Public comments for: Performance Summary Cards and Penalties for Child Care Programs Rule (New Chapter 3 in Title 24 of the RCNY)

Comments

Comment:
I am submitting a comment to Performance Summary Cards and Penalties for Child Care Programs Rule (24 RCNY Chapter 3): Proposed Section 3-04(a) Posting. Proposed Section 3-04(a) states: (a) Upon receipt of a performance summary card, a child care program shall post it in a conspicuous location within two feet of the front door or other main entrance to the site, between four and six feet above the ground or floor. The performance summary card shall not be defaced, marred, camouflaged, or hidden from public view, or posted in a manner that permits it to be damaged by exposure to weather. This language is too proscriptive and not necessarily achievable given the layout of building and program entrances. I would suggest the following type of language be substituted, similar to that found in New York State Department of Labor requirements for required workplace postings: (a) Upon receipt of a performance summary card, a child care program shall conspicuously post it on the program site in a location where the public can see and access it.
Agency: DOHMH
Comment:
The following are my comments regarding this proposal: 1. Who, what agencies or depts, will be giving the grade? 2. What criteria will be used? 3. How will it be communicated? 4. To whom will it be be communicated? 5. How often will the grade be evaluated? 6. How can a grade be upgraded? My biggest concern is that we are treating child care centers like restaurants. Unless the entire NYC public system adopts such a regulation (which I am certain they will NOT) then the notion of relegating day care and child care centers to receive a letter grade diminishes the multi-faceted purpose and services that we provide. There are already an enormous number of checks and balances and agency reviews for day cares. A letter grade moves closer to what we aim to eliminate - which is a competitive environment. We need to build collaboration and remove the stigma of yet another evaluation that ultimately will be subjective.
Agency: DOHMH