meredith Berger Fri, 07/8/16 - 8:27 Regarding the requirements for the Educational Director notification, this is redundant for programs that are also 4410/Approved Private School Programs. APS/4410 programs are already burdened by overlapping regulations and requirements from NYS and multiple departments in NYC. I would request an exemption for programs that are already required to have appropriate staffing in place through another state or city agency.

meredith Berger Fri, 07/8/16 - 8:30 re: Teacher and trainer qualification verification For programs that are 4410/Approved Private Schools, this requirement is redundant based on the NYSED/Commissioner's Regulations that already impose requirements for appropriate certification for the positions discussed. For APS/4410 programs, consider issuing a waiver to reduce the burden and redundancy of overlapping regulations to our programs.

meredith Berger Fri, 07/8/16 - 8:35 Individuals who work or volunteer in or are in control of any child care service must be fingerprinted in accordance with Health Code §47.19. Currently, Approved Private Schools/4410 programs, which are approved by NYSED to provide special education services have the financial and time burden of having new employees fingerprinted by at least two authorities-DOI and NYC DOE. This occurs because the two agencies do not communicate findings not accept each other's results. This creates an undue burden on small programs. Please consider ways to address this to reduce the burden while maintaining student safety.

Randi Levine Tue, 07/26/16 - 11:48 Please see the attached comments from Advocates for Children of New York in support of the proposed addition of subdivision (j) to section 47.19 of the New York City Health Code. This amendment would require child care providers to permit Early Intervention and preschool special education providers to conduct assessments and provide services to children at the children’s child care centers without providing proof of their fingerprinting, State Central Register (SCR) clearances, or employment references to the child care providers. Early Intervention providers and preschool special education providers have already been cleared to provide assessments and services to children. Citing current rules, some child care centers have prohibited such providers from working with children until they produce another set of documents, causing substantial delays in providing children who have developmental delays and disabilities with the assessments and services they need and to which they are entitled under federal law. The attached document has additional information. Thank you.

Mary DeBey Wed, 07/27/16 - 10:33 July 27, 2016 New York City Department of Health and Mental Hygiene Gotham Center 42-09 28th Street, CN 31 New York State Department of Health Long Island City, NY Re: Department of Health’s proposed amendments to Article 47 (Child Care Services) This is a statement in support of Article 47, the amendment requring early childhood special educators/early interventionists and therapists across disciplines to deliver EI or CPSE services to infants, toddlers and young children with disabilities in child care settings as determined on their Individualized Family Service Plan (IFSP) or Individualized Education Plan (IEP). I am an associate professor of Early Childhood Education at Brooklyn College and have taught, directed and consulted in early childhood centers and now observe College students at centers weekly. There is a desperate need for qualified teachers in early childhood centers throughout New York City to provide high quality developmentally appropriate educational services for all children including those with disabilities. Given this shortage it is imperative that EI/CPSE therapists and teachers working directly with infants and young children with disabilities in childcare settings be exempt from needing additional SCR clearance, fingerprinting, and employment references and requirements, since these requirements are already required of them to qualify as EIP and/or CPSE providers and would only slow down their ability to provide approved services to infants and young children with developmental disabilities. It is DOHMH’s responsibility to ensure that all NYC child care providers allow children with special needs to receive services in the least restrictive or natural environment. The inclusion of infants, toddlers and young children with disabilities into educational settings with typically developing young children and therapists who embed their interventions into children’s daily routines supports the overall development and wellbeing of children with special needs. This amendment will assist in meeting this goal more quickly. Please feel free to contact me with any questions regarding my comments in support of the Department of Health’s proposed amendments to Article 47 (Child Care Services) Sincerely, Mary DeBey, Ph.D. Department of Early Childhood Education and Art Education School of Education Brooklyn College, The City University of New York(CUNY) 2900 Bedford Ave. Brooklyn, NY 11210 718-951-5205 1

Louisa Higgins Wed, 07/27/16 - 17:01 The New York Early Childhood Professional Development Institute is in full support of the proposed Amendments to Article 47 of the New York City Health Code, specifically the changes related to sections 47.13, 47.15, 47.17 and 47.37 that would require child care programs to submit teachers’ and trainers’ documentation for review to a qualified agency. It is our belief that outsourcing the verification of educational information for education directors and teachers will lead to increased program compliance and will allow DOHMH field staff to focus their efforts on increasing program quality. Currently, education verification happens on-site and is not tracked in a data system. There are lead teachers on study plans to achieve certification who have seven years to meet the education requirement. However, a teacher can move from one program to another and there is no mechanism to track this movement. In addition to education and certification, high-quality professional development is an integral component of program quality in early childhood settings. Providers of professional development should be qualified to offer training across the range of topics related to working with young children. We support the proposed amendment to have trainer documentation reviewed to determine if individuals have the education and professional experience to teach in particular subjects. An enhanced system for tracking teacher education and professional development supports the national movement towards creating career pathways for the early childhood workforce. Supporting career advancement and individualized professional growth can have a significant impact on the abilities of the workforce and overall program quality. The New York Early Childhood Professional Development Institute is confident that the proposed changes to Article 47 would move the DOHMH forward in their goal to provide high quality services to New York City’s youngest children.