Jul 25, 2016Times Argus
William Moore
The Child Development Division of the Vermont Department for Children and Families has issued new regulations governing family child care homes and family child care professionals. The regulations, approved in May and effective in September, will impose significant costs on FCCHs and FCCPs. The Chamber testified in opposition to the regulations at the hearing conducted by the General Assembly’s Legislative Committee on Administrative Rules. 
There may be a glimmer of hope to revisit the costs associated with the new regulations. The Blue Ribbon Commission on Financing High Quality, Affordable Child Care, a quasi-governmental panel, has been charged to inventory and review 10 years of reports relating to high quality, affordable child care; to determine the elements inherent in all quality child care programs; and to make recommendations to the Legislature and the governor. The Blue Ribbon Commission is holding hearings across the state and is in Barre this evening (from 7:30 to 9 p.m. at the Aldrich Public Library). Additional hearings will be held on July 26 in Rutland and Brattleboro (find the schedule at the commission’s website, http://buildingbrightfutures.org/blue-ribbon-commission). Those unable to attend can send written comments to the commission. 
The Chamber has submitted our concerns to the commission and I would like to share those concerns with you. The Chamber’s primary concern is a simple one. Employees must have access to affordable, quality child care. 
First and foremost, we believe that the estimated cost of compliance with the new regulations may force many FCCHs and FCCPs either to close or to operate in the “underground economy,” in an illegal and unregulated manner. As these regulations force the closure of properly licensed facilities, employees will have a difficult time finding child care and there will be a direct, negative impact on employee morale and job performance. There will be increased absenteeism and productivity issues which will also directly affect employers across the state. 
We believe that the Economic Impact Statement that accompanied the new regulations is incomplete and inadequate. 
I have personally reviewed the EIS several times and I am at a loss to find any discussion of the “benefits anticipated” for the enterprises “potentially affected” by the proposed regulations as required by the Vermont Administrative Procedures Act.
The EIS does not indicate any impact on Vermont businesses whose employees depend on child care while they are at work. An EIS that neglects to assess the impact on Vermont “enterprises” is incomplete at best.
The EIS identified seven expenses to be incurred by the FCCHs and FCCPs totaling $1,964. One of those costs is “associated with providing sufficient cushioning material for use zones when needed.” According to the EIS, those costs “will vary depending on the material used (e.g. peastones, wood chips, sand or rubber mulch), square footage needing coverage, and transportation costs.” That is not an estimate of the cost of cushioning. That is one simple example of the weakness of the EIS. Another new requirement that is not adequately addressed in the EIS is for staff training. Is it truly necessary for a part-time employee who may work five hours or less a month in some capacity to undergo 15 hours of annual professional development?
I have calculated those same seven areas found in the EIS as costing at least $2,400. In addition to those costs, however, there are nine other additional costs that were imposed by the regulations but not identified in the EIS that total well in excess of $10,000, hardly an insignificant cost. It is these costs that put additional stress on FCCHs and FCCPs, resulting in the closing of FCCHs.
If you are as concerned about this issue as the Chamber is, I encourage you to contact the Blue Ribbon Commission and file comments on the commission’s website, or call the Commission at 802-828-3333.
William Moore is the president of the Central Vermont Chamber of Commerce.
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