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 BFIS accounts reflected that the Director and Staff B had not yet submitted documentation of current pediatric first aid and infant and child CPR certifications to Northern Lights at CCV. Staff E confirmed that the program did not have said documentation. Both staff listed have been employed by the program for at least 6 months.

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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 accounts reflected that the Director, Staff B and Staff D had not yet submitted documentation of completion of the required mandated reporter training, "Protecting Vermont's Children: Reporting Abuse and Neglect" to Northern Lights at CCV with cover sheets. Two staff listed are in positions which lend themselves to being left alone with children and/or counted in ratio and all staff listed have been with the program for more than 6 months. Staff E confirmed that the program did not have said documentation and that there has been ongoing confusion about whether or not the district offered mandated reporter training met this requirement.

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5.10.3.3 · Safe Use Zones For all play equipment that is thirty (30) inches or higher from the ground, including climbing equipment, slides, swings and other similar equipment, the licensee shall ensure that the surface under and around the equipment, including recommended use zones, is of approved resilient material that protects children if they fall. * Materials in the use zone shall consist of wood chips, pea stone, mulch, engineered wood fibers, sand, safety-tested shredded or rubber like material or rubber mats designed for protective cushioning; * Materials used in the use zone shall follow the recommendations listed in the most recent publication of U.S. Consumer Product Safety Commission's Public Playground Safety Handbook regarding critical depth of tested materials determined by the height of the highest climbing surface of the equipment; * Materials used in the use zone shall be installed and maintained according to the manufacturer's instructions; * If the loose material such as sand, mulch, or shredded rubber is used in use zones, the licensee shall ensure that the material is raked regularly and replenished to maintain depth and resilience; and * If the resilient material in use zones freezes, staff shall ensure that children will not play on the equipment until the resilient material has thawed and is once again resilient.

During the visit, the temperature was approximately 29 degrees F and there was snow and ice under and around all playground equipment. Staff B and Staff C stated that the children are allowed to utilize all playground equipment, including equipment which allows them to reach a height of 30 inches or higher, regardless of freezing temperatures and the condition of the cushioing materials.

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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 quality and credential accounts reflected that the Director, Staff A, Staff B and Staff C had not yet submitted documentation of completion of an approved orientation training. Staff E confirmed that the program did not have documentation of completed approved orientation trainings for the staff listed and that there has been ongoing confusion about whether the district offered orientation training would meet this requirement. All staff listed are in positions which lend themselves to being left alone with children and/or counted in ratio.

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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 staff BFIS quality and credential accounts reflects that documentation of staff qualifications, required trainings, professional development and CPR and first aid certifications has not been submitted as required. As a result, the following could not be assessed: 1. Qualifications for the Director, Staff A, Staff B and Staff H, 2. Orientation training for Staff F, 3. Mandated Reporter training for Staff G, CPR and first aid certifications for Staff A and Staff C. All listed staff have been employed by the program for at least 6 months.

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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 staff list reflected that 8 listed staff are no longer employed by the program. Staff E confirmed that all 8 staff have not worked for the program for more than 5 days, at least three have not worked for the program since the beginning of the school year which means at least 5 months. Additionally, Staff E confirmed that 3 current staff members were not listed under the proper position title.

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6.2.6.6 · The program director shall ensure that no person be left alone with children without approval from the Division based on the results of a background check that includes fingerprinting; with the exception of a parent may be left alone with his/her own child(ren).

Staff Z has been regularly present in the classroom and worked in a capacity as a one on one with a child. Staff Z was observed exiting the classroom with the child and being gone for more than 10 minutes. Staff Z was not listed on the associated parties list and therefore has not had a background check through the Child Development Division.

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