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Proposed Center Rule Feedback

ECEA of Colorado has been working for YOU! We’ve been attending policy meetings and the FCCH rule group bringing feedback to the state that benefits all programs. GREAT NEWS!!! Carin Rosa announced this week in the ECLC Workforce Subcommittee that they have heard from enough programs to now change the new rule set to read that if a training is required then it counts towards the 15 hour of annually required trainings! That is what your feedback can accomplish! On that note, there are some things that ECEA leadership would like you to consider. You get to decide! Maybe you agree with us, maybe you don’t! What we need is for everyone to provide their feedback to the State before the public comment period closes on August 19th! That link is HERE.

  1. In order to ensure that staff can be onboarded without delay, and owner/directors can utilize their authority in determining who is qualified to work in their business, ECEA is recommending that the following verbiage be added to rule 7.702.45A1B&C: “An college degree (Associates, Bachelor’s, Master’s or Doctorate) from a regionally accredited college or university with a major area of study in any area other than those listed at 7.702.45A1a, and enough training or ongoing professional development or experience, to meet the criteria for an early childhood credential, along with a signed affidavit with a points sheet that verifies that the credential has been submitted for approval. Documentation is maintained in the file at all times.”
  2. We know that we can put it into policy that a weapon is not allowed on site. We also know that Police Officers are not allowed to leave their weapons in the car. Programs do not want to be cited for an armed officer in their program.
  3. 7.702.45. F. 2. – Although the intent of the rule to allow up to 5 business days per year that an Assistant Teacher can sub for an ECT, we wonder if it’s possible for this number to be expanded to a realistic number that meets todays workforce challenges?
  4. 7.702.42L4b – This rule, although not color coded is a NEW potential rule that would require that a training certificate has either the competency domain or is “from a nationally approved vendor list”. This requirement takes discretion away from business owners/directors to determine what their specific staff needs are and to address them. Approved vendor lists from OEC have been difficult to read, and difficult to update. Why would the State want to create another service that they have to oversee that directly impacts the ability of programs to meet their staff needs?
  5. 7.702.64H. “Any form of restraint is not permitted.” The next rule allows for physical redirection. We feel compelled to point out that on a rare occasion, a child’s behavior may provide harm to other children and require a restraint to keep them from doing so. We ask that a phrase about “immediately releasing a child once there is no risk for imminent danger” to this rule. We also want to point out that higher education courses and state recognized certifications TEACH these practices. Allow professionals to implement the information that they’ve learned from these classes.
  6. Additional recommendations can be found HERE. Please note, there are two charts in this document. The second chart is related to expanding verbiage of center rules to enable the possibility of continuity of care settings in private programs that do not have access to funding streams such as Early Head Start. ECEA does not advocate for the requirement of Continuity of Care settings but as the Executive Director, I do believe that business owners should not be limited in the scope of care that they choose to offer in their business. If you are interested in the potential of offering Continuity of Care settings in your program some time, the recommended verbiage changes need to be made to the rule set to enable that possibility.