________________________________________  THE VERMONT EDUCATION REPORT February 07, 2005 - Vol. 5, No. 06 ¯¯¯¯¯¯¯¯¯¯¯¯¯¯¯¯¯¯¯¯¯¯¯¯¯¯¯¯¯¯¯¯¯¯¯¯¯¯¯¯  Covering education news in Vermont and beyond... Informative, provocative, unique... Published by Vermonters for Better Education  VBE is a nonprofit, nonpartisan organization whose mission is to enlist parents and the public at large in achieving quality educational opportunities for all the children of Vermont by monitoring the state of education in Vermont; promoting the value of educational freedoms for all parents; and giving parents the evaluative tools with which to identify excellence. Libby Sternberg, executive director: VTBetterEd@aol.com NEWS & ANALYSIS... LIST OF EARLY ED RULES "PARTNERS" SHRINKS Yet another "partner" has peeled away from supporting the Vermont Department of Education's draft early education rules.  Maxine Brandenburg of the Child Care Fund of Vermont was originally listed by the VDOE as a partner in helping construct the rules. But Brandenburg says she "never reviewed, approved, or otherwise indicated support for the draft rules now being proposed by the Department of Education." She says at the meetings she attended she raised concerns about a number of issues. "I expressed my belief that we should assure geographical flexibility for parents, support the current provider network at the same time that we set long term goals for improving quality," she says. "I was very concerned about establishing certification and quality requirements that would eliminate the participation of most of the existing private pre-school providers." These are issues, in fact, that the Child Care Fund of Vermont has formally expressed concern about in a letter to the State Board and Commissioner of Education Richard Cate (see below). As reported last week in the VER, the VDOE falsely gave the impression that a variety of disparate groups had helped work on the draft rules. In a "List of Partners" originally included with the rules, both Brandenburg and Tim Volk were listed as representatives of the Vermont Business Roundtable when in fact they were representing the Child Care Fund of Vermont, and neither of them wholeheartedly endorses the rules themselves. Without Volk and Brandenburg's endorsement, the diversity among the "partners" dwindles considerably, leaving only the usual powerful players in the education lobby -- representatives of the VT-NEA, Vermont Superintendents Association, Vermont School Boards Association, and numerous staff from the VDOE itself. In other words, the list of partners seemed to be designed to indicate that the rule-making process included diverse views when in reality it reflected the views of the usual dominant education voices. The List of Partners was removed from the VDOE's web site where the early education rules can be found*: (http://www.state.vt.us/educ/new/pdfdoc/board/packet_04_0114/item_O_EE.pdf). * Note: At the time of this posting the link above was not working, but another copy was found here: http://www.state.vt.us/educ/new/pdfdoc/board/packet_05_0118/item_O_EE.pdf QUALITY STANDARDS IN EARLY ED RULES RAISE CONCERNS The early education rules drafted by the Vermont Department of Education and the education lobby have several "quality" components that could present problems for current early ed and childcare providers. In particular, the rules say that "at least one of the educators teaching a group of children in a qualified early childhood education program shall maintain a valid Vermont educator license with an endorsement in either early childhood education or early childhood special education." Programs that don't meet these standards wouldn't be eligible for the public funds. Programs have three years to come into compliance with this rule. While some private providers might have a licensed teacher running the entire program, they might not have licensed teachers for every group of children in the program. Some of the quality standards in the rules are actually higher than those required by national accreditation organizations.  CHILD CARE FUND'S LETTER TO THE COMMISSIONER January 27, 2005  To Richard Cate, Commissioner Department of Education 120 State Street Montpelier, VT 05620 RE: Proposed Rules Governing Pre-Kindergarten ADM Eligibility Dear Commissioner Cate: We are writing regarding the above-cited draft rules pending before the Board of Education. As you know, the Child Care Fund of Vermont (CCFV) is a component fund of the Vermont Community Foundation (VCF) and was founded in 1995 with a mission to build a long-term, sustainable base of financial and moral support to strengthen and improve child care for Vermont's children. CCFV's Advisory Board recently reviewed the draft rules and passed a motion to urge the Department of Education and the Board of Education to delay action on the proposed rules. The rationale for asking for the delay is twofold. First, as you know, the Building Bright Futures (BBF) transitional board appointed by Governor Douglas just completed drafting legislation that proposes to create a public-private partnership to promote a statewide, unified, voluntary system of early education. We believe that the Board of Education's proposed rules and the BBF legislation should not be put forth simultaneously and without serious consideration of how they interact.  For example, it is unclear how BBF's "regional affiliates" who are charged with coordinating community-based services for young children relate to the "collaborative needs assessment" the public schools must undertake in the "Planning Process" section of the Board of Education proposed rules. Second, we understand that the Agency of Human Services is also drafting rules governing early education programs. The proposed rules pending before the Board of Education should be delayed to enable better coordination and to ensure consistency with the BBF legislation and the Agency of Human Services rules. As we understand it from your public comments, the intent of the rules is to impose quality standards and other requirements on the current practice of schools to include pre-K children in their ADM counts and thereby draw down education funds. There are many collaboratives between public schools and private childcare providers that are working well using these ADM funds today -- Burlington and Franklin County being two examples. CCFV wants to encourage these types of collaborations. However, in some instances the draft rules appear to make it more difficult for these collaborations to take place.  For example, in order to fully utilize the existing provider system and increase its quality, any rule must recognize the obstacles many private programs face in becoming nationally accredited and offer new resources to support programs and their staff in working toward meeting the quality standards required for participation. The "Educator Licensing Standards" section of the draft rule requires that at least one of the educators teaching a "group" (defined as up to 20 children ages 3-5) must have a valid Vermont educator license with an endorsement in either early childhood education or early childhood special education. This requirement sets the bar too high. Even the existing 5 percent of homes and 15 percent of centers that are nationally accredited may not meet this standard. We do not want nationally accredited programs to have to jump through additional hoops in order to receive ADM funds. Our experience has shown that success for educators of 3 and 4 year olds is not necessarily related to an educator license. The "Program Quality Standards" section is equally troubling because it too appears to disqualify many private childcare programs from receiving ADM funds. Both of these sections allow a three year period for early childhood education programs to come into compliance with these standards. But there are problems with this as well. If a teacher who is working toward obtaining a license decides to leave the program right before the three year period expires will the program be ineligible to receive ADM funding? The "Planning Process" section of the proposed rule is also of concern to CCFV. One of CCFV's guiding principles is that the existing infrastructure of public and private early care and education programs be the foundation of any statewide early education system in Vermont. The "Planning Process" section requires that a school district engage in a "collaborative needs assessment process." The section also requires that the "school district shall build upon existing community resources before establishing new early childhood education programs." The draft rules contain no criteria for the collaborative needs assessment process or for a school district to determine whether or not it has sufficiently built upon existing "community resources." The language is not sufficiently strong to ensure that schools use existing community providers (homes and centers) before opening a program in the public school.  Another CCFV principle is that parents must be the ones to decide where to place their young children, either in a local school district program or in a participating early childhood center or home. The draft rules leave it up to the school districts to decide whether to contract with private providers outside of their district (the draft rules are actually silent on this point but we understand that it is the Department of Education's intent to allow school districts to continue the current practice of contracting with providers outside their school district). However, the draft rules contain no explicit authority for a parent to place his or her child in a program that is outside their school district. Geographic flexibility is critical to allow parents to place their children in programs close to their place of business, for example. It may be that the Department of Education needs additional rulemaking authority from the General Assembly to include such a provision in the proposed rules. This is another reason to delay action on the rules. We all share the goal of a statewide, unified, quality and voluntary system of early education for Vermont's preschoolers. CCFV would respectfully request that the Board of Education delay action on the proposed rules to allow for time to better coordinate efforts by the legislature, the Douglas Administration and the Agency of Human Services to achieve this goal. Please feel free to contact us with questions - Maxine at (480) 595-2253, or Judy at (802) 496-6789. Sincerely, Maxine Brandenburg, Co-Chair                 Judy MacIsaac, Co-Chair cc: Diane Mueller, Chair, State Board of Education  STATE BOARD OF ED EMAIL ADDRESSES The State Board will consider the early ed rules at their February 15 meeting. Below are email addresses for board members. Diane Mueller (Chair) Dmueller@okemo.com Lindy Caslin caz1072@yahoo.com William Corrow wbcorrow@aol.com Rick Manahan RMan@together.net Chris Robbins Chris.Robbins@EHV-Weidmann.com Linda Cox (vice chair) Cox@sover.net Marissa Cormier misscee114@yahoo.com Tom James tomjames1@adelphia.net Deborah McDowell DebMcDowell@compuserve.com Susan Schill schills@sover.net Or, you may send comments to the board through the Vermont Department of Education itself by emailing Carol King at carolking@education.state.vt.us or by calling her at 802.828.5101. If you do contact the State Board, consider sending a copy of your comments to us at VTBetterEd@aol.com.  *   *   * The VERMONT EDUCATION REPORT is published by Vermonters for Better Education 170 Church Street, Rutland, VT 05701, 802.773.5240 Contact VTBetterEd@aol.com for more information.   Subscribe Here SubscribeRemove

---

Return to Education Report Index | Return to VBE Index | Vermonters for Better Education Homepage 

---

........