Warren Scharf Thu, 12/7/17 - 13:40 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.

Michelle Mascioli Fri, 12/15/17 - 21:00 DOHMH should have stricter guidelines with daycare facilities and especially monitor the facilities that are funded by the city and don't have a big budget. Most importantly, the children should be exposed to fresh air and be outside for some portion of the day. There should also be windows in every room the children are in so they are exposed to daylight. There should be regulations regarding the administration in charge of the facility as well. There must be a person in charge that has an advanced degree in Education, Psychology, Nutrition and/or some Medical/Health degree, either a Masters or PhD that has final say and is on site throughout the week. Although some schools cut costs by hiring less educated and specialized teachers and day care workers, the schools can still be effective if there is someone in charge and advising the staff on day to day operations and tailoring the curriculum based on their experience. There should be fresh, healthy meals prepared for the children for both breakfast and lunch. There must be a kitchen facility in each daycare with the ability to provide these meals that is inspected by the city. Food served may not be frozen or contain chemicals and preservatives. The older children in the daycare may benefit from spending time in the kitchen and learning about different aspects of preparing and serving healthy meals. The attached document is a letter I wrote about the daycare facility my son was attending years ago, against my wishes, but enrolled by his father (without my knowledge) and then upheld by a court order in family court. This also touches upon the issue of daycare and schools becoming more sensitive to children having parents that live in two separate homes and can not or do not communicate with one another but are still involved in the children's lives. School administration should do everything possible to include both parents, foster healthy relationships and even provide support or help parents who are facing issues or difficulties in this area. Thank you. MiCHELLE MASCiOLi CHIEF OPERATING OFFICER MASCiOLi HOLDINGS INC. 401 WEST 25TH ST, APT 15i NEW YORK, NEW YORK 10001 (646) 761-3645 .

Anna Accardi Sat, 12/16/17 - 22:52 As directors and educators our number one job is the safety of our children. I am unaware if whomever proposed this rule has had any actual hands on experience in a childcare facility. I’m very concerned that this department is treating us as if we are a pub, bar or restaurant. It is quite the opposite, for example we now have to take a day away from making sure our centers are being ran properly to pay or dispute a ticket for a minor violation at OATH, because we no longer receive time to make any corrections. Operating a daycare is a constant obligation, whom many, if not all of us, take pride in. I am completely opposed to this new rule for many reasons. As it is, staying in compliance is already very difficult for us. We are rarely notified, in advance, of new rules and regulations. In fact, recently, I had to deal with an inspector who had his own agenda and rules that are clearly not in article 47. In turn, when we need clarity regarding new regulations or when we have general questions to help ensure proper operations it is very difficult for us to get that assistance from the department. I want nothing more than to be in compliance at all times, yet I am treated as if I am operating a bar and not a childcare facility. I offer my community a due diligence by running a safe, warm and loving environment for their children. Though, I am now to be penalized even more by having my program graded upon. We are not serving burgers, we are looking over peoples most precious gifts, their children. I should be able to contact someone from the DOHMH immediately to help me with a problem or issue. This rule only adds more stress for our programs when our main goal is to make sure our children are our number priority. Please stop treating us as bar owners and help us. Especially for the sake of the children, we must have more open lines of communication. PLEASE HELP US.

Leslie Velazquez Mon, 12/18/17 - 15:07 As a life-long resident of New York City, I would like to assert my right to comment on the proposed amendment to Title 24 of the Rules of the City of New York, with a new Chapter 3. I am in favor of the proposed summary card and penalties for Child Care programs. I, myself am a two-time parent and know first-hand the difficulties many parents face when selecting child care. The children of New York City are amongst the most vulnerable within our population. Those under the age of six cannot advocate for themselves. It is a parent/guardian responsibility to conduct a diligent search of locating a safe and secure program to care for their child/ren. Which can often be proven difficult. Many a times, parent(s) rely on word of mouth when selecting a program. It is because of this, a summary card of the front entrances of child care programs would be successful. However, I recommend changes to §3-03 (c)(6) the average number of public health hazard violations per inspection at the site adjudicated in the previous year. And, §3-03 (c)(7) the average number of violations the Health Code or rules of the Department other than public health hazard violations, at the site adjudicated in the previous year. At no point, should the City of New York, provide parent/s with an average number of violations at a child care site. The real number of mediated violations ought to be provided on the Performance Card. Parent/s can then make a sound decision when comparing the site’s number to the Citywide average, that is also provided on the Performance Card. Child care programs are growing in number under Mayor DeBlasio. The recent expansion of pre-kindergarten programs for children 3 and 4-years of age, creates a need for performance cards. Similar to K-12 school evaluations, it is only right that parents are provided performance cards from the first phases of their child education.