7.3.1.3 · The program director of a CBCCPP licensed to serve thirteen (13) - fifty-nine (59) children shall be qualified as a teacher associate, and shall have completed either: * A Vermont Early Childhood and Afterschool Program Director Step One (1) Certificate; or * Successful completion of a three (3) college credit course in program management for early care and education or for school age care and education, or in staff supervision related to early care and education of children; and a three (3) college credit course in curriculum.

The program director who has been employed since 11/22/2024, has not completed a three (3) college credit course in program management for early care and education or for school age care and education, or in staff supervision related to early care and education of children which is needed to meet qualification for program director for 13-59 children.

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7.3.2.3 · Teacher Assistant A teacher assistant is at least eighteen (18) years of age, is a high school graduate or has completed a GED, and meets one (1) of the following qualifications: * At least a Vermont Early Childhood Career Ladder Level One (1) or Two (2) Certificate; or * At least a current CDA (Child Development Associate) and at least twelve (12) months experience working with groups of children from grade three (3) or younger; or * At least a State Board of Education approved Human Services Program Certificate that emphasizes child development or early childhood education and at least twelve (12) months experience working with groups of children from grade three (3) or younger; or * At least successful completion of the Fundamentals for Early Childhood Professionals' course or the Vermont Afterschool Essentials Certificate and at least twelve (12) months experience working with groups of children from grade three (3) or younger; or * At least successful completion of a three (3) college credit course in child or human development or a three (3) college credit course for school age care and education and at least twelve (12) months experience working with groups of children from grade three (3) or younger.

Four (4) assistants who have been employed since July and September of 2024, as assistants have not completed the Fundamentals for Early Childhood Professional course or a three (3) college course in Child or Human Development which is needed to meet regulation.

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7.5.4 · The program director shall establish and implement a system of communication among staff to ensure that any staff member assuming responsibility for a child or group is informed of significant information related to the care and education of the child or children.

During the site visit on 11/09/2022, Staff A, B and C confirmed that it has not been a typical practice for staff to exchange any information about the children in care when one staff member leaves and another steps in to care for the children. Staff A, B, and C confirmed that there was no communication between Staff D to Staff A and B when Staff D left and Staff A and B toook over. Staff B stated concerns about the ongoing lack of communication between staff during times of staff transition.

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7.5.4 · The program director shall establish and implement a system of communication among staff to ensure that any staff member assuming responsibility for a child or group is informed of significant information related to the care and education of the child or children.

School Principal, Jennifer Nordensen, Staff A, Staff B and Staff C stated that on 11/03/2022, Child A, who was of preshcool age, was left unattended inside the school for approximately 20 minutes while the remainder of the preschool children and preschool staff were on the playground. Additionally, the three staff stated that none of the staff present during the incident were aware of that Child A was in attendance on 11/03/2022. Child A was discovered by Staff B after the group returned to the classroom to have snack. While an attendance system was observed during the site visit on 11/09/2022, the three staff stated that it was not a normal practice for the afternoon staff to review or utilize the attendance system or any other tracking system or communication system to keep track of childrens' presence or whereabouts duirng the afternoon portion of the preschool program. Further, the three staff stated that while the school entrances/exits are locked during the school day, they are not typically locked during the afternoon/afterschool care portion of the day. The front entry door was not locked during the site visit on 11/09/2022. While Child A was reported to be sleeping throughout the 20 minute time period, had Child A exited the building, the child would have had ready access to a large parking lot and Route 100 and no staff present would have known that Child A was missing. While the program reported the incident, there were no immediate systems implemented to adjust attendance and communciation policies and practices during the six days between the date of the incident and the date of the site visit. This is a serious violation.

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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.

Documentation of current CPR certification for 1 staff member and documentation of First Aid certification was not provided for 6 staff members for individuals who have been staff for more than 3 months. This information was not in the staff's BFIS Quality and Credential accounts or in staff files at the time of this visit.

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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.

Upon review of staff quality and credential accounts in BFIS and on-site documentation, it was determined that six (6) staff who have been employed with the program 6+ months in a position that allows them to work with children had not completed the Orientation training.

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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 the BFIS Quality and Credential accounts of staff who have been with the program more that 6 months reflected that several staff accounts do not have the following required documentation; verification of qualifications, professional development, Orientation, Mandated Reporter training, and current first aid and CPR certification. The director confirmed that some of the documents had been submitted to Northern Lights, but not all. This is a repeat violation previously cited on 10/18/2019.

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5.1.2 · General Health Examinations: Within forty-five (45) days of enrollment, the licensee shall obtain documentation of the child's age appropriate well care exam from the parent. Documentation shall include information regarding any health conditions and medications that may impact the care of the child.

A review of 5 randomly selected files for children who have been enrolled more than 45 days showed that they did not include documentation of a General Health Exam signed by a pediatrician. Staff confirmed that the program has not been requesting this documentation.

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3.4.7.3 · Within six (6) months of the initial date of employment, staff working with children 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 NLCDC to be verified and maintained in BFIS.

A review of the BFIS Quality and Credential accounts of staff who have been with the program more that 6 months reflected that several staff accounts do not have the following required documentation; verification of qualifications, annual professional development, and current first aid and CPR certification.

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