, and non-profit management. Standards: Curriculum and Assessment - school age programs must be aligned to the K-12 Learning Standards. Does this include the SEL standards? Not all programs are academically focused. I would love to see something in the curriculum standards for school age programs at the Silver and Gold level along the lines of having a clear mission, purpose and goals and offering activities in alignment with the mission and goals, and perhaps at the Gold level demonstrating that youth voice is used in the planning and implementation of the program. Family Partnerships/Community Resources - we need more information on this. Is there a sample tool? Can parents opt out of completing the tool? Can the tool be included as part of registration? What is the definition of a referral? Is providing information to the parent count as a referral or does the program need to call the referral agency and make a formal referral? 5101:2-17-02(5)(a-d) - This language is confusing. All other sections have been updated to indicate "licensed programs" but these sections still have separate criteria for ODJFS and ODE licensed programs and there are different point totals for the different licenses, different lists of serious risk non compliances, and different timelines. Thank you! -- (Internet) 3/26/2024 4:19 PM    Directors Wente and Damschroder, On behalf of YWCA Columbus, we are submitting comments on draft rule 8850 regarding the new rating model for the Step Up to Quality Rating and Improvement System in Chapter 5101:2-17 of the Ohio Administrative Code for the five-year review and draft rule 8940 regarding the 2024 update to PFCC provider payment rates to the 50th percentile. YWCA Columbus has served the central Ohio region for over 100 years, and our mission of eliminating racism, empowering women, and bringing peace, justice, freedom, and dignity to all guides our work from serving the unhoused to promoting youth development. In 2023, across 23 sites, YWCA provided care for 1,613 children through our youth development programs. For over 30 years, we’ve served over 20,000 students in our high-quality after-school programs. These programs are all Step Up to Quality star-rated and a portion of the families we serve receive PFCC. Additionally, our emergency shelter for families operates a 5-star Step Up to Quality childcare program, available to parents so they can accomplish their employment and housing goals. Nearly 90% of the families served in our shelter receive PFCC. Ohio’s reimbursement rates are so low – the lowest of any state – that the federal government mandated they be raised to the 50th percentile by the end of 2024, leading to these proposed changes. The most current rates reflect costs at the 35th percentile. Reimbursing at the 75th percentile is the federal benchmark for equal access. At a time when costs are rising and the childcare crisis is destabilizing families (Ohio is also among the lowest access points in childcare eligibility), these proposed rules will only strain our budget and operations. At YWCA Columbus, we have committed to achieving a 3-star rating for all our childcare sites. We are just four sites away from achieving that goal. We also increased the wage floor for our frontline childcare staff to $17/hour for part-time and $20/hour for full-time employees, ensuring their wages are dignified, competitive, and honor the critical support they provide our communities. We are committed to quality at every level because it’s the right thing to do for the families and children we serve. While we remain committed to high standards, we know that the new reimbursement rates will take a toll on other areas of our operations that provide critical support for families in our community. We do not intend to reduce the number or quality of our programs because of this change, but many other providers do not have the flexibility to have their rates fluctuate or lowered – further reducing the number of childcare providers available to families, especially those receiving PFCC. Childcare providers are more critical than ever to the economy – we should make changes to allow us to increase the quality of our care, keep our workers, and serve more people. Instead of these rules, ODJFS and DCY should advocate for an increase in funding to support the new 50% reimbursement rate. YWCA Columbus urges the Ohio Department of Job and Family Services and the Ohio Department of Youth and Families to not adopt the new quality rating model for SUTQ and reimbursement rates proposed in rules 8850 and 8940. If allowed to go into effect as written, these proposed rules would harm the most marginalized children and families in our communities – those we serve directly – and strain our already overburdened childcare infrastructure. Sincerely, Tanya Salyers Director of Advocacy YWCA Columbus -- (Internet) 3/26/2024 4:22 PM    Thank you for us an opportunity to review and provide comments on the proposed changes to the Step Up to Quality Rating System. We appreciate that one of the goals for the changes in SUTQ is to ease the burden for providers by reducing paperwork requirements. We would like to provide input/comments on the following proposed changes: Learning & Development - Bronze Requirements - It mentions curriculum from "verified list". In the past, there has been problems with listing curriculums for school age programs. We would like to see the verified list. Will these fit with the goals of our programs? Is there additional costs to programs to purchase materials? It also mentions "all hours of instructional time" - Do we designate this or does the dept? Is there a minimum? What does this look like for am programs? Admin & Leadership Practices- Continuous Improvement- Gold Requirement Under community partnership "activity, function, or meeting" - For some program partners, this may be fine, but for other important community partnerships like PNC Bank, Battelle and United Way that don't fit into this requirement, they may be leaving them out. Family & Community Partnerships Partnerships/community resources We like the intention of these requirements but we feel more clarification needs to be done around what this will look like in practice. For example, our school age sites don't necessarily have the staff or resources to have these conversations in private. Bronze The requirement alludes to a Tool to determine needs of whole family - Will there be a tool provided? Will confidential information it specifies like health & resources (maybe financial) be put into this tool? We don't typically gather and keep this confidential information at our school age sites? Silver Referrals within 30 days - Can this be just a sheet of resources we give them or willl one be provided by the state? Gold Follow up on referrals to determine if needs are being met - this could be a confidentiality issue if it involves health, mental health or finances; could be an awkward conversation for our school age staff to have with families - I'm not sure if this is their role. The part that is most difficult is checking to see "if needs are being met". Professional Development What is your definition of annual in regard to PD Requirement.-For example-Fiscal or calendar year? 8 PD Topic Areas- These should be aligned to Core Knowledge and Competencies Please consider accepting college coursework to meet the PD requirement for all level (Bronze, Silver, and Gold) and for Administrators. Our goal is to encourage professionals to seek higher education. Trying to align individual courses to PD topics, complicates the PD requirement. Professionals must provide a transcript with their declared major and the grades they received. If their major is early childhood education or child development, nothing else should be needed. If they have a related degree coursework may be needed to demonstrate that they have taken at least 12 credit hours in early childhood/child development. -- (Internet) 3/26/2024 4:22 PM    New Quality Rating Model for SUTQ :The lower funds percentage and then lower ratio requirement is detrimental to my center and the ability to have a profit margin -- (Internet) 3/26/2024 4:25 PM    Lowering ratios for highly rated programs should be the standard! -- (Internet) 3/26/2024 4:29 PM    March 26, 2024 Kara B. Wente Director Ohio Department of Children and Youth 246 North High Street, 8th Floor Columbus, OH 43215 RE: Draft Ohio Step Up To Quality Program Revisions Dear Director Wente, On behalf of KinderCare Learning Companies (KinderCare), thank you for the opportunity to comment on the draft changes to the Step Up To Quality (SUTQ) program centered around promoting high-quality early childhood education (ECE) in the State of Ohio. KinderCare proudly serves over 13,200 young children at our 95 high-quality early learning centers and 42 before/after school sites across Ohio. Our world class educators build confidence in students by providing high-quality educational experiences that meet the unique developmental needs of every child in our care. KinderCare serves all children regardless of background and financial circumstance. Approximately 45% of the children we serve depend on financial assistance offered through Ohio’s Publicly Funded Child Care program. We want to thank the DeWine Administration for their continued focus and dedication the ECE. KinderCare is your committed partner to promoting health, safety, and educational excellence for young children and working families throughout Ohio. I am writing to provide feedback on the proposed revisions to the SUTQ program rules. As a stakeholder in the ECE field, we believe these revisions are critical to ensuring the success and effectiveness of the SUTQ program. We recommend the following adjustments to the SUTQ program to better align with its goal of advancing centers to a higher level of quality. 1. Offer Flexibility within SUTQ Categories: The current SUTQ rules allow child care programs to gain points across categories, recognizing there are multiple approaches to measuring and delivering high-quality care. Such flexibility, for example, allowed a center with a highly educated staff to demonstrate quality through teacher credentialing, professional development, and national accreditation. Such approach allows each licensed center with the flexibility to operate within the program and in the context of their community. In the draft rules, a meaningful change was made to Subsection B of 5101:2-17-01, which limits providers’ ability to earn points in SUTQ. This has a significant impact on centers, especially those that will explore additional pathways to achieving the “gold” level. We recommend retaining a form of the following language that was removed: 4) Programs who register for a four or five-star rating may be awarded points based on the verification of the three-star rating requirements and their ability to earn additional points as outlined in appendix A Reopening this flexibility language allows centers to operate effectively and meet the diverse needs of their communities. 2. Retain the Optional National Accreditation Pathway: As part of our proposal for streamlining, we recommend retaining the national accreditation standard as an embedded pathway to attaining the "Gold" rating. National accreditation standards frequently overlap with the benchmarks of a quality rating and improvement system, resulting in redundant standards. This approach mirrors the pathway taken by 26 other states across the country to align with common standards. KinderCare aims to achieve national accreditation in all our centers and currently has 81 nationally accredited centers in Ohio. 3. Reconsider New Ratios for SUTQ: We respectfully request a reconsideration of the new ratios for licensed child care programs. The current proposal exempts family child care, and we suggest extending this exemption to include licensed programs to maintain alignment with current ratio and group size rules. This requirement, while well-intentioned, presents a significant administrative challenge that could limit access and impose further financial constraints on centers and the families we serve. Introducing new, enhanced ratios at this time would not only add administrative burden and oversight for the state but also creates significant operational challenges for centers. KinderCare proudly operates 38 4- and 5-star centers. To comply with new ratios each center will be operating at a different combination of 50% of classroom with one less child in the room. The variation of combinations will result in an elevated level of administration paper work to maintain the “gold” level. Furthermore, the variation in child attendance as well as the staffing levels could put a center in the position of falling to a silver level without an alternative path to make those points up. Such unforeseen circumstances could lead to family disenrollment due to a perceived reduction in quality. The quality of a center may not have decreased; rather, the proposed ratios could not be achieved. An additional level of difficulty operating in these ratios is the reduction in reimbursement at the “gold” level. The combination on lower ratios and the reduction in reimbursement adds a financial burden just to main the highest level of quality. Thank you for considering our feedback. We look forward to continuing to collaborate with you to improve the SUTQ program and support the success of early childhood education in Ohio. If you have any questions or need further information, please do not hesitate to contact me at brian.holcombe@kindercare.com. Sincerely, Brian A. Holcombe Government Relations Representative -- (Internet) 3/26/2024 5:05 PM    I am writing in response to the public comment period for 8850 Five Year Review and New Rating Model for the Step Up to Quality Rating and Improvement System and the impact it will have on our childcare center. In March of 2024, our center was approved as a 4-Star SUTQ center. We are extremely excited to move from a three star to a four-star center and we are even more excited to know that we will become a gold rated center in July of this year. Our administrators and teachers have spent the last year preparing to become a five-star center. Due to the change ODJFS made to the educational requirements for an administrator, we lost our points that would have made us eligible to become a five-star rated center. While this was very disappointing for our staff and a bitter pill to swallow, we made the decision to continue to move forward to obtain our four-star rating. We knew that we could not lower the ratio to achieve more points as it would jeopardize our financial position. Hours and hours of work was put into strengthening lesson plans, delving deeper into child and classroom assessment, curriculum alignment, and increasing professional development hours. Thousands of dollars were invested into our center to raise teachers’ wages and purchase additional resources for our classrooms. We knew we would recoup our investment and be able to sustain teachers wages due to the increase in Ohio's Publicly Funded Child Care (PFCC) base provider payment rates to the 50th percentile. Things were truly beginning to look up after the turmoil of the past three years due to the pandemic and the aftermath left in its wake. By increasing wages, we were finally able to hire additional staff who are invested in our center and proud to be a four-star and soon to be gold rated center. Then the new proposed SUTQ amendments were introduced. We were shocked. Up until now, we have been impressed with Director Wente’s direction and leadership of the new Department of Children and Youth. We believed she had our best interests at heart and the interests of small businesses throughout the state. Businesses that have strived to meet higher state standards to provide elevated quality care for young children and for many centers for which this came at a significant cost. We had been hopeful that the politics and legacy from the Ohio Department of Jobs and Family Services was behind us. We believed Governor DeWine and Lt. Governor Husted who have over and over again pledged their support for businesses in Ohio. I am, of course, referring to the mandated decrease in ratios. The decision to require centers to decrease ratios in fifty percent of their classrooms at the end of the pandemic is beyond the imagination. The financial hit to centers will range from the insignificant to astronomical. For our center, the estimated one-year loss in revenue due to lowered ratio is $123,929.80. We cannot sustain a financial hit of this magnitude. We will be forced to close classrooms and lay off teachers which will have a negative impact on our local community and businesses who rely on us to support the workforce by providing childcare. Why do we keep hearing that Ohio does not have enough childcare slots for all the children needing care and yet the Department of Children and Youth want to decrease the number of available slots? How does this fly in the face of the Inclusion Grant to increase the number of infants and toddlers enrolled at centers? Doesn’t DCY want these children to be able to attend a four or five star rated center? Or,do you want them to go to centers that are lower quality? In closing, I am requesting that DCY remove the change in regulations to decrease ratio in fifty percent of classrooms for centers who are four and five stars rated. It is obviously apparent that this change was made with inadequate research into the serious repercussions it will have on childcare in Ohio. Admit that you are not ready to move forward with this type of change and please go back to the drawing board. Perhaps you could add a Diamond category for centers who are able to lower ratio and provide a small financial incentive or some other type of state recognition. We became a four-star rated center and would have been five stars had the educational requirements not changed. And we did this without lowering ratios. The existing ratios are sufficient for centers to provide high quality care. Please step away from those pressuring the department to make this change, leave politics out of it, and stand up for childcare centers in the state. We thought we had a new voice and new leadership for the field of early childhood education in Director Wente. Please do not let us down. We need you. -- (Internet) 3/26/2024 5:05 PM    Five Year Review and New Rating Model for the Step Up To Quality Rating and Improvement System A Proposed Rule by the Ohio Department of Children and Youth and the Ohio Department of Job and Family Services March 26, 2024 Dear Directors Wente and Damschroder, Thank you for your commitment to addressing the challenges within Ohio’s child care system, including the need for increased resources and a strong and sustainable quality system. This is especially important as we continue to experience the impacts and aftermath of the pandemic and navigate an ongoing and exacerbated child care crisis. PRE4CLE is a collective impact initiative working to expand access to high-quality preschool to all 3- and 4-year-olds in the city of Cleveland so that every child enters kindergarten ready to succeed. PRE4CLE connects families to high-quality public and private preschool programs; connects preschool providers to tools, resources, and key partners to increase their quality and serve more children; and provides strategic leadership and advocacy to accelerate the availability of high-quality preschool in Cleveland. We are writing to express appreciation for your effort to thoughtfully and collaboratively update the Step Up To Quality system while maintaining a focus on those aspects of a quality system that matter most for children. As leading early childhood advocates in Northeast Ohio that advocate for comprehensive, equitable, and well-funded child care systems that support all families and providers, we are submitting comments for your consideration. We support the changes in the proposed rule, along with the proposed rule to increase Ohio’s base rate for child care providers to the 50th percentile, which would create a more stable and accessible child care system for children and families. We do, however, want to express our concern about several areas in which Ohio is moving away from research-based practice related to quality within early learning settings, particularly related to staff qualifications and teacher to child ratios. In Northeast Ohio, and specifically the Greater Cleveland area and Cuyahoga County, our community has worked for more than two decades to increase access to high-quality early learning opportunities in partnership with the State of Ohio. This commitment includes the dedication of significant local resources to support access high-quality early learning as well as increasing the number of programs that are highly rated in Ohio’s Step Up To Quality. We remain committed to expanding access to high-quality early learning programs to all children in Ohio, and we offer the following comments on the proposed rules to support Ohio’s continued progress toward that goal. Reduction in Benchmarks and Transition to Fixed Standards We are supportive of the effort to streamline the administrative burden involved in Step Up To Quality and focus on those benchmarks that research has shown have the greatest impact on child development and kindergarten readiness. We also agree with the transition to a set of fixed standards at each level of Step Up To Quality and the elimination of a point-based system. We believe this will allow for greater understanding of the impact of quality standards on kindergarten readiness in Ohio. Along with those changes, we believe the change to require all levels of the rating system to include the implementation of a research-based curriculum will strengthen overall child outcomes. Finally, we are grateful for the movement towards a more standard set of professional development requirements for all early educators in Ohio to build core knowledge in critical areas. Taken together, we think these are positive changes that have the potential to both remove unneeded administrative burden while also building a foundation of quality supports for children in Ohio’s early learning system. Ratio and Group Size Requirements While we appreciate that ratio and group size requirements were included at the proposed “gold” level of quality, we believe that the proposed ratio and group sizes are still too large to adequately address the need for individual attention and teacher-child interactions with Ohio’s early learning classrooms. Research shows that smaller group sizes and teacher to child ratio requirements allow for greater and deeper interaction and create stronger child outcomes. In Cleveland, preschool programs that partner with PRE4CLE meet a requirement to maintain a group size of 20 and a teacher to child ratio of 1:10, as well as several education requirements beyond the current SUTQ requirements. Our data show that PRE4CLE preschools consistently support higher levels of kindergarten readiness compared to lower-quality providers as well as high-quality providers not meeting reduced ratio and group size requirements. Additionally, as the number of children with special needs increases dramatically within our early learning centers, especially in our high poverty areas, lower group sizes and ratios will allow for greater accommodation and support for children who require more individualized attention and support. We understand that lower group sizes and ratio requirements are a major cost driver within the early learning system, and that this proposed set of changes works within the current budget for Ohio’s child care system. We call on Ohio’s leaders to work towards greater funding for early learning classrooms to allow for smaller group sizes and teacher to child ratios to improve learning and early childhood development outcomes. Teacher and Administrator Education Requirements Like our comments above on ratio and group size, we would like to request that state leaders continue to work toward increasing the educational requirements for early learning teachers and educators as we rebuild the workforce following the COVID-19 pandemic. We understand that the proposed requirements for teacher and administrator education reflect changes made by the Ohio legislature limiting which degrees can be required, as well as the current staffing challenges and pipeline limitations following the COVID-19 pandemic. While short-term accommodations are made to rebuild the system, we strongly request that Ohio create a roadmap and strategy for increasing teacher and administrator education requirements over time. This roadmap should include strategies to increase educator compensation as well as improve the training pipeline with high schools and higher education institutions. At a minimum, we would recommend that all lead and assistant teachers at every level meet or be working towards educational requirements. Thank you for the opportunity to submit comments on these changes. We look forward to working with you and your staff to partner on a successful transition as well as on future goals for Ohio’s early education system. -- (Internet) 3/26/2024 5:17 PM    Five Year Review and New Rating Model for the Step Up To Quality Rating and Improvement System A Proposed Rule by the Ohio Department of Children and Youth and the Ohio Department of Job and Family Services March 26, 2024 Dear Directors Wente and Damschroder, Thank you for your commitment to addressing the challenges within Ohio’s child care system, including the need for increased resources and a strong and sustainable quality system. This is especially important as we continue to experience the impacts and aftermath of the pandemic and navigate an ongoing and exacerbated child care crisis. PRE4CLE is a collective impact initiative working to expand access to high-quality preschool to all 3- and 4-year-olds in the city of Cleveland so that every child enters kindergarten ready to succeed. PRE4CLE connects families to high-quality public and private preschool programs; connects preschool providers to tools, resources, and key partners to increase their quality and serve more children; and provides strategic leadership and advocacy to accelerate the availability of high-quality preschool in Cleveland. We are writing to express appreciation for your effort to thoughtfully and collaboratively update the Step Up To Quality system while maintaining a focus on those aspects of a quality system that matter most for children. As leading early childhood advocates in Northeast Ohio that advocate for comprehensive, equitable, and well-funded child care systems that support all families and providers, we are submitting comments for your consideration. We support the changes in the proposed rule, along with the proposed rule to increase Ohio’s base rate for child care providers to the 50th percentile, which would create a more stable and accessible child care system for children and families. We do, however, want to express our concern about several areas in which Ohio is moving away from research-based practice related to quality within early learning settings, particularly related to staff qualifications and teacher to child ratios. In Northeast Ohio, and specifically the Greater Cleveland area and Cuyahoga County, our community has worked for more than two decades to increase access to high-quality early learning opportunities in partnership with the State of Ohio. This commitment includes the dedication of significant local resources to support access high-quality early learning as well as increasing the number of programs that are highly rated in Ohio’s Step Up To Quality. We remain committed to expanding access to high-quality early learning programs to all children in Ohio, and we offer the following comments on the proposed rules to support Ohio’s continued progress toward that goal. Reduction in Benchmarks and Transition to Fixed Standards We are supportive of the effort to streamline the administrative burden involved in Step Up To Quality and focus on those benchmarks that research has shown have the greatest impact on child development and kindergarten readiness. We also agree with the transition to a set of fixed standards at each level of Step Up To Quality and the elimination of a point-based system. We believe this will allow for greater understanding of the impact of quality standards on kindergarten readiness in Ohio. Along with those changes, we believe the change to require all levels of the rating system to include the implementation of a research-based curriculum will strengthen overall child outcomes. Finally, we are grateful for the movement towards a more standard set of professional development requirements for all early educators in Ohio to build core knowledge in critical areas. Taken together, we think these are positive changes that have the potential to both remove unneeded administrative burden while also building a foundation of quality supports for children in Ohio’s early learning system. Ratio and Group Size Requirements While we appreciate that ratio and group size requirements were included at the proposed “gold” level of quality, we believe that the proposed ratio and group sizes are still too large to adequately address the need for individual attention and teacher-child interactions with Ohio’s early learning classrooms. Research shows that smaller group sizes and teacher to child ratio requirements allow for greater and deeper interaction and create stronger child outcomes. In Cleveland, preschool programs that partner with PRE4CLE meet a requirement to maintain a group size of 20 and a teacher to child ratio of 1:10, as well as several education requirements beyond the current SUTQ requirements. Our data show that PRE4CLE preschools consistently support higher levels of kindergarten readiness compared to lower-quality providers as well as high-quality providers not meeting reduced ratio and group size requirements. Additionally, as the number of children with special needs increases dramatically within our early learning centers, especially in our high poverty areas, lower group sizes and ratios will allow for greater accommodation and support for children who require more individualized attention and support. We understand that lower group sizes and ratio requirements are a major cost driver within the early learning system, and that this proposed set of changes works within the current budget for Ohio’s child care system. We call on Ohio’s leaders to work towards greater funding for early learning classrooms to allow for smaller group sizes and teacher to child ratios to improve learning and early childhood development outcomes. Teacher and Administrator Education Requirements Like our comments above on ratio and group size, we would like to request that state leaders continue to work toward increasing the educational requirements for early learning teachers and educators as we rebuild the workforce following the COVID-19 pandemic. We understand that the proposed requirements for teacher and administrator education reflect changes made by the Ohio legislature limiting which degrees can be required, as well as the current staffing challenges and pipeline limitations following the COVID-19 pandemic. While short-term accommodations are made to rebuild the system, we strongly request that Ohio create a roadmap and strategy for increasing teacher and administrator education requirements over time. This roadmap should include strategies to increase educator compensation as well as improve the training pipeline with high schools and higher education institutions. At a minimum, we would recommend that all lead and assistant teachers at every level meet or be working towards educational requirements. Thank you for the opportunity to submit comments on these changes. We look forward to working with you and your staff to partner on a successful transition as well as on future goals for Ohio’s early education system. -- (Internet) 3/26/2024 5:18 PM    There is no guidance written on how the implementation and follow-up of the tool that is used to determine family needs. What is the specific documentation required to show that the tool was used, the follow-up occurred, and that referrals are made. You indicate the you want to lesson the administrative burden and this alone has increased the administrative burden exponentially without additional support or funding to follow-up with families and to provide resources. The Department should simply have a list of resources for families that can be linked to a school's website or handout provided. Doctor's offices and other service agencies like ODJFS should be completing these tools for resources not child care centers that are already over extended and without resources available to them. For too long early childhood professionals have been used to enable families instead of empowering them. It is presumptuous that families want their child care center to ask them personal questions that determine if they need referrals or services. Our focus should be on the education of their children and telling families to reach out to their pediatricians for additional support and their case managers at ODJFS. If their needs aren't met by the resources provided, that should be on the provider of the resources to figure out next steps for the family again, not the child care provider. -- (Internet) 3/26/2024 5:28 PM    As a family childcare type B provider, the recommended changes to SUTQ raises concerns financial stability for my small program. Part of the income generated not only provides revenue for the program needs but it also supports financial needs for my family. With a child with autism and the continuous inflation of cost of goods and maintenance of the increasing needs of families of the program, sutq shouldn't be decreased in the incentive reimbursement. Many providers value the efforts put forth to get to the higher quality level and shouldn't have to take a loss in value in all the efforts completed. in addition, with most of the state citizens still suffering from the cost of inflation, the right solution would be to keep the rates as they currently are so support stabilizing programs. In review of what it will look like 7/1/24, all programs will suffer a wage loss from what they are currently receiving. In order to create a liveable childcare wage system, the state has to provide proper financial investments to all levels of service in the industry. -- (Internet) 3/26/2024 5:40 PM    I TRACY RICHARDSON-HARMON I BEEN DOING CHILDCARE IN MAHONING COUNTY TYPE B FOR 16YRS.I LOVE WHAT I DOING AS A PROVIDERIAM A STAR 2 WAS GOING TO3 BUT WHY CHANGE AND I STILL GOING TO MAKE THE SAME AS 2,I VERY UP STEP THAT YALL DOING ALL THESE CHANGES TO THE STEP UP TO QUALITY CHILDCARE PROGRAMS.I WILL LOSE MONEY OR NO MONEY INREASE AT ALL.NEED TO REIMBURSEMENT RATES THAT ESSENTIAL CHILDCARE PROVIDERS ABLE TO POVIDE QUALITY SERVICESFOR OHIO KIDSAND FAMILIES. -- (Internet) 3/26/2024 5:41 PM    Ohio Department of Children and Youth Re: Rule Changes 8850, 8940 Thank you for the opportunity to share my perspective. Rule 8850, new Step Up To Quality (SUTQ) tiers is not the appropriate or necessary change needed at this time because it does not address what is most needed in the Early Education Sector. What is most needed in the Early Childhood Education (ECE) space are solutions and resources to address the workforce crisis. The best intentions and changes to SUTQ cannot be properly implemented without an adequate workforce. Before the onset of the pandemic, the need for qualify staff was the number one factor hindering ECE. Covid exasperated this to a crisis level, debilitating the field of ECE. The current SUTQ guidelines cannot be implementation because we don't have adequate staff. Creating new guidelines does not address the needs of the field. We must have adequate qualified staff in order to deliver the services needed to best serve children and families. As a grassroots contributor to SUTQ. I made the commitment to lower student enrollment, staff ratios and everything necessary to implement SUTQ. It was a struggle for my medium center, but I am committed to quality care. I struggled to find and maintain qualified staff. When the pandemic hit I did everything necessary to maintain the staff I had at that time. I used Payroll Protection Program (PPP) resources to pay and maintain my staff and they committed to stay, however, when the governor reopened the centers the staff did not return. I was stripped of my quality rating without any consideration to the years of hard work I had given to quality. It has taken me years to recently recruit two individuals who want to pursue a career in ECE. This highlights the number two deterrent to our success, which is adequate reimbursement and addresses Rule change 8940, percentile and reimbursement changes. Ohio already provides the lowest reimbursement of any state. This rule change further exasperates our ability to sustain our centers and implement SUTQ. Without adequate reimbursement, centers cannot afford to pay sustainable wages. This translates to our inability to attract and retain career oriented personnel. We simply need the proper funding, based on cost of care. Finally, we need true collaboration and equity from the state. This includes inclusion of center directors that do the work when determining changes in all aspects of our field. We do the work, and my twenty- five years of experience operating a star-rated center qualifies me to add valuable contributions to necessary changes. A commitment to true transparent funding and equity in distributing those funds must happen in order to provide quality care to children and families, while maintaining our centers and sustainable employment of quality staff. Kathleen Lamb Tyler In GOD'S Hands Christian Youth Center 3808 Zinsle Avenue Cincinnati, Ohio 45213 -- (Internet) 3/26/2024 5:50 PM    Ohio Department of Children and Youth Re: Rule Changes 8850, 8940 Thank you for the opportunity to share my perspective. Rule 8850, new Step Up To Quality (SUTQ) tiers is not the appropriate or necessary change needed at this time because it does not address what is most needed in the Early Education Sector. What is most needed in the Early Childhood Education (ECE) space are solutions and resources to address the workforce crisis. The best intentions and changes to SUTQ cannot be properly implemented without an adequate workforce. Before the onset of the pandemic, the need for qualify staff was the number one factor hindering ECE. Covid exasperated this to a crisis level, debilitating the field of ECE. The current SUTQ guidelines cannot be implementation because we don't have adequate staff. Creating new guidelines does not address the needs of the field. We must have adequate qualified staff in order to deliver the services needed to best serve children and families. As a grassroots contributor to SUTQ. I made the commitment to lower student enrollment, staff ratios and everything necessary to implement SUTQ. It was a struggle for my medium center, but I am committed to quality care. I struggled to find and maintain qualified staff. When the pandemic hit I did everything necessary to maintain the staff I had at that time. I used Payroll Protection Program (PPP) resources to pay and maintain my staff and they committed to stay, however, when the governor reopened the centers the staff did not return. I was stripped of my quality rating without any consideration to the years of hard work I had given to quality. It has taken me years to recently recruit two individuals who want to pursue a career in ECE. This highlights the number two deterrent to our success, which is adequate reimbursement and addresses Rule change 8940, percentile and reimbursement changes. Ohio already provides the lowest reimbursement of any state. This rule change further exasperates our ability to sustain our centers and implement SUTQ. Without adequate reimbursement, centers cannot afford to pay sustainable wages. This translates to our inability to attract and retain career oriented personnel. We simply need the proper funding, based on cost of care. Finally, we need true collaboration and equity from the state. This includes inclusion of center directors that do the work when determining changes in all aspects of our field. We do the work, and my twenty- five years of experience operating a star-rated center qualifies me to add valuable contributions to necessary changes. A commitment to true transparent funding and equity in distributing those funds must happen in order to provide quality care to children and families, while maintaining our centers and sustainable employment of quality staff. Kathleen Lamb Tyler In GOD'S Hands Christian Youth Center 3808 Zinsle Avenue Cincinnati, Ohio 45213 -- (Internet) 3/26/2024 5:53 PM    To whom it may concern. I am a 5 star childcare provider in Trumbull county. I have been looking over the new rates and not seeing where the new changes will be beneficial to those that have achieved getting their five star. I feel as if we are losing out on pay and we're going down to a four star rating pay when we are doing a five star rated Childcare. I am not understanding how they are saying that we will get a pay raise when we will actually be losing out on pay. It's not fair to us. It's not fair to the families we serve in our childcare settings. We go above and beyond for our families and for us to have accomplished a five star and basically getting a four star rate is not fair. It's not fair type type. A providers are getting paid way more than type B providers and we're all doing the same thing they are just allowed more children at a time I would really like to see where it would be fair to all of us in the settings Childcare. We do so many more things for our families than centers were cooks were taxi drivers were nurses were counselors we were hats for us, not to be treated fair. Those that have accomplished stars and those of us with the higher star four and five seems as if we always get the short end of the stick and we are the ones doing the most for these families we're giving them the best quality care that they can get and for us not to be compensated for it is really not fair at all to us. -- (Internet) 3/26/2024 7:28 PM    I'm a childcare provider Type A been doing childcare for 8 years. before I start by said that Replaces the 5-tiered star rating system with a 3-tiered rating system of bronze, silver, and gold is not good system the reason is. I was working to get my five star. I was looking at this new tier the percentage that I'm current now with the three star is more that the gold tier after this new rating going in effect .I think is not about the money is about the quality an service that we going to offer. in my case I'm open 24 hours. I do have 4 staff with me and I offer extra service in my program to provide resource for the family that is why, I'm refusing of the change of the STEP UP TO QUALITY RATE. I think we have work so hard to get were we are special to the 50% percent . we deserved. I will like for you to look at all this comment an considered our opinion because we are the one who is doing this job a lot of us been in this industry for decades.thank you very much -- (Internet) 3/26/2024 9:35 PM    No Comment -- (Internet) 3/26/2024 9:58 PM    The Ohio Organizing Collaborative's CEO Project along with The Over 300 Providers we represent stand against a rule to collapse Step Up to Quality’s rating system Family Child Care (FCC) providers and child care centers serve foundational roles in their communities but are once again being asked to provide more for less. The Ohio Department of Children and Youth (DCY) and the Ohio Department of Job and Family Services (ODJFS) have proposed a rule that would change the Step Up to Quality (SUTQ) system from a five-star system to bronze, silver, and gold (a three-tier system). Through this process, one- and two-star providers would be grouped into a new bronze tier, three-star providers would become silver, and four- and five-star providers would become gold. Ohio child care providers are not fooled and know that this will result in more administrative work and less funding, but parents might be. The Ohio Childcare system is currently in crisis. These Changes will only exacerbate that crisis and force some centers to close down. Especially Urban and Rural Centers that serve a large number of PFCC Spots. This will have an adverse ripple effect in underserved communities. These changes further de-incentive Quality as providers currently participating in SUTQ are currently providing exceptional quality at a subsidized rate. The state of Ohio has an obligation to do right by its providers and early childhood educators by ensuring that they can care for themselves, their families, and their communities. Lawmakers must add money to the Department of Children and Youth (DCY) and Publicly Funded Child Care (PFCC) budgets for higher provider reimbursement rates. Without adequate funding, Ohio’s child care system will remain in crisis with early childhood educators, parents, and kids left to deal with the consequences.  -- (Internet) 3/26/2024 10:12 PM    My name is Rochelle Bankhead. I'm the owner of Under The Sea Childcare for over 25 years. Childcare industry has been suffering for about 8 years.McDonalds pays more than someone educating our children. There are mass closure of Childcare industry. Failure of the government will have a massive ramifications on the industry. One we have been under paid for 6 years with no reconciliation in sight.The Ymca have been getting 85% pay for 6 years this has to be illegal. Third they are cutting SUTQ which my center will lose 1,100 a month. So you give us a raise to take it back. It should be able to file a class action lawsuit. These are some horrible changes. -- (Internet) 3/26/2024 10:39 PM    Concerns Regarding Proposed Changes to Training Requirements I am writing to express my concerns regarding the proposed changes to the training requirements, particularly the transition from a biennium requirement to a requirement of completing 10-15 hours of training per year. As someone with over 25 years of experience as a family childcare educator, I value the significance of time management and understand the importance of professional development. However, I find the proposed adjustment to the training timeline rather challenging. The current biennium requirement affords me the necessary flexibility to allocate my training hours across a two-year period, allowing for a more balanced integration of professional development amidst my daily responsibilities. It grants me the flexibility to navigate unforeseen circumstances or challenges without the added pressure of condensing the training hours into a single year. Moreover, the biennium framework aligns well with the dynamic nature of our profession, where the pace of learning and growth may not always adhere to rigid annual timelines. By extending the timeframe to two years, it enables a more comprehensive approach to skill enhancement and knowledge acquisition, ultimately benefiting the quality of care and education provided to the children under my supervision. In light of these considerations, I respectfully urge for a reconsideration of the proposed changes. Maintaining the biennium requirement would not only uphold the practicality and effectiveness of the current system but also support the continued professional development of childcare educators like myself. Thank you for considering my perspective on this matter. I remain committed to contributing to the enhancement of our childcare practices. Trina Averette -- (Internet) 3/26/2024 11:01 PM    I do not agree with the upcoming changes to SUTQ -- (Internet) 3/26/2024 11:50 PM