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Public Comment 1
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2/2/2024 12:25:18Melinda FrizzelThank you for the opportunity to share my thoughts. While I appreciate discussions on important issues (Black History Month, social justice opinions, etc), I believe it's crucial to ensure our focus on universal PreK remains dedicated to the developmental and educational needs of the children. I suggest we consider a separate platform for broader political discussions, allowing us to maintain the integrity of our PreK agenda. Looking forward to productive discussions!
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2/2/2024 12:25:24Oscar TangThe Network also believes this is an important opportunity to amend this program so that it fairly supports state FCCHEN contractors and the FCC provider participants to meet the quality objectives of this program. Feedback from R&R agencies across the state identified four of the biggest challenges that FCCHEN contractors face and that need to be corrected in the program:
The FCCHEN contract does not offer enough funding to pay for a contracted staff to administer and support its network of FCCs.
The FCCHEN contract does not cover enough funding to operate the program. The 30% of the contract is not enough to fully staff and provide the support and array of services to providers.
The subcontract to FCC providers, often referred to as the 70% of direct service), must be increased to accommodate the cost of care and the requirements and additional work for to meet the quality standards required of this contract.
Contract adjustments must also be made to include and address the additional challenges of including non-English-speaking providers whom would also benefit from back end administrative services and professional development.

We also additionally encourage funding for other models that achieve the same objectives of improved professional development and/or business support for family child care providers that have less stringent program participation requirements than the FCCHENs. The state needs to support Staffed Family Child Care Networks (infrastructure of support decoupled from other funding sources that can pay for the cost of care), and/or Shared Services hosted agencies (that can be a more robust array of back end supports or efficiencies shared amongst the network of providers). Each of these models relieve the burden of administrative duties so that providers can focus on the quality service of caring for children and supporting families.
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2/2/2024 12:26:00Melanie SluggettPlease clarify the statement regarding adjustment of TK and preschool ratios of 1 to 10 in relation to the adjustment of TK ratios.It was not clear to me how that would affect different aged classrooms..thanks!
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2/2/2024 12:27:55Wendy Shenk-EvansRegarding ratios, a Montessori classroom has several essential pedagogical components, including higher ratios and group sizes along with three-year mixed age groupings and highly qualified teachers, that work in concert with one another to create the high-quality environment and produce the excellent outcomes for which Montessori is known. The Montessori approach embeds child-initiated activities, continuous teacher observation, and individualized instruction, and yields a high level of engagement in learning activities - the very components that drive desired student outcomes, according to research. Because they are so integral to the Montessori approach, larger class sizes and higher ratios are core components of accreditation standards for Montessori schools.
Recommendation: Create an allowance for accredited Montessori early childhood programs to have group sizes up to 30 and adult:child ratios up to 1:15. Several states have already added increases to group sizes and ratios specifically for Montessori programs where the staff meet the required qualifications and the other aspects required in Montessori programs are met. MPPI can support states that want to ensure that programs are implementing all the core components of the Montessori method that support the larger class sizes and ratios.

We also recently worked with a public school and the office of childcare to clarify that TK students and UPK students could be in the same mixed age Montessori classroom along with Kindergarteners maintaining the 3-6 year old mixed age grouping dictated by the pedagogical model. Would love to see this clarified in the report. wendy@montessoriadvocacy.org for further conversation. Thank you.
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2/2/2024 12:34:31Alan GuttmanAs the report and recommendations are submitted a general suggestion that any "mandates" that will require programs to expend additional monies, that these be identified and fully funded (i.e. that there shouldn't be any unfunded mandates to programs)
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2/2/2024 12:37:22Veronica Montano Sanchez More clarity on how to become a CPSS site
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Public Comment 2
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2/2/2024 14:36:26Sarina LynnI truly appreciate the ECE field. I think the videos and surveys clearly demonstrate the professionalism, integrity, and passion of the field that educates California’s youngest and most vulnerable children. Several spoke about the desire and need for more training and increased teacher education to best serve children and families. That being said, without PROFESSIONAL COMPETITIVE WAGES for the entire ECE field –subsidized and private pay, community based and LEA, family child care homes and center-based programs; no further requirements should be placed on the backs of the women, a majority of whom are women of color. The stipends are a STEP in the right direction but must accompany a seismic shift in reimbursement rates as recommended by the CA Rate and Quality Stakeholder Pane for racial equity and stability in the ECE workforce. Although the charge of this workgroup is limited to action that will not require additional cost, I strongly urge and encourage this workgroup in the notes and addendum of the report to highlight the need for the state to finally fully fund the state subsidized early care and learning programs and adopt an alternative methodology based on the TRUE cost of care. The TRUE cost of care is one that is not subsidized by the early learning and care workforce accepting low wages to care for and educate children.
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2/2/2024 14:38:01Sarina LynnI raise up the words, the power, and the wisdom of Otokonda Ble when she spoke about the need for flexibility and access to professional development and training classes. She is one of thousands of providers that opens their doors at 6am and ends the day at 7p. Requiring Otokanda or other professionals to do training online and in flexible ways is CRUCIAL to the success of this initiative. I also want to raise up Samantha Thompson’s recommendation to add increase AND RETAIN the number of diverse UPK educators, that are culturally and linguistically diverse.” Ensuring throughout the report both multi-lingual and multi-cultural are elevated and recognized as strengths. When we talk about the importance of multi-cultural and multi-lingual, I must note that the community-based programs (private pay, subsidized, center based, and family child care homes) are the most diverse AND these community-based programs due to complicated and inequitable funding streams are also severely underfunded. Successful strategies must consider systemic barriers and create systemic changes. There is a huge disparity in early educator pay between LEA TK/K teachers and those in community-based programs (private pay, subsidized, center based, and family child care homes). Although the state now refers to all of these programs that serve children 3-5 years of age as “UPK” the fact remains that TK/K teachers on average earn double of their community-based teacher cohorts (see CSCCE for details and further information). Although I appreciate the universalism of this workgroup’s approach to professional development, the state’s segregation and continued underfunding of the mixed delivery community based early learn and care agencies perpetuates inequity for and reinforces the existing gaps in pay and opportunity for women of color that serve California’s youngest children in community-based centers and family child care homes.

For reference, I have included the below from the 2022 CSCCE Early Educator Compensation Study. “On an hourly basis, the median wage in a child care center in California in 2020 was $16 for an assistant or aide and $19 for a lead teacher. By comparison, directors and administrators earned $26 per hour, which is less than half the wage of an administrator in an elementary-school setting. Large FCC providers (serving up to 14 children) reported earning $40,000-$56,400, similar to the salaries of center teachers and directors. Small FCC providers (serving up to eight children) reported the lowest wages among the ECE workforce, with an annual income of $16,200-$30,000. The entire early education workforce is well below the $41 hourly wage of a transitional kindergarten (TK) or elementary school teacher—and below the living wage of $40 for a family with one adult and one child.
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2/2/2024 14:38:26Leanna ZarzarThe information shared today show ECE is moving in a positive direction. I agree that pathways for Director's with high level degrees and permits should have a pathway to administrative credential.

I wonder if thier is a collaboration with California childcare licensing and if these recommendations will be shared and adapted across all programs.
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2/2/2024 14:40:25Wendy Shenk-EvansCurrently, 11 states recognize Montessori teaching credentials plus a bachelor’s degree as part of a pathway to a state teaching license, which speaks to the rigor and comprehensive nature of Montessori teacher preparation. These pathways are essential to ensuring that Montessori classrooms have a highly qualified teacher, namely, one with a Montessori credential.

Through rigorous, college level coursework, Montessori teachers study child development, curriculum, classroom management, instruction (both standard and differentiated) and the other knowledge and skills included in traditional teacher preparation through a Montessori lens. There are some Montessori preparation programs embedded in the bachelor’s or master’s degree programs of colleges and universities, but most often they are situated within independent centers that operate outside of the higher education system. Standard bearers, such as the American Montessori Society (AMS) and American Montessori Internationale (AMI) develop and oversee requirements for their affiliated teacher education programs. In addition, the Montessori Accreditation Council for Teacher Education (MACTE), which is recognized by the US Department of Education, accredits Montessori teacher education programs in both freestanding centers and institutions of higher learning, ensuring that comprehensive teacher competencies are met. These systems of preparation exist to ensure a pool of highly qualified, Montessori teachers.

Please ensure that there is a lead teacher pathway for individuals with a bachelor’s in any field and a Montessori credential issued by AMI, AMS, or a MACTE accredited institution. The Montessori early childhood credential is, at a minimum, equivalent to 33 college credit hours.
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2/2/2024 14:44:21Wendy Shenk-EvansWith regards to multi-lingual learners, Indigenous language revitalization programs serve a distinct and necessary purpose. Indigenous knowledge, wisdom, and culture is embedded in their language. Indigenous educators have shared with me that language fluency is the top criteria needed in their teachers. It is imperative that Indigenous language immersion programs be able to hire language fluent teachers and staff regardless of higher education credentials.
In addition, many Indigenous language revitalization programs do not take advantage of participating in public funding streams because of requirements for English language competency testing using instruments based in the English language. This type of requirement undermines the work they need to do to reclaim their languages, so please be mindful of program requirements such as this and how they may create inequities for Indigenous children and families.
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2/2/2024 14:47:55Jeannette MulhernPlease consider that ratios for our youngest children were based on health is prepared settings. With LEAs circumventing Title 22 in environment and ratios we risk the safety and health and more importantly the care and learning of our youngest children. The inequity of funding exists between programs serving these children. The location (school districts for example) should not drive what we know is best practice for these young children.
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2/2/2024 14:48:21Heather Haubrich My concern is that the proposed changes to the permit matrix will negatively impact the women of color in the workforce due to the access to college courses, the time and energy to take said courses, and the lack of pay advancement when completing the higher education. Some community colleges lack coursework at time that is flexible and in languages of the students which will negatively impact the overall ECE workforce.
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2/2/2024 14:51:00Oscar TangIt is NOT REASONABLE to expect better WITHOUT investing more.
Someone is paying for it sooner or later.

Most of "quality" indicators are build upon the proof of ability to produce administration documents instead of serving the needs of children and families.
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2/2/2024 14:52:38María CastroI cannot tell if comments were heard. Can you acknowledge speakers so they know their “on”. My comment was concerning Mixteco/ Zapotec speakers. Interpreters are hard to find—but familiarity with their cultures has helped our providers interact appropriately with the children . Can this need be sent to someone with power to research? And disseminate info & resources to the childcare community.
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2/2/2024 14:52:48Crystal Jones How are black early childhood educators being sustained, supported,and offered equitable opportunities to expand and partner? How are black early childhood educators offered ways to grow according to the master plan created and equity statements established in our local planning council and local educational agencies. How are we ensuring we have the mentors we need and support we deserve to remain experts in the field and thriving in our facilities and under served communities?
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2/2/2024 14:54:29Sarina LynnI am very concerned about the recommendation to change ratios to serve 4-year-old children at a 1:10 ratio, instead of a 1:8 ratio. When first proposed TK was advertised as a quality option because the ratios would be no more than 1:10. Now, due to funding issues, TK ratios have been watered down to 1:12. Until UTK, there was no discussion for early learning and care programs to increase ratios and class size. Because this group and all early learning programs should be founded in what is developmentally appropriate and what is best for the children, I strongly disagree with the recommendation regarding higher ratios.
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2/2/2024 14:57:09Sarina LynnTotally agree with this workgroup member comment:
We need aligned quality measures for all CDE UPK programs, including CSPP and TK. It really is concerning that CSPP is the only program implementing CLASS and Health and safety requirements, while TK has very few quality standards. TK teachers are also concerned with the health and safety of young 4-year-olds sharing playgrounds, bathrooms, and lunch rooms with older children. Lunch and recess are outside of “instructional time”, and there are no ratio or group size requirements during this time. Meal time scheduling is also very difficult for school sites to manage, which leaves TK students with inappropriate meal times, such as a 10am lunch for students who stay all day because that is the only time available to get them into the lunch room. These are concerns TK teachers are elevating in regard to health and safety concerns for our youngest students.
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2/2/2024 14:59:20Denise CamposI am commenting on behalf of center-based providers and family childcare providers. Is there a way that we can contract directly with the state for UPK/TK spaces?
. Our programs have been greatly affected with all of our students going to the public school for TK and our enrollment has dropped drastically. We all have our permits and teacher qualifications and we would like an opportunity to be able to serve TK age children.
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2/2/2024 14:59:46Sandy Moreno Your thoughts on requiring childcare providers and program directors to have training in pediatric nutrition.
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2/2/2024 14:59:55Nellie Rios-ParraI would like to echo Tony Jordan's comments regarding the adult to child ratio, those working with children recommend and desire a smaller adult to child ratio to better meet the needs of all children and provide high quality care and education. Remaining at a ratio of 1:12 is too high. Continue to seek alignment with Community Care Licensing, Title 22 regulations (Teacher-Child ratio, 101216.3);
Contractors shall maintain at least the following minimum ratios in all centers:
(A) Infants (birth to 18 months old) - 1:3 adult-child ratio, 1:18 teacher-child ratio.
(B) Toddlers (18 months to 36 months old) - 1:4 adult-child ratio, 1:16 teacher-child ratio.
(C) Preschool (36 months to enrollment in kindergarten) - 1:8 adult-child ratio, 1:24 teacher child ratio.
Moving forward with best practices is the goal, anything less than high quality needs additional attention and supports to be implemented to fidelity.
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2/2/2024 15:03:25Kelly GraeschWhile we think it falls short of a true mixed delivery system for California’s families, we appreciate the inclusion of certain FCCHEN programs. There is much confusion among the provider community about FCCHENs and participation in UPK. The FCCHEN program limitations that we have heard from contractors includes: the participation agreement for FCC providers to participate in a FCCHEN, must be increased to accommodate the cost of care and the requirements and additional work to meet the quality standards required of this contract. Rates and the administrative costs must be realistic to the work that is required. Assessment tools are not meeting the linguistic needs of a diverse workforce, ensuring the tools are available in many languages responds to the diverse needs of California’s ECE workforce. Revisit assessment tools, are they meeting the needs of California’s diverse population of children and the workforce?g
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2/2/2024 15:06:12Kelly GraeschWaivers, and experience that count towards college credits can validate the lived experiences of ECE professionals, developing alternatives and pathways opens the doors for a more inclusive and diverse workforce. Example, apprenticeships, credit for CDA obtainment, credit for lived experience through alternative coursework, credit for participation in FCCHEN programs, coaching and credit through staffed family child care networks (not the currently funded FCCHEN but an additional model that was shared at a previous workgroup meeting by All Our Kin) .

Developing alternative pathways that recognize the CD permit holder with administrative experience as eligible for Administrator Credential recognizes and values the work and commitment of CD administrators and promotes a more inclusive and diverse workforce.
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2/2/2024 15:06:32Crystal Jones Loved the parent feedback and insight to build what our parents desire and need as a care facility and support for their child to learn their culture language and become multilingual. Loved the 1 to 10 ratio for preschoolers ages 3 and 4. Loved the feedback of how Dr. Wesley and Nancy Herota on how they waived the degree or permit based on experience and expertise. How can we be offered that waiver as black educators to meet the gaps and continue the great work needed for our children, families, and communities. I am definitely interested. Especially after being displaced and not being supported by all the leas I spoke with and had Me fill out letters of intent thinking I'm included for it to be a year and a month from my own public counsel and county working to make me homeless while serving high quality childcare and support services in my home and in a center setting. I am devastated and blown away at how I listened and reached out to everyone to not be helped sustained and offered capacity building assistance and the desire to fill empty slots. I did everything on my own with my community and neighbors not aware of how our child development leas operate and was genuine caring and serving why are me and my kids in the streets homeless still as we continue to reach out for help and real justice. I am so confused frustrated and overwhelmed my kids do not deserve this from me giving my all and insight to my council to boldly deny me help and say they can not help me. What is really going on? Offered to get on public assistance but not help to recover my child care businesses. Where is the equity and inclusion with sustainable resources and support??? I keep hearing our ECE is ran by black educators and mothers where is the help to be a priority to have the resources available in serving more kids and ensuring we are sustained and helped?
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2/2/2024 15:20:50Alan GuttmanTo Reiterate My Verbal Testimony: While the workgroup's charge was to provide "no-cost" recommendations, the state needs to be very mindful that any and all recommendations that result in mandates for programs or personnel, those requirements should not create or shift costs onto counties, municipalities, districts, programs, teachers, or providers. In other words, any and all mandates that result from the recommendations should be FULLY FUNDED. As an example, if a reduction in adult:child ratios (to expand access to high quality programs and services) results in a need for additional facilities, then it is incumbent on the state to provide (i.e. fund) such necessary facilities since it is for the betterment of the children. Or if compensation and benefits reforms (e.g. increased salary or expanded benefits for early care and education caregivers, teachers, and administrators) is proposed or mandated, such requirements MUST be accompanied by sufficient funding so that those costs are not borne by counties, municipalities, districts, or programs). The early care and education system in the United States, including California, has been sustained on the backs of (by the pocketbooks of) early care and education professionals for too long. Finally, so as to align this testimony with the charge of the work group, my final general recommendation is that with regard to any recommendations of the workgroup to the state that reflect best practice and what is best for young children and families, that cost to the state to fulfill the charge of the workgroup not nullify the 1400+ hours of effort that professionals and the public committed to this process. Otherwise the result will be just another report that sits on a shelf or a PDF document on a hard drive.
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2/2/2024 15:56:27Claudia MendozaIn order to have a mixed delivery, it is important for quality early education run in our family childcares be included. There are many FCC programs that go above and beyond for our young student and their families. Many of us have the education and professionalism of UPK goals. Making the only way to join going to FCCHEN is complete left us out if the FCCHEN that we belong is not join UPK as apparently is high cost for them. I should not be that way and quality program should be able to contract directly or with an organization that is already working toward quality. If the program works with a pioneer childcare providers we can serve as mentors for other childcare providers. The program doesn''t have to be expending much in training as there is already a Workforce and other organizations available for us to achive higher education. Mentors can be use working with the Californing Mentor Program and QSLA who already receive funding. Please help FCC who voluntarly want to participate in UPK for the best of our community and want to provide quality preschool. This is a barrier and challenge for us. The Family Child Care community help each other and we can support each other to accomplish and meet requirement and goals. We are self driven professional with passion with working with children and helping families and our community.
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