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OSSE also received a comment requesting clarification as to whether a training that is not specifically applicable to the children served by the staff member is required, specifically referencing the training on sudden infant death syndrome. The proposed rulemaking sets forth language that reflects necessary content variation within required topic areas. As provided in §§ 139.2(c) and (d), the trainings shall be included “as applicable.”

The State Superintendent received two comments specific to requirements for training in first aid and CPR. One commenter sought clarification regarding the first aid and CPR training requirement. The commenter correctly notes that § 139.2 requires all staff members receive training in first aid and CPR within thirty (30) days of hire, but § 150.2 requires two (2) staff members readily available to administer first aid or CPR at the Facility at all times. The State Superintendent appreciates the comment and recognizes how these two sections may seem in conflict. The State Superintendent notes, however, that § 150.1 requires all staff members possess current and valid certification in first aid and CPR, which aligns with the training requirements in § 139.2. The intent and purpose of § 150.2 was to ensure that a facility is appropriately staffed in case of an emergency, not to set requirements for the number of staff members trained. Another commenter requested that the requirement for training in first aid and CPR was moved to § 139.3, the orientation trainings done within ninety (90) days of hire, because the facility would need an outside vendor. While OSSE recognizes the challenges presented in obtaining an outside vendor, training in first aid and CPR, and the confidence to use these skills, is critically important to the outcome of an emergency situation. Accordingly, OSSE will retain the requirement for first aid and CPR within thirty (30) days of hire.

G. Program Activities for Healthy Development

Sections 140 through 141 set forth the activities and curriculum for children’s healthy development. Specifically, § 140.1 requires that a licensee implement a curriculum that is consistent with the District of Columbia Early Learning Standards. Two stakeholders commented on this requirement. One commenter specifically noted that the standards are extensive and it is not clear how the term “consistent” will be interpreted. Both commenters recommended that this requirement should be removed from the regulations and that the standards should be issued as guidance. Neither § 140.1 nor the definition of “District of Columbia Early Learning Standards” set forth specific requirements for the implementation of the standards. The “District of Columbia Early Learning Standards” provides a framework for the desired outcomes and content for the education of the District’s youngest learners but the standards do not dictate the actual curriculum, classroom practices, and teaching strategies that licensed facilities use. While the District of Columbia Early Learning Standards are an important component of the District’s comprehensive, high-quality system of early care and education, OSSE recognizes stakeholders’ concerns. Therefore, in response to these comments, this final rulemaking does not adopt § 140.1 that was included in the Notice of Proposed Rulemaking. However, this final rulemaking does reserve § 140.1 for future rulemaking after further consideration and consultation with stakeholders. In addition, this final rulemaking does not adopt the definition “District of Columbia Early Learning Standards” but will consider adding it back in future rulemaking after further consideration and consultation with stakeholders.