3.7.2.2 · The licensee shall ensure that evacuation drills are conducted at least once a month, and children and staff are evacuated in under three (3) minutes. Licensees of a CBCCPP located within a public or independent school building may count a lock-down drill performed while the CBCCPP is in operation in place of a monthly evacuation drill with the CBCCPP children and staff and at least three (3) of the monthly drills conducted within 365 days shall be evacuation drills.

During the visit, the evacuation drill log indicated that no evacuation drills were conducted for the months of November and December of 2023. Staff testimony supported that these drills had not occured.

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3.7.1.2 · The licensee shall ensure that all staff are trained on the Emergency Response Plan and are aware of where to find the written plan in the CBCCPP.

During the visit, staff testimony reflected that the emergency response plan is made available to all staff upon hire. The program has an already established system to have staff read the plan, ask questions and sign a document stating their understanding of the plan. However, the program is not currently utilizing that system or any other system to ensure staff are properly trained on the Emergency Response Plan as required.

Open Not marked corrected in the state record

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5.10.1.10.4 · Materials required for routine cleaning shall be stored and used in a safe manner out of the reach of children.

During the visit, it was observed that a container of clorox disinfecting wipes and multiple bottles of hand sanitizer were stored at children's reach. One child was observed to pick up a bottle of hand sanitizer and use it on their own hands and then squirt it onto the hands of multiple other children. These items were all noted to have labelling stating: "Keep Out of Reach of Children".

Open Not marked corrected in the state record

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6.2.4.4 · The program director shall ensure that a staff member who is at least qualified as a teacher assistant is present while children are present at the CBCCPP.

During the visit, Staff B stated that they regularly work with the children for the afterschool portion of the program when the regular staff leave for the day. Staff B stated that Staff F typically works with them each afternoon. Neither Staff B or F are qualified as at least a teacher assistant. This does not meet the requirements of this rule.

Open Not marked corrected in the state record

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7.1.2.2 · Staff who are counted in the staff/child ratios and auxiliary staff left alone with children and/or counted in staff/child ratio as specified in the rule 6.2.1.8 of these regulations shall obtain training in pediatric first aid and in infant and child CPR within three (3) months of beginning work in the CBCCPP and remain currently certified.

A review of staff files and staff BFIS credential accounts, reflected that Staff A, B and C had not yet completed infant and child CPR and pedicatric first aid certifications. Staff A, B and C have been employed by the program since August of 2023 and hold position titles which allow for being counted in ratio and left alone with children.

Open Not marked corrected in the state record

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3.3.5 · The licensee, staff, and auxiliary staff shall be trained in prevention, identification and mandatory reporting of child abuse and neglect.

A review of staff BFIS credential accounts and staff files reflected that Staff C, D and E had not yet completed the required Mandated Reporter Training; Protecting Vermont's Children: Reporting Abuse and Neglect. Staff C and D hole position titles which allow them to be counted in ratio and left alone with children and have been with the program for at least five months. Staff C was left alone with children during this visit. Staff D stated that they are left alone with children during the afternoon protion of the program. Staff E is an auxiliary staff and has been with the program for more than two years.

Open Not marked corrected in the state record

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3.7.3 · Emergency Preparedness Training: Within 365 days of opening a CBCCPP, the licensee shall attend emergency preparedness training which shall include content specifically related to sheltering in place in the event of an emergency in which the licensee and children present need to remain in the CBCCPP for an extended period.

A review of staff BFIS credential accounts and staff files, reflected that no current representative of the licensee had taken an approved emergency preparedness training. The director of program has been appointed such since October of 2020.

Open Not marked corrected in the state record

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7.1.3 · The licensee, in consultation with the program director, shall establish written program policies and procedures and provide these to staff and to auxiliary staff left alone with children and/or counted in staff/child ratio as specified in the rule 6.2.1.8 of these regulations during an orientation training session approved by the Division prior to being left alone with children. Trainees under eighteen (18) years of age and other staff not left alone with children shall complete the orientation training within at least one (1) month of their first date of working with children. Complete written information and the orientation training session shall include: Basic knowledge of child growth and development; Routine and emergency health protection of children including health related exclusions; Safety and sanitation requirements including handling and storage of hazardous materials and disposal of bio contaminants; Positive behavior management; Supervision of children; Child accident and injury procedures including building and physical premises safety; Safe sleep practices; Administration of medication requirements; Emergency and evacuation requirements; Nutrition and food safety including prevention of and response to emergencies due to food and allergic reactions; Recordkeeping; Transportation and child passenger safety; Release of children; Respectful engagement of families; Preventing, recognizing, and reporting child abuse and neglect; including information about the signs and symptoms of sexual abuse, sexual violence, grooming processes, recognizing the dangers of child sexual abuse, and other predatory behaviors of sex offenders; Recognition of and response to the symptoms of common childhood illnesses; Preventing the spread of infectious disease; Providing developmentally appropriate activities and experiences for children; Inclusion of children with special needs; Guidelines for volunteers, partner staff, auxiliary staff, and business managers; Responsibility to comply with current applicable licensing regulations; Staffing requirements to include opening and closing; and Ensuring children have extra clothes and diapers available.

A review of staff BFIS credential accounts and staff files reflected that Staff C and F had not yet completed an approved orientation training. Staff C and F hold position titles which allow them to be counted in ratio and left alone with children. Staff C was counted in ratio and left alone with children during this visit. Staff C and F have been employed by the program for at least five months.

Open Not marked corrected in the state record

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7.4.4 · All staff shall complete fifteen (15) clock hours of annual professional development activities as required in the rule 7.4.2 of these regulations. Substitutes filling a staff position for less than thirty (30) consecutive days within a 365 day period shall be exempt.

A review of staff BFIS accounts and staff files reflected that the Director and Staff D had not completed 15 hours of annual professional development based on their start dates. Staff D had completed eleven hours of professional development and the Director had completed zero hours of annual professional development.

Open Not marked corrected in the state record

Open / not marked corrected.

3.4.7.3 · Within six (6) months of the initial date of employment; staff and auxiliary staff left alone with children and/or counted in staff/child ratio as specified in the rule 6.2.1.8 of these regulations, and the program director shall maintain an up-to-date BFIS Quality and Credential Account. Documentation, verification of qualifications, and all annual professional development activities as specified in the rules in sections 7.3 and 7.4 of these regulations shall be submitted to Northern Lights at CCV to be verified and maintained in BFIS.

A review of BFIS credential accounts and staff files reflected that required documents for the Director, Staff B, E and F had not submitted in a manner which ensures compliance with this rule. the Director and all three listed staff have been employed by the program for at least six months.

Open Not marked corrected in the state record

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3.4.7.5 · The licensee shall maintain a current list of the licensee or designee, staff, auxiliary staff, and volunteers as in the rules in section 7.7.5 of these regulations, as applicable in BFIS. Any changes shall be reported through BFIS within five (5) working days of the change.

A review of the BFIS program Staff List reflected that four individuals listed at the time of the visit had not been working with the program for at least 30 days. This does not meet the requirements of this rule.

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5.10.2.3.2 · The CBCCPP shall ensure that perishable food provided by home is stored in insulated lunch boxes with at least two (2) ice packs. The CBCCPP shall ensure that perishable food provided by home is stored in a refrigerator as specified in the rule 5.10.2.3.1 of these regulations when the perishable food is not stored in an insulated lunch box, and/or not stored with at least two (2) ice packs.

During the visit, it was observed that children's lunchboxes contained perishable items, such as chicken, dairy products, and lunch meat and did not contain at least two ice packs. Most observed lunchboxes contained zero ice packs. All children's lunchboxes are stored at room temperature.

Open Not marked corrected in the state record

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5.10.1.1.2 · Children shall be protected from choking hazards presented by cords on window coverings, electric or electronic appliances or equipment and telephones.

During the visit, it was observed that multiple cords were not secured and were accessible in areas where children were playing. The accessible cords were noted in both preschool classrooms and included; cords to phones, fans, computers, speakers, and one long green extention cord.

Open Not marked corrected in the state record

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5.2.1.2 · The program director shall ensure that adults also wash their hands: * Before and after giving medications; * Before and after caring for a child who is injured or may be sick; * Before diapering; and * After coming into contact with blood, fecal matter, urine, vomit, nasal secretions or other body fluids.

During the visit, it was noted that at least eight children were permitted to use hand sanitizer after returning from outdoor play and prior to eating lunch. This does not meet the requirements of this rule.

Open Not marked corrected in the state record

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7.1.3 · The licensee, in consultation with the program director, shall establish written program policies and procedures and provide these to staff and to auxiliary staff left alone with children and/or counted in staff/child ratio as specified in the rule 6.2.1.8 of these regulations during an orientation training session approved by the Division prior to being left alone with children. Trainees under eighteen (18) years of age and other staff not left alone with children shall complete the orientation training within at least one (1) month of their first date of working with children. Complete written information and the orientation training session shall include: Basic knowledge of child growth and development; Routine and emergency health protection of children including health related exclusions; Safety and sanitation requirements including handling and storage of hazardous materials and disposal of bio contaminants; Positive behavior management; Supervision of children; Child accident and injury procedures including building and physical premises safety; Safe sleep practices; Administration of medication requirements; Emergency and evacuation requirements; Nutrition and food safety including prevention of and response to emergencies due to food and allergic reactions; Recordkeeping; Transportation and child passenger safety; Release of children; Respectful engagement of families; Preventing, recognizing, and reporting child abuse and neglect; including information about the signs and symptoms of sexual abuse, sexual violence, grooming processes, recognizing the dangers of child sexual abuse, and other predatory behaviors of sex offenders; Recognition of and response to the symptoms of common childhood illnesses; Preventing the spread of infectious disease; Providing developmentally appropriate activities and experiences for children; Inclusion of children with special needs; Guidelines for volunteers, partner staff, auxiliary staff, and business managers; Responsibility to comply with current applicable licensing regulations; Staffing requirements to include opening and closing; and Ensuring children have extra clothes and diapers available.

It was identified that six (6) staff who have been employed for more than 30 days, have not completed an approved orientation training. Three (3) of the six (6) staff have not completed an approved mandated reporter training.

Open Not marked corrected in the state record

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7.1.2.2 · Staff who are counted in the staff/child ratios and auxiliary staff left alone with children and/or counted in staff/child ratio as specified in the rule 6.2.1.8 of these regulations shall obtain training in pediatric first aid and in infant and child CPR within three (3) months of beginning work in the CBCCPP and remain currently certified.

Three (3) staff who have been employed for more than three (3) months, have not completed pediatric first aid and CPR certification as required.

Open Not marked corrected in the state record

Open / not marked corrected.

5.4.1.8 · Bedding used by a child shall be stored in a manner that prevents contact with bedding used by other children.

Bedding used by children in both preschool classrooms are stored in the bottom portion of the cubbies. The bedding is not contained in bags or storage containers so that one child's bedding can touch another child's bedding.

Open Not marked corrected in the state record

Open / not marked corrected.

3.4.7.3 · Within six (6) months of the initial date of employment; staff and auxiliary staff left alone with children and/or counted in staff/child ratio as specified in the rule 6.2.1.8 of these regulations, and the program director shall maintain an up-to-date BFIS Quality and Credential Account. Documentation, verification of qualifications, and all annual professional development activities as specified in the rules in sections 7.3 and 7.4 of these regulations shall be submitted to Northern Lights at CCV to be verified and maintained in BFIS.

After a review of BFIS Quality and Credential accounts and discussion with the program director, it was determined that nine (9) staff employed longer than six (6) months did not have up to date BFIS Quality and Credential Accounts as required. This is a repeat violation previously cited on 9/28/20.

Open Not marked corrected in the state record

Open / not marked corrected.

3.4.7.3 · Within six (6) months of the initial date of employment; staff and auxiliary staff left alone with children and/or counted in staff/child ratio as specified in the rule 6.2.1.8 of these regulations, and the program director shall maintain an up-to-date BFIS Quality and Credential Account. Documentation, verification of qualifications, and all annual professional development activities as specified in the rules in sections 7.3 and 7.4 of these regulations shall be submitted to Northern Lights at CCV to be verified and maintained in BFIS.

After a review of staff Quality and Credential accounts and onsite files, it was determined that 7 staff at the program did not have up to date Quality and Credential accounts as required. This is a violation because one or more documents may have been missing from staff Quality and Credential accounts that includes but is not limited to: qualification documentation, proof of required trainings such as Orientation, Emergency Response Plan Training, or Mandated Reporter training and annual professional development. This is a violation because all items related to qualifications, required trainings, and annual professional development is required to be kept up to date in each staff member's BFIS account.

Open Not marked corrected in the state record

Open / not marked corrected.