Child Care and Child Supervision Programs

Online comments: 28

• Renata Flider

  • Accept foreign experience: Recognize documented early childhood teaching experience from
  licensed childcare centers abroad.
  • Broaden accepted fields: Expand eligible fields of study/experience for preschool teachers
  (ages 3+) to include Child Development, Psychology, Elementary Education, Social Work, Art
  Education, Music Education, Physical Education, Speech and Language Pathology,
  Occupational Therapy, Human Services, Nursing (pediatric/early childhood), Montessori
  Certification, and Teacher of Languages (Linguistics).
  • Preserve staffing equity: Ensure childcare centers without Universal 3K are not disadvantaged
  by DOE-level requirements that make it difficult to compete for teachers.
  • Revise experience requirement: Allow teachers with 3 years of verified teaching experience
  (instead of 5) to qualify as lead preschool teachers.
  Clarifications Needed
  • Age transitions: Can children remain with the same teacher until 3 years 11 months (3.11), or
  must they change classrooms immediately upon turning three?
  • CDA requirements: If a teacher holds a CDA, is a study plan still required? If so, what is the
  completion timeline, and can short breaks in enrollment be permitted? Must teachers prove
  enrollment or a plan to enroll within a set timeframe?
  • Experience-based qualifications: Will a teacher with only a high school diploma but 3+ years of
  verified experience qualify as a preschool group teacher under the new rules?
  We urge DOH to provide clarity, expand eligibility, and allow broader recognition of professional and
  international experience so that all schools can continue to deliver high-quality early childhood
  education.

  Comment attachment
  DOH_Teacher_Qualifications_Advocacy-3.pdf

  Comment added August 21, 2025 2:28pm

• Hayley Feliciano

  Interest

  Comment added August 21, 2025 2:43pm

• Renata Flider

  We respectfully submit the following recommendations and requests for clarification regarding teacher qualifications under the amended Article 47. These changes, if applied without flexibility, could have significant impacts on non-3K childcare centers’ ability to recruit and retain staff.
  Key Recommendations

  Accept foreign experience: Recognize documented early childhood teaching experience from licensed childcare centers abroad.
  Broaden accepted fields: Expand eligible fields of study/experience for preschool teachers (ages 3+) to include child development, psychology, social work, nursing (pediatric), occupational therapy, speech and language pathology, human services, and elementary education, social work, Art Education, Music Education, Physical Education, Montessori Certification, Teacher of languages ( linguist)
  Preserve staffing equity: Ensure childcare centers without Universal 3K are not disadvantaged by DOE-level requirements that make it difficult to compete for teachers.
  Revise experience requirement: Allow teachers with 3 years of verified teaching experience (instead of 5) to qualify as lead preschool teachers. Many assistants thrive and grow into excellent leads within this timeframe, and a degree itself is not equivalent to three years of training.
  Clarifications Needed
  •
  •
  •
  Age transitions: Can children remain with the same teacher until 3 years 11 months (3.11), or must they change classrooms immediately upon turning three?
  CDA requirements: If a teacher holds a CDA, is a study plan still required? If so, what is the completion timeline, and can short breaks in enrollment be permitted? Does a teacher need to prove they are enrollled in school or have a plan to enroll in school within a certain time window.
  Experience-based qualifications: Will a teacher with only a high school diploma but 3+ years of verified experience (supported by references and resume) qualify to serve as a preschool group teacher under the new rules?
  Without clear guidance and flexibility, the new requirements may unintentionally create inequities between DOE 3K programs and private childcare centers. We urge DOH to provide clarity, expand eligibility, and allow broader recognition of professional and international experience so that all schools can continue to deliver high-quality early childhood education.
  Detailed Advocacy Points Acceptance of Foreign Experience
  • Accept documented foreign daycare/early childhood teaching experience toward teacher qualifications.

  • Many strong candidates come with years of licensed teaching abroad; this should be recognized.
  Expanded Acceptable Fields of Study/Experience (Ages 3+)
  • • • • • • • •
  Child Development
  Psychology (child-focused)
  Elementary Education
  Art Education
  Music Education
  Physical Education
  Social Work (child/family-focused)
  Speech and Language Pathology (early childhood focus)
  Occupational Therapy (pediatric focus)
  Human Services (child/family-focused)
  Nursing (pediatric/early childhood background)
  Equity Between DOE and Non-DOE Centers
  Montessori Credential (AMS / AMI)
  • •
  • •
  Not all schools have Universal 3K.
  If DOH requires childcare centers to meet the same qualifications as DOE/3K programs, staffing will become nearly impossible because:
  – Teachers will prefer DOE jobs (shorter hours, summers off, DOE benefits).
  – Childcare centers without 3K will struggle to attract and retain teachers.
  Clarification Needed on New Requirements
  •
  •
  •
  Age transitions: Can children remain with the same teacher until 3 years 11 months (3.11), or must they change classrooms immediately upon turning three?
  CDA requirements: If a teacher holds a CDA, is a study plan still required? If so, what is the completion timeline, and can short breaks in enrollment be permitted?
  Experience-based qualifications: Will a teacher with only a high school diploma but 3+ years of verified experience (supported by references and resume) qualify to serve as a preschool group teacher under the new rules?
  Key Requests
  • • •
  • •
  Accept foreign daycare teaching experience.
  Broaden eligible fields of study/experience for preschool teachers.
  Revise experience requirement from 5 years to 3 years to allow qualified assistants to move into lead teacher roles sooner.
  Provide flexibility for non-3K centers so they can remain competitive in hiring.
  Clarify CDA requirements, age transition rules, and experience-based qualifications

  Comment attachment
  Five-Stars-DOH-Comments-on-Article-47.docx

  Comment added August 21, 2025 3:46pm

• Kamilia Duisheeva

  We respectfully submit the following recommendations and requests for clarification regarding teacher qualifications under the amended Article 47. These changes, if applied without flexibility, could have significant impacts on non-3K childcare centers’ ability to recruit and retain staff.
  Key Recommendations

  Accept foreign experience: Recognize documented early childhood teaching experience from licensed childcare centers abroad.
  Broaden accepted fields: Expand eligible fields of study/experience for preschool teachers (ages 3+) to include child development, psychology, social work, nursing (pediatric), occupational therapy, speech and language pathology, human services, and elementary education, social work, Art Education, Music Education, Physical Education, Montessori Certification, Teacher of languages ( linguist)
  Preserve staffing equity: Ensure childcare centers without Universal 3K are not disadvantaged by DOE-level requirements that make it difficult to compete for teachers.
  Revise experience requirement: Allow teachers with 3 years of verified teaching experience (instead of 5) to qualify as lead preschool teachers. Many assistants thrive and grow into excellent leads within this timeframe, and a degree itself is not equivalent to three years of training.
  Clarifications Needed

  Age transitions: Can children remain with the same teacher until 3 years 11 months (3.11), or must they change classrooms immediately upon turning three?
  CDA requirements: If a teacher holds a CDA, is a study plan still required? If so, what is the completion timeline, and can short breaks in enrollment be permitted? Does a teacher need to prove they are enrollled in school or have a plan to enroll in school within a certain time window.
  Experience-based qualifications: Will a teacher with only a high school diploma but 3+ years of verified experience (supported by references and resume) qualify to serve as a preschool group teacher under the new rules?
  Without clear guidance and flexibility, the new requirements may unintentionally create inequities between DOE 3K programs and private childcare centers. We urge DOH to provide clarity, expand eligibility, and allow broader recognition of professional and international experience so that all schools can continue to deliver high-quality early childhood education.
  Detailed Advocacy Points Acceptance of Foreign Experience
  • Accept documented foreign daycare/early childhood teaching experience toward teacher qualifications.

  • Many strong candidates come with years of licensed teaching abroad; this should be recognized.
  Expanded Acceptable Fields of Study/Experience (Ages 3+)

  Child Development
  Psychology (child-focused)
  Elementary Education
  Art Education
  Music Education
  Physical Education
  Social Work (child/family-focused)
  Speech and Language Pathology (early childhood focus)
  Occupational Therapy (pediatric focus)
  Human Services (child/family-focused)
  Nursing (pediatric/early childhood background)
  Equity Between DOE and Non-DOE Centers
  Montessori Credential (AMS / AMI)

  Not all schools have Universal 3K.
  If DOH requires childcare centers to meet the same qualifications as DOE/3K programs, staffing will become nearly impossible because:
  – Teachers will prefer DOE jobs (shorter hours, summers off, DOE benefits).
  – Childcare centers without 3K will struggle to attract and retain teachers.
  Clarification Needed on New Requirements
  Age transitions: Can children remain with the same teacher until 3 years 11 months (3.11), or must they change classrooms immediately upon turning three?
  CDA requirements: If a teacher holds a CDA, is a study plan still required? If so, what is the completion timeline, and can short breaks in enrollment be permitted?
  Experience-based qualifications: Will a teacher with only a high school diploma but 3+ years of verified experience (supported by references and resume) qualify to serve as a preschool group teacher under the new rules?
  Key Requests
  Accept foreign daycare teaching experience.
  Broaden eligible fields of study/experience for preschool teachers.
  Revise experience requirement from 5 years to 3 years to allow qualified assistants to move into lead teacher roles sooner.
  Provide flexibility for non-3K centers so they can remain competitive in hiring.
  Clarify CDA requirements, age transition rules, and experience-based qualifications

  Comment attachment
  DOH_Teacher_Qualifications_Advocacy-3-1.pdf

  Comment added August 21, 2025 4:16pm

• Chloe Pashman

  Re: Amended Article 47 – Impact on Childcare Centers:
  We respectfully submit the following recommendations and requests for clarification regarding teacher qualifications under the amended Article 47. These changes, if applied without flexibility, could have significant impacts on non-3K childcare centers’ ability to recruit and retain staff, and to be able to remain open serving some of the most vulnerable children and families in the city.

  Key Recommendations:
  -Accept foreign experience
  -Recognize documented early childhood teaching experience from licensed childcare centers abroad.
  Broaden accepted fields: Expand eligible fields of study/experience for preschool teachers (ages 3+) to include child development, psychology, social work, nursing (pediatric), occupational therapy, speech and language pathology, human services, and elementary education, social work, Art Education, Music Education, Physical Education, Montessori Certification, Teacher of languages ( linguist)
  Preserve staffing equity: Ensure childcare centers without Universal 3K are not disadvantaged by DOE-level requirements that make it difficult to compete for teachers.
  Revise experience requirement: Allow teachers with 3 years of verified teaching experience (instead of 5) to qualify as lead preschool teachers. Many assistants thrive and grow into excellent leads within this timeframe, and a degree itself is not equivalent to three years of training.

  Clarifications Needed:
  Age transitions: Can children remain with the same teacher until 3 years 11 months (3.11), or must they change classrooms immediately upon turning three?
  CDA requirements: If a teacher holds a CDA, is a study plan still required? If so, what is the completion timeline, and can short breaks in enrollment be permitted? Does a teacher need to prove they are enrollled in school or have a plan to enroll in school within a certain time window.
  Experience-based qualifications: Will a teacher with only a high school diploma but 3+ years of verified experience (supported by references and resume) qualify to serve as a preschool group teacher under the new rules?
  Without clear guidance and flexibility, the new requirements may unintentionally create inequities between DOE 3K programs and private childcare centers. We urge DOH to provide clarity, expand eligibility, and allow broader recognition of professional and international experience so that all schools can continue to deliver high-quality early childhood education.
  Detailed Advocacy Points Acceptance of Foreign Experience
  • Accept documented foreign daycare/early childhood teaching experience toward teacher qualifications.
  • Many strong candidates come with years of licensed teaching abroad; this should be recognized.
  Expanded Acceptable Fields of Study/Experience (Ages 3+)
  • • • • • • • •
  Child Development
  Psychology (child-focused)
  Elementary Education
  Art Education
  Music Education
  Physical Education
  Social Work (child/family-focused)
  Speech and Language Pathology (early childhood focus)
  Occupational Therapy (pediatric focus)
  Human Services (child/family-focused)
  Nursing (pediatric/early childhood background)
  ***Equity Between DOE and Non-DOE Centers***
  Montessori Credential (AMS / AMI)

  Not all schools have Universal 3K.
  If DOH requires childcare centers to meet the same qualifications as DOE/3K programs, staffing will become nearly impossible because:
  – Teachers will prefer DOE jobs (shorter hours, MUCH higher pay, summers off, DOE benefits etc.).
  – Childcare centers without 3K will struggle to attract and retain teachers.
  Clarification Needed on New Requirements:
  Age transitions: Can children remain with the same teacher until 3 years 11 months (3.11), or must they change classrooms immediately upon turning three?
  CDA requirements: If a teacher holds a CDA, is a study plan still required? If so, what is the completion timeline, and can short breaks in enrollment be permitted?
  Experience-based qualifications: Will a teacher with only a high school diploma but 3+ years of verified experience (supported by references and resume) qualify to serve as a preschool group teacher under the new rules?
  Key Requests:
  -Accept foreign daycare teaching experience.
  -Broaden eligible fields of study/experience for preschool teachers.
  -Revise experience requirement from 5 years to 3 years to allow qualified assistants to move into lead teacher roles sooner.
  -Provide flexibility for non-3K centers so they can remain competitive in hiring.
  -Clarify CDA requirements, age transition rules, and experience-based qualifications.
  ***Please note that PAY PARITY MUST finally be established between CBO/NYCEEC/DOE contracted centers and 3Ks/PreKs that are DOE standalone/located in DOE buildings, or the DOHMH licensed child care centers will soon cease to exist and be unable to continue operating!***
  Thank you!

  Comment added August 22, 2025 8:08am

• Marina Shishkin

  Re: Amended Article 47 – Impact on Childcare Centers
  We respectfully submit the following recommendations and requests for clarification regarding teacher qualifications under the amended Article 47. These changes, if applied without flexibility, could have significant impacts on non-3K childcare centers’ ability to recruit and retain staff.
  Key Recommendations

  Accept foreign experience: Recognize documented early childhood teaching experience from licensed childcare centers abroad.
  Broaden accepted fields: Expand eligible fields of study/experience for preschool teachers (ages 3+) to include child development, psychology, social work, nursing (pediatric), occupational therapy, speech and language pathology, human services, and elementary education, social work, Art Education, Music Education, Physical Education, Montessori Certification, Teacher of languages ( linguist)
  Preserve staffing equity: Ensure childcare centers without Universal 3K are not disadvantaged by DOE-level requirements that make it difficult to compete for teachers.
  Revise experience requirement: Allow teachers with 3 years of verified teaching experience (instead of 5) to qualify as lead preschool teachers. Many assistants thrive and grow into excellent leads within this timeframe, and a degree itself is not equivalent to three years of training.
  Clarifications Needed
  •
  •
  •
  Age transitions: Can children remain with the same teacher until 3 years 11 months (3.11), or must they change classrooms immediately upon turning three?
  CDA requirements: If a teacher holds a CDA, is a study plan still required? If so, what is the completion timeline, and can short breaks in enrollment be permitted? Does a teacher need to prove they are enrollled in school or have a plan to enroll in school within a certain time window.
  Experience-based qualifications: Will a teacher with only a high school diploma but 3+ years of verified experience (supported by references and resume) qualify to serve as a preschool group teacher under the new rules?
  Without clear guidance and flexibility, the new requirements may unintentionally create inequities between DOE 3K programs and private childcare centers. We urge DOH to provide clarity, expand eligibility, and allow broader recognition of professional and international experience so that all schools can continue to deliver high-quality early childhood education.
  Detailed Advocacy Points Acceptance of Foreign Experience
  • Accept documented foreign daycare/early childhood teaching experience toward teacher qualifications.

  • Many strong candidates come with years of licensed teaching abroad; this should be recognized.
  Expanded Acceptable Fields of Study/Experience (Ages 3+)
  • • • • • • • •
  Child Development
  Psychology (child-focused)
  Elementary Education
  Art Education
  Music Education
  Physical Education
  Social Work (child/family-focused)
  Speech and Language Pathology (early childhood focus)
  Occupational Therapy (pediatric focus)
  Human Services (child/family-focused)
  Nursing (pediatric/early childhood background)
  Equity Between DOE and Non-DOE Centers
  Montessori Credential (AMS / AMI)
  • •
  • •
  Not all schools have Universal 3K.
  If DOH requires childcare centers to meet the same qualifications as DOE/3K programs, staffing will become nearly impossible because:
  – Teachers will prefer DOE jobs (shorter hours, summers off, DOE benefits).
  – Childcare centers without 3K will struggle to attract and retain teachers.
  Clarification Needed on New Requirements
  •
  •
  •
  Age transitions: Can children remain with the same teacher until 3 years 11 months (3.11), or must they change classrooms immediately upon turning three?
  CDA requirements: If a teacher holds a CDA, is a study plan still required? If so, what is the completion timeline, and can short breaks in enrollment be permitted?
  Experience-based qualifications: Will a teacher with only a high school diploma but 3+ years of verified experience (supported by references and resume) qualify to serve as a preschool group teacher under the new rules?
  Key Requests
  • • •
  • •
  Accept foreign daycare teaching experience.
  Broaden eligible fields of study/experience for preschool teachers.
  Revise experience requirement from 5 years to 3 years to allow qualified assistants to move into lead teacher roles sooner.
  Provide flexibility for non-3K centers so they can remain competitive in hiring.
  Clarify CDA requirements, age transition rules, and experience-based qualifications

  Comment added August 22, 2025 9:09am

• Yuliya Grinberg

  Re: Amended Article 47 – Impact on Childcare Centers
  We respectfully submit the following recommendations and requests for clarification regarding teacher qualifications under the amended Article 47. These changes, if applied without flexibility, could have significant impacts on non-3K childcare centers’ ability to recruit and retain staff.
  Key Recommendations

  Accept foreign experience: Recognize documented early childhood teaching experience from licensed childcare centers abroad.
  Broaden accepted fields: Expand eligible fields of study/experience for preschool teachers (ages 3+) to include child development, psychology, social work, nursing (pediatric), occupational therapy, speech and language pathology, human services, and elementary education, social work, Art Education, Music Education, Physical Education, Montessori Certification, Teacher of languages ( linguist)
  Preserve staffing equity: Ensure childcare centers without Universal 3K are not disadvantaged by DOE-level requirements that make it difficult to compete for teachers.
  Revise experience requirement: Allow teachers with 3 years of verified teaching experience (instead of 5) to qualify as lead preschool teachers. Many assistants thrive and grow into excellent leads within this timeframe, and a degree itself is not equivalent to three years of training.
  Clarifications Needed
  •
  •
  •
  Age transitions: Can children remain with the same teacher until 3 years 11 months (3.11), or must they change classrooms immediately upon turning three?
  CDA requirements: If a teacher holds a CDA, is a study plan still required? If so, what is the completion timeline, and can short breaks in enrollment be permitted? Does a teacher need to prove they are enrollled in school or have a plan to enroll in school within a certain time window.
  Experience-based qualifications: Will a teacher with only a high school diploma but 3+ years of verified experience (supported by references and resume) qualify to serve as a preschool group teacher under the new rules?
  Without clear guidance and flexibility, the new requirements may unintentionally create inequities between DOE 3K programs and private childcare centers. We urge DOH to provide clarity, expand eligibility, and allow broader recognition of professional and international experience so that all schools can continue to deliver high-quality early childhood education.
  Detailed Advocacy Points Acceptance of Foreign Experience
  • Accept documented foreign daycare/early childhood teaching experience toward teacher qualifications.

  • Many strong candidates come with years of licensed teaching abroad; this should be recognized.
  Expanded Acceptable Fields of Study/Experience (Ages 3+)
  • • • • • • • •
  Child Development
  Psychology (child-focused)
  Elementary Education
  Art Education
  Music Education
  Physical Education
  Social Work (child/family-focused)
  Speech and Language Pathology (early childhood focus)
  Occupational Therapy (pediatric focus)
  Human Services (child/family-focused)
  Nursing (pediatric/early childhood background)
  Equity Between DOE and Non-DOE Centers
  Montessori Credential (AMS / AMI)
  • •
  • •
  Not all schools have Universal 3K.
  If DOH requires childcare centers to meet the same qualifications as DOE/3K programs, staffing will become nearly impossible because:
  – Teachers will prefer DOE jobs (shorter hours, summers off, DOE benefits).
  – Childcare centers without 3K will struggle to attract and retain teachers.
  Clarification Needed on New Requirements
  •
  •
  •
  Age transitions: Can children remain with the same teacher until 3 years 11 months (3.11), or must they change classrooms immediately upon turning three?
  CDA requirements: If a teacher holds a CDA, is a study plan still required? If so, what is the completion timeline, and can short breaks in enrollment be permitted?
  Experience-based qualifications: Will a teacher with only a high school diploma but 3+ years of verified experience (supported by references and resume) qualify to serve as a preschool group teacher under the new rules?
  Key Requests
  • • •
  • •
  Accept foreign daycare teaching experience.
  Broaden eligible fields of study/experience for preschool teachers.
  Revise experience requirement from 5 years to 3 years to allow qualified assistants to move into lead teacher roles sooner.
  Provide flexibility for non-3K centers so they can remain competitive in hiring.
  Clarify CDA requirements, age transition rules, and experience-based qualifications

  Comment added August 22, 2025 1:33pm

• Nekea Whitson

  Thank you for the opportunity to comment on the updated staffing requirements that have been implemented as emergency rules. Attached are my comments.

  Thank you kindly.

  Comment attachment
  Staff_Flexibility_Comments.pdf

  Comment added August 22, 2025 2:08pm

• Lanny Cheuck

  Re: Amended Article 47 – Impact on Childcare Centers
  We respectfully submit the following recommendations and requests for clarification regarding teacher qualifications under the amended Article 47. These changes, if applied without flexibility, could have significant impacts on non-3K childcare centers’ ability to recruit and retain staff.
  Key Recommendations

  Accept foreign experience: Recognize documented early childhood teaching experience from licensed childcare centers abroad.
  Broaden accepted fields: Expand eligible fields of study/experience for preschool teachers (ages 3+) to include child development, psychology, social work, nursing (pediatric), occupational therapy, speech and language pathology, human services, and elementary education, social work, Art Education, Music Education, Physical Education, Montessori Certification, Teacher of languages ( linguist)
  Preserve staffing equity: Ensure childcare centers without Universal 3K are not disadvantaged by DOE-level requirements that make it difficult to compete for teachers.
  Revise experience requirement: Allow teachers with 3 years of verified teaching experience (instead of 5) to qualify as lead preschool teachers. Many assistants thrive and grow into excellent leads within this timeframe, and a degree itself is not equivalent to three years of training.
  Clarifications Needed
  •
  •
  •
  Age transitions: Can children remain with the same teacher until 3 years 11 months (3.11), or must they change classrooms immediately upon turning three?
  CDA requirements: If a teacher holds a CDA, is a study plan still required? If so, what is the completion timeline, and can short breaks in enrollment be permitted? Does a teacher need to prove they are enrollled in school or have a plan to enroll in school within a certain time window.
  Experience-based qualifications: Will a teacher with only a high school diploma but 3+ years of verified experience (supported by references and resume) qualify to serve as a preschool group teacher under the new rules?
  Without clear guidance and flexibility, the new requirements may unintentionally create inequities between DOE 3K programs and private childcare centers. We urge DOH to provide clarity, expand eligibility, and allow broader recognition of professional and international experience so that all schools can continue to deliver high-quality early childhood education.
  Detailed Advocacy Points Acceptance of Foreign Experience
  • Accept documented foreign daycare/early childhood teaching experience toward teacher qualifications.

  • Many strong candidates come with years of licensed teaching abroad; this should be recognized.
  Expanded Acceptable Fields of Study/Experience (Ages 3+)
  • • • • • • • •
  Child Development
  Psychology (child-focused)
  Elementary Education
  Art Education
  Music Education
  Physical Education
  Social Work (child/family-focused)
  Speech and Language Pathology (early childhood focus)
  Occupational Therapy (pediatric focus)
  Human Services (child/family-focused)
  Nursing (pediatric/early childhood background)
  Equity Between DOE and Non-DOE Centers
  Montessori Credential (AMS / AMI)
  • •
  • •
  Not all schools have Universal 3K.
  If DOH requires childcare centers to meet the same qualifications as DOE/3K programs, staffing will become nearly impossible because:
  – Teachers will prefer DOE jobs (shorter hours, summers off, DOE benefits).
  – Childcare centers without 3K will struggle to attract and retain teachers.
  Clarification Needed on New Requirements
  •
  •
  •
  Age transitions: Can children remain with the same teacher until 3 years 11 months (3.11), or must they change classrooms immediately upon turning three?
  CDA requirements: If a teacher holds a CDA, is a study plan still required? If so, what is the completion timeline, and can short breaks in enrollment be permitted?
  Experience-based qualifications: Will a teacher with only a high school diploma but 3+ years of verified experience (supported by references and resume) qualify to serve as a preschool group teacher under the new rules?
  Key Requests
  • • •
  • •
  Accept foreign daycare teaching experience.
  Broaden eligible fields of study/experience for preschool teachers.
  Revise experience requirement from 5 years to 3 years to allow qualified assistants to move into lead teacher roles sooner.
  Provide flexibility for non-3K centers so they can remain competitive in hiring.
  Clarify CDA requirements, age transition rules, and experience-based qualifications

  Comment added August 22, 2025 10:53pm

• Daneel Howe

  First and foremost, we at (insert name of daycare) want to thank those involved in revising staffing changes to provide CBOs and daycares with more flexibility. We are very grateful that decision-makers are seeing the huge challenges that early childhood industry is facing even though we are essential workers that help prop up the economy. Please see our comments and suggestions below:

  ED Changes

  1. ED shorter core hours – we wholeheartedly support this move as ED should not be onsite for 10-11 hours a day to stay compliant.
  2. Expanded pool of designee – we are happy that group teachers with degrees in ECE are now allowed to be designee and to cover ED for up to 60 days in case the ED leaves.
  – [ ] We recommend the coverage period to be increased to 90 days as hiring takes longer than 2 mos for such a role and with such a shortage of certified teachers.

   
  Group Teacher Changes

  1. We support the decision to increase coverage for group teachers to 5 days and recommend this increase to 10 days to be more in line with the DOE as classroom teachers get 10 days of PTO a year.
  2. We are thrilled to see that Group Teachers for infant / toddler qualifications are now able to be group teachers for infant / toddler classrooms. This is a way to make it fair for those under different licensures but serve the same age population.
  1. We suggest that this takes into account degrees while including experience in a classroom such as BA + 3 year’s classroom experience and MS + 2 years experience to be considered a GT for infant / toddler classroom.
  2. We also suggest that educators with foreign credentials be approved for their experience in the classroom in other countries as this training is invaluable and will help fill the workforce as essential workers
  ***We are devastated to see that many formerly approved degrees for certification / study plan / group teacher have been stripped from current regulations. This is devastating for our schools as we have been supporting teachers under study plans and have been working under specific certifications with degrees. We ask the decision-makers to broaden accepted fields: Expand eligible fields of study/experience for preschool teachers (ages 3+) to include the following:
  Child Development
  Psychology (child-focused)
  Art Education
  Music Education
  Physical Education
  Social Work (child/family-focused)
  Montessori Credential (AMS / AMI)
  Speech and Language Pathology (early childhood focus)
  Occupational Therapy (pediatric focus)
  Human Services (child/family-focused)
  Nursing (pediatric/early childhood background)
  Equity Between DOE and Non-DOE Centers

  We thank you for your foresight and proactive thinking in helping to save our overburdened schools. We hope you will take our suggestions into consideration.

  Comment added August 23, 2025 11:32am

• Daneel Howe

  First and foremost, we at MACADEMY would like to thank those involved in revising staffing changes to provide CBOs and daycares with more flexibility. We are very grateful that decision-makers are seeing the huge challenges that early childhood industry is facing even though we are essential workers who help prop up the economy. Please see our comments and suggestions below:

  ED Changes

  1. ED shorter core hours – we wholeheartedly support this move as ED should not be onsite for 10-11 hours a day to stay compliant.
  2. Expanded pool of designee – we are happy that group teachers with degrees in ECE are now allowed to be designee and to cover ED for up to 60 days in case the ED leaves.
  – [ ] We recommend the coverage period to be increased to 90 days as hiring takes longer than 2 mos for such a role and with such a shortage of certified teachers.

   
  Group Teacher Changes

  1. We support the decision to increase coverage for group teachers to 5 days and recommend this increase to 10 days to be more in line with the DOE as classroom teachers get 10 days of PTO a year.
  2. We are thrilled to see that Group Teachers for infant / toddler qualifications are now able to be group teachers for infant / toddler classrooms. This is a way to make it fair for those under different licensures but serve the same age population.
  1. We suggest that this takes into account degrees while including experience in a classroom such as BA + 3 year’s classroom experience and MS + 2 years experience to be considered a GT for infant / toddler classroom.
  2. We also suggest that educators with foreign credentials be approved for their experience in the classroom in other countries as this training is invaluable and will help fill the workforce as essential workers
  ***We are devastated to see that many formerly approved degrees for certification / study plan / group teacher have been stripped from current regulations. This is devastating for our schools as we have been supporting teachers under study plans and have been working under specific certifications with degrees. We ask the decision-makers to broaden accepted fields: Expand eligible fields of study/experience for preschool teachers (ages 3+) to include the following:
  Child Development
  Psychology (child-focused)
  Art Education
  Music Education
  Physical Education
  Social Work (child/family-focused)
  Montessori Credential (AMS / AMI)
  Speech and Language Pathology (early childhood focus)
  Occupational Therapy (pediatric focus)
  Human Services (child/family-focused)
  Nursing (pediatric/early childhood background)
  Equity Between DOE and Non-DOE Centers

  We thank you for your foresight and proactive thinking in helping to save our overburdened schools. We hope you will take our suggestions into consideration.

  Comment added August 23, 2025 11:36am

• Victoria Luzuriaga

  First and foremost, we at wBees Forest House Inc. want to thank those involved in revising staffing changes to provide CBOs and daycares with more flexibility. We are very grateful that decision-makers are seeing the huge challenges that early childhood industry is facing even though we are essential workers that help prop up the economy. Please see our comments and suggestions below:

  ED Changes

  ED shorter core hours – we wholeheartedly support this move as ED should not be onsite for 10-11 hours a day to stay compliant.
  Expanded pool of designee – we are happy that group teachers with degrees in ECE are now allowed to be designee and to cover ED for up to 60 days in case the ED quits.
  We recommend the coverage period to be increased to 90 days as hiring takes longer than 2 mos for such a role and with such a shortage of certified teachers.

  Group Teacher Changes
  We support the decision to increase coverage for group teachers to 5 days and recommend this increase to 10 days to be more in line with the DOE as classroom teachers get 10 days of PTO a year.
  We are thrilled to see that Group Teachers for infant / toddler qualifications are now able to be group teachers for infant / toddler classrooms. This is a way to make it fair for those under different licensures but serve the same age population.
  We suggest that this takes into account degrees while including experience in a classroom such as BA + 3 year’s classroom experience and MS + 2 years experience to be considered a GT for infant / toddler classroom.
  We also suggest that educators with foreign credentials be approved for their experience in the classroom in other countries as this training is invaluable and will help fill the workforce as essential workers
  ***We are devastated to see that many formerly approved degrees for certification / study plan / group teacher have been stripped from current regulations. This could break our schools as we have been supporting teachers under study plans and have been working under specific certifications with degrees. We ask the decision-makers to broaden accepted fields: Expand eligible fields of study/experience for preschool teachers (ages 3+) to include the following:

  Child Development

  Psychology (with 9 credits of child-focused Psychology)

  Art Education

  Music Education

  Physical Education

  Social Work (child/family-focused)

  Montessori Credential (AMS / AMI)

  Speech and Language Pathology (early childhood focus)

  Occupational Therapy (pediatric focus)

  Human Services (child/family-focused)

  Nursing (pediatric/early childhood background)

  Equity Between DOE and Non-DOE Centers

  We thank you for your foresight and proactive thinking in helping to save our overburdened schools. We hope you will take our suggestions into consideration.

  Comment added August 23, 2025 11:37am

• Yelena Shteyman

  We respectfully submit the following recommendations and requests for clarification regarding teacher qualifications under the amended Article 47. These changes, if applied without flexibility, could have significant impacts on non-3K childcare centers’ ability to recruit and retain staff.
  Key Recommendations

  Accept foreign experience: Recognize documented early childhood teaching experience from licensed childcare centers abroad.
  Broaden accepted fields: Expand eligible fields of study/experience for preschool teachers (ages 3+) to include child development, psychology, social work, nursing (pediatric), occupational therapy, speech and language pathology, human services, and elementary education, social work, Art Education, Music Education, Physical Education, Montessori Certification, Teacher of languages ( linguist)
  Preserve staffing equity: Ensure childcare centers without Universal 3K are not disadvantaged by DOE-level requirements that make it difficult to compete for teachers.
  Revise experience requirement: Allow teachers with 3 years of verified teaching experience (instead of 5) to qualify as lead preschool teachers. Many assistants thrive and grow into excellent leads within this timeframe, and a degree itself is not equivalent to three years of training.
  Clarifications Needed
  •
  •
  •
  Age transitions: Can children remain with the same teacher until 3 years 11 months (3.11), or must they change classrooms immediately upon turning three?
  CDA requirements: If a teacher holds a CDA, is a study plan still required? If so, what is the completion timeline, and can short breaks in enrollment be permitted? Does a teacher need to prove they are enrollled in school or have a plan to enroll in school within a certain time window.
  Experience-based qualifications: Will a teacher with only a high school diploma but 3+ years of verified experience (supported by references and resume) qualify to serve as a preschool group teacher under the new rules?
  Without clear guidance and flexibility, the new requirements may unintentionally create inequities between DOE 3K programs and private childcare centers. We urge DOH to provide clarity, expand eligibility, and allow broader recognition of professional and international experience so that all schools can continue to deliver high-quality early childhood education.
  Detailed Advocacy Points Acceptance of Foreign Experience
  • Accept documented foreign daycare/early childhood teaching experience toward teacher qualifications.

  • Many strong candidates come with years of licensed teaching abroad; this should be recognized.
  Expanded Acceptable Fields of Study/Experience (Ages 3+)
  • • • • • • • •
  Child Development
  Psychology (child-focused)
  Elementary Education
  Art Education
  Music Education
  Physical Education
  Social Work (child/family-focused)
  Speech and Language Pathology (early childhood focus)
  Occupational Therapy (pediatric focus)
  Human Services (child/family-focused)
  Nursing (pediatric/early childhood background)
  Equity Between DOE and Non-DOE Centers
  Montessori Credential (AMS / AMI)
  • •
  • •
  Not all schools have Universal 3K.
  If DOH requires childcare centers to meet the same qualifications as DOE/3K programs, staffing will become nearly impossible because:
  – Teachers will prefer DOE jobs (shorter hours, summers off, DOE benefits).
  – Childcare centers without 3K will struggle to attract and retain teachers.
  Clarification Needed on New Requirements
  •
  •
  •
  Age transitions: Can children remain with the same teacher until 3 years 11 months (3.11), or must they change classrooms immediately upon turning three?
  CDA requirements: If a teacher holds a CDA, is a study plan still required? If so, what is the completion timeline, and can short breaks in enrollment be permitted?
  Experience-based qualifications: Will a teacher with only a high school diploma but 3+ years of verified experience (supported by references and resume) qualify to serve as a preschool group teacher under the new rules?
  Key Requests
  • • •
  • •
  Accept foreign daycare teaching experience.
  Broaden eligible fields of study/experience for preschool teachers.
  Revise experience requirement from 5 years to 3 years to allow qualified assistants to move into lead teacher roles sooner.
  Provide flexibility for non-3K centers so they can remain competitive in hiring.
  Clarify CDA requirements, age transition rules, and experience-based qualifications

  Comment added August 23, 2025 7:57pm

• Fabiola Santos-Gaerlan

  First and foremost, we at Honeydew Drop Childcare want to thank the leaders of the Bureau of Daycare for revising staffing changes to provide CBOs and daycares with more flexibility. We are very grateful that decision-makers are seeing the huge challenges that early childhood industry is facing even though we are essential workers that help prop up the economy. Please see our comments and suggestions below:

  ED Changes

  ED shorter core hours – we wholeheartedly support this move as ED should not be onsite for 10-11 hours a day to stay compliant.
  Expanded pool of designee – we are happy that group teachers with degrees in ECE are now allowed to be designee and to cover ED for up to 60 days in case the ED leaves.
  We recommend the coverage period to be increased to 90 days as hiring takes longer than 2 mos for such a role and with such a shortage of certified teachers.

  Group Teacher Changes

  We support the decision to increase coverage for group teachers to 5 days and recommend this increase to 10 days to be more in line with the DOE as classroom teachers get 10 days of PTO a year.
  We are thrilled to see that Group Teachers for infant / toddler qualifications are now able to be group teachers for infant / toddler classrooms. This is a way to make it fair for those under different licensures but serve the same age population.
  We suggest that this takes into account degrees while including experience in a classroom such as BA + 3 year’s classroom experience and MS + 2 years experience to be considered a GT for infant / toddler classroom.
  We also suggest that educators with foreign credentials be approved for their experience in the classroom in other countries as this training is invaluable and will help fill the workforce as essential workers
  ***We are devastated to see that many formerly approved degrees for certification / study plan / group teacher have been stripped from current regulations. This is devastating for our schools as we have been supporting teachers under study plans and have been working under specific certifications with degrees. We ask the decision-makers to broaden accepted fields: Expand eligible fields of study/experience for preschool teachers (ages 3+) to include the following:
  Child Development
  Psychology (child-focused)
  Art Education
  Music Education
  Physical Education
  Social Work (child/family-focused)
  Montessori Credential (AMS / AMI)
  Speech and Language Pathology (early childhood focus)
  Occupational Therapy (pediatric focus)
  Human Services (child/family-focused)
  Nursing (pediatric/early childhood background)
  Equity Between DOE and Non-DOE Centers

  We thank you for your foresight and proactive thinking in helping to save our overburdened schools. We hope you will take our suggestions into consideration.

  Comment added August 24, 2025 11:03am

• Criselda Carmenate

  First and foremost, we at Riverdale Neighborhood House want to thank those involved in revising staffing changes to provide CBOs and daycares with more flexibility. We are very grateful that decision-makers are seeing the huge challenges that early childhood industry is facing even though we are essential workers that help prop up the economy. Please see our comments and suggestions below:

  ED Changes

  1. ED shorter core hours – we wholeheartedly support this move as ED should not be onsite for 10-11 hours a day to stay compliant.

  2. Expanded pool of designee – we are happy that group teachers with degrees in ECE are now allowed to be designee and to cover ED for up to 60 days in case the ED leaves.

  ◦ We recommend the coverage period to be increased to 90 days as hiring takes longer than 2 mos for such a role and with such a shortage of certified teachers.

  Group Teacher Changes
  1. We support the decision to increase coverage for group teachers to 5 days and recommend this increase to 10 days to be more in line with the DOE as classroom teachers get 10 days of PTO a year.

  2. We are thrilled to see that Group Teachers for infant / toddler qualifications are now able to be group teachers for infant / toddler classrooms. This is a way to make it fair for those under different licensures but serve the same age population.

  a. We suggest that this takes into account degrees while including experience in a classroom such as BA + 3 year’s classroom experience and MS + 2 years experience to be considered a GT for infant / toddler classroom.

  b. We also suggest that educators with foreign credentials be approved for their experience in the classroom in other countries as this training is invaluable and will help fill the workforce as essential workers

  ***We are devastated to see that many formerly approved degrees for certification / study plan / group teacher have been stripped from current regulations. This is devastating for our schools as we have been supporting teachers under study plans and have been working under specific certifications with degrees. We ask the decision-makers to broaden accepted fields: Expand eligible fields of study/experience for preschool teachers (ages 3+) to include the following:

  Child Development

  Psychology (child-focused)

  Art Education

  Music Education

  Physical Education

  Social Work (child/family-focused)

  Montessori Credential (AMS / AMI)

  Speech and Language Pathology (early childhood focus)

  Occupational Therapy (pediatric focus)

  Human Services (child/family-focused)

  Nursing (pediatric/early childhood background)

  Equity Between DOE and Non-DOE Centers

  We thank you for your foresight and proactive thinking in helping to save our overburdened schools. We hope you will take our suggestions into consideration.

  Comment added August 24, 2025 9:07pm

• Julia Zhang

  We are writing to respectfully request an amendment to the current lead teacher qualification requirements outlined in Article 47. The existing regulations, while well-intentioned, have created significant challenges in hiring qualified and competent educators for our preschool classrooms.

  At present, the requirements place an overwhelming emphasis on specific diplomas while undervaluing teaching experience. This has led to a paradoxical situation where many experienced educators, with over a decade of proven classroom expertise—often gained in other states or countries—are deemed unqualified, whereas recent graduates with minimal or no hands-on teaching experience are eligible. This disconnect has resulted in hiring difficulties, workforce shortages, and, in some cases, reduced classroom quality.

  Our Recommendations:

  Incorporate Practical Experience into Qualification Standards
  We propose recognizing a broader range of academic backgrounds in combination with classroom experience:

  Bachelor’s degree in any field plus three years of classroom experience.

  Master’s degree in any field plus two years of classroom experience.

  Acknowledge Foreign Credentials and Experience
  We urge the DOH to recognize teaching experience obtained in other countries, particularly for educators with substantial early childhood training abroad. This adjustment would help alleviate the critical workforce shortage and enrich classrooms with diverse and invaluable expertise.

  Restore and Expand Accepted Fields of Study
  We are deeply concerned that many degrees formerly approved for certification, study plans, or group teacher qualifications have recently been excluded. This change has disrupted the progress of teachers already on study plans and undermined staffing stability. We respectfully request that the following fields be included as eligible for preschool teachers (ages 3+):

  Child Development

  Psychology (child-focused)

  Art Education

  Music Education

  Physical Education

  Social Work

  Speech and Language Pathology (early childhood focus)

  Occupational Therapy (pediatric focus)

  Human Services (child/family-focused)

  Nursing (pediatric/early childhood background)

  Ensure Equity Between DOE and Non-DOE Centers
  Aligning qualification flexibility across both DOE and non-DOE settings would create a fair and consistent standard that benefits children, families, and educators alike.

  We sincerely thank you for your foresight and willingness to consider solutions that can help stabilize and strengthen the early childhood education workforce. We hope these recommendations will guide a more balanced and practical approach that values both academic preparation and real-world teaching expertise.

  Comment added August 26, 2025 12:19am

• Anna Ellis Nesser

  First and foremost, we at Collective Kind want to thank those
  involved in revising staffing changes to provide CBOs and daycares with
  more flexibility. We are very grateful that decision-makers are seeing the
  huge challenges that early childhood industry is facing even though we are
  essential workers that help prop up the economy. Please see our comments
  and suggestions below:

  *ED Changes*
  1. ED shorter core hours – we wholeheartedly support this move as ED
  should not be onsite for 10-11 hours a day to stay compliant.
  2. Expanded pool of designee – we are happy that group teachers with
  degrees in ECE are now allowed to be designee and to cover ED for up to 60
  days in case the ED leaves.
  – We recommend the coverage period to be increased to 90 days as
  hiring takes longer than 2 mos for such a role and with such a
  shortage of
  certified teachers.

  *Group Teacher Changes*
  1. We support the decision to increase coverage for group teachers to 5
  days and recommend this increase to 10 days to be more in line with the DOE
  as classroom teachers get 10 days of PTO a year.
  2. We are thrilled to see that Group Teachers for infant / toddler
  qualifications are now able to be group teachers for infant / toddler
  classrooms. This is a way to make it fair for those under different
  licensures but serve the same age population.
  1. We suggest that this takes into account degrees while including
  experience in a classroom such as BA + 3 year’s classroom
  experience and MS
  + 2 years experience to be considered a GT for infant / toddler
  classroom.
  2. We also suggest that educators with foreign credentials be
  approved for their experience in the classroom in other countries as this
  training is invaluable and will help fill the workforce as
  essential workers

  ***We are devastated to see that many formerly approved degrees for
  certification / study plan / group teacher have been stripped from current
  regulations. This is devastating for our schools as we have been supporting
  teachers under study plans and have been working under specific
  certifications with degrees. We ask the decision-makers to broaden accepted
  fields: Expand eligible fields of study/experience for preschool teachers
  (ages 3+) to include the following:

  Child Development

  Psychology (child-focused)

  Art Education

  Music Education

  Physical Education

  Social Work (child/family-focused)

  Montessori Credential (AMS / AMI)

  Speech and Language Pathology (early childhood focus)

  Occupational Therapy (pediatric focus)

  Human Services (child/family-focused)

  Nursing (pediatric/early childhood background)

  Equity Between DOE and Non-DOE Centers

  We thank you for your foresight and proactive thinking in helping to save
  our overburdened schools. We hope you will take our suggestions into
  consideration.

  Comment added August 26, 2025 1:52pm

• Renee Gervais

  Dear Department of Health and Mental Hygiene,

  I am writing to provide comment on the proposed amendments to Article 47 of the New York City Health Code regarding staff qualifications, maximum age requirements, group teachers for younger children, and staff-to-child ratios for child care programs.

  Request for Additional Provisions on Group Teacher Qualifications

  While I support the Department’s efforts to maintain high standards for child care quality, I urge the inclusion of additional provisions that address the practical challenges of hiring and retaining qualified group teachers in the current educational landscape.

  Private child care providers are facing an unprecedented staffing crisis due to significant compensation disparities between publicly funded programs and private facilities:

  – State-funded 3-K and 4-K programs offer substantially higher wages and benefits to early childhood educators
  – Private preschool and daycare settings cannot compete with these compensation packages, leading to chronic understaffing
  – Qualified teachers are leaving private child care for better-paying positions in public programs

  Proposed Solution: Differentiated Standards
  I respectfully request that the Department consider establishing differentiated qualification standards that recognize the distinct operational contexts of different child care settings:

  For State-Funded 3-K/4-K Programs:
  – Maintain current proposed qualification requirements
  – These programs have access to public funding that supports higher compensation

  For Private Child Care Programs:
  – Create alternative pathways to meet group teacher qualifications
  – Allow for professional development plans that enable teachers to meet requirements over time while employed
  – Consider experience-based qualifications in addition to formal education requirements
  – Establish mentorship programs pairing less credentialed teachers with experienced educators

  Benefits of Differentiated Standards

  1. Preserves Child Care Access: Prevents further closures of private child care programs
  2. Maintains Quality: Ensures children receive care from qualified providers while allowing for professional growth
  3. Supports Workforce Development: Creates pathways for career advancement within the private child care sector
  4. Recognizes Economic Reality: Acknowledges the funding disparities between public and private programs

  I urge the Department to include provisions in the final regulations that:
  – Establish reasonable alternative qualification pathways for private child care providers
  – Allow for phased implementation of new requirements with professional development support
  – Create incentive programs to help private providers attract and retain qualified staff
  – Regularly review and adjust requirements based on workforce availability and program sustainability

  Quality child care is essential for working families and child development. However, unrealistic staffing requirements without corresponding support for compensation equity will further destabilize the private child care market, ultimately harming the families and children these regulations aim to protect.

  I respectfully ask that you consider these concerns and include provisions that balance quality standards with the practical realities of operating sustainable child care programs in New York City.

  Thank you for your consideration of these comments and your continued commitment to supporting quality child care for all New York City families.

  Comment added August 28, 2025 1:55pm

• Nekea

  Thank you for the opportunity to comment on the provisions regarding staff qualifications. Across the childcare field, it has been a significant challenge to hire candidates under the current standards, which in many cases are more restrictive than those applied by the Board of Education.

  There also appears to be inconsistency in how the rules are being interpreted, particularly regarding academic language on transcripts. For example, candidates with a bachelor’s degree and a minor in Early Childhood Education are often denied Head Teacher status because the transcript states “minor” rather than “associate’s degree.” However, many institutions — such as Lehman College — do not issue associate’s degrees, only bachelor’s degrees, and the coursework within a minor provides the equivalent associate-level credits in Early Childhood Education.

  This lack of alignment between the regulation and its interpretation creates unnecessary barriers and excludes otherwise qualified staff from being placed in classrooms. To avoid confusion, the language should be simplified to clearly state:

  “12 credits in Early Childhood Education qualifies an individual to be a Head Teacher in an infant or toddler classroom.”

  Updating the wording and ensuring consistent application of the rules would help expand the pool of qualified candidates, reduce miscommunication, and relieve some of the workforce strain currently facing childcare providers.

  Comment added August 30, 2025 8:53am

• Nekea

  A minor in Early Childhood should qualify an individual to be a group teacher, as it consists of 12 college credits. Many young adults complete these 12 credits, yet unfortunately, they are still not eligible to serve as infant/toddler teachers. Recognizing these credentials would not only validate their education but also provide much-needed support to childcare providers who face ongoing staffing challenges.

  Comment added September 13, 2025 5:43am

• Sane

  Childcare providers who been licensed more than 5 years should be able to take director role for infant and toddler centers

  Comment added September 18, 2025 2:15pm

• Rafa Perez-Segura

  I want to echo the sentiments of many of my fellow commentators. The rules around coverage for the Education Director a much more realistic in terms of coverage and allows Directors to be able to be sick without leaving a school out of compliance. State licensed teachers are few and far between and tend to go to work in the DoE given the generally higher pay.

  The rules around allowing individuals who satisfy the requirements of infant/toddler teachers is helpful to an extent – however for a place like Mi Casita in Brooklyn it means that teacher can only ever work in one classroom. The barriers for getting on a 7 year plan to be a Head Teacher is mounting as enrollment in a program becomes more expensive. Funding for the PDI workforce scholarship is exhausted and financial aid continues to be less available at universities.

  I also support the expansion of fields that are considered “related”. I have run into situations where someone has a psychology degree and over 12 credits in early childhood coursework but simply because the degree doesn’t say “child” in front of it it doesn’t count, despite the person having experience and relevant coursework. This person had more than the 12 required credits, and yet someone with a child psychology degree but fewer credits in early childhood work would technically qualify. That doesn’t make sense.

  In addition to an expanded list, I would promote the Department of Health considering a dynamic process in determining qualification of a candidate. Similar to disability law where employers must engage in an “interactive process” to determine “reasonable accommodations”, I believe the DoH can codify a similar approach where inspectors can work in good faith with programs to determine if someone can be a Head Teacher. For example, I was looking at hiring someone with a degree equivalence from Spain in Elementary Education – focus on foreign language. This is perfect for a Spanish immersion program such as Mi Casita. But I could not get the teacher to be a Head Teacher as she had the “focus on foreign language” aspect in her title. This was a big missed opportunity for the school and deepening high quality education at Mi Casita. Through an interactive process, I wish I could have had a logical good faith conversation with my inspector. The inspector could ask for additional trainings to be given, perhaps in child development, by a certain time. The point is, an interactive process transcends the problem of having the “perfect list” and rather allows for a logical approach to determining teacher qualifications (rather than a strict yet illogical approach of sticking to a list). High quality teaching and education is too complex to be confined to one list. This approach still allows for the DoH to not approve someone who is clearly not qualified (e..g someone with degree from a completely different field) but allows flexibility for programs to meet their unique needs. In summary, I think both an expanded list and allowing for a dynamic approach can meet many needs at once.

  I also always look first for educators with degrees in early childhood and a teaching license, but that’s becoming very difficult to find.

  Around the world, Pedagogy is a common degree related to teaching that I hope is recognized more universally by the DoH sa well, especially if the degree has sufficient coursework in early childhood.

  Respectfully,

  Rafa Perez-Segura
  Education Director Mi Casita Preschool

  Comment added September 18, 2025 2:50pm

• Laurie Torres

  Subject: Urgent Need for Support and Partnership with DOH

  Running a childcare program has become increasingly challenging, yet I remain deeply committed because I truly love the work we do. Like many of my colleagues, I recognize that the recent changes are a step in the right direction, but we urgently need continued reform and a stronger partnership with the Department of Health.

  One area of concern is the disparity in required core hours. DOE NYC teachers have core hours of 6 hours and 20 minutes, while our schools, even with the revised Ed Director (certified teacher) requirement, are held to an 8-hour day. Aligning these expectations would greatly help with recruitment and retention.

  The Ed Director requirement for preschool-age children is particularly difficult to meet and sustain. Certified teachers overwhelmingly choose DOE positions because of the benefits, leaving childcare centers at a severe disadvantage. Meanwhile, we have highly qualified teachers—many with Bachelor’s and Master’s degrees and decades of experience—who are ineligible solely due to certification.

  Montessori programs are a prime example. Our credentialed Montessori teachers undergo rigorous training that is equivalent to Group Teacher requirements, yet their qualifications are not recognized. This barrier prevents us from hiring excellent educators who are ready and able to serve children.

  To address these challenges, we strongly recommend the following:

  Broaden Accepted Fields: Expand eligible qualifications for infant/toddler and preschool teachers to include fields such as Child Development, Psychology, Sociology, Elementary Education, Social Work, Art Education, Music Education, Physical Education, Speech and Language Pathology, Occupational Therapy, Human Services, Linguistics, and Montessori Certification in infant/toddler or primary classroom.

  Preserve Staffing Equity: Ensure childcare centers without Universal 3K are not disadvantaged by DOE-level requirements that make it nearly impossible to compete for teachers.

  Revise Experience Requirement: Allow teachers with 3 years of verified teaching experience (instead of 5) to qualify as lead preschool teachers.

  If DOH cannot collaborate more effectively with infant/toddler programs and preschools, we risk a continued decline in the availability and quality of early childhood care. In Carroll Gardens alone, the rapid rise in new housing has not been matched with enough schools, creating a critical gap for families.

  We urge DOH to provide more flexibility in staffing requirements and to open opportunities for funding and grants—even for for-profit schools—so that we can adequately staff our programs without taking on unsustainable debt.

  Please help us continue to provide the high-quality care that families in our community so urgently need. Thank you for your time and consideration.

  Sincerely,
  Laurie Torres
  Executive Director/Founder
  Elite Minds Montessori

  Comment added September 22, 2025 11:42am

• Susan Galanos

  These proposed updated staffing requirement changes are much needed and appreciated for Day Cares/Preschools like ours that struggle with staffing. From what previous staff have told us, they were able to count as Preschool Teachers in DOE UPK programs and Catholic schools with less requirements than our program has to follow due to DOHMH. We hope with these changes we will be able to comfortably bring on more children and have more staff stay with us longer as it opens up more opportunities for growth.

  If you could consider continuing to expand on the changes for your staffing requirements:
  Experience-based qualifications: Expanding who can be a Head Teacher in Infant/Toddler programs (extended now to 2-year-old Preschool classrooms) to being a high school diploma and 3+ years of verified experience (rather than 5+ years)?
  Experience-based qualifications: Allowing more longevity/experience of years to qualify as a Preschool Group Teacher?
  For Preschool Group Teachers: Lowering requirements for Preschool Group Teacher, such as less credits needed and expanding which majors/degrees qualify?

  Our main difficulty is finding and keeping Preschool Study-Plan Teachers, Preschool Group Teachers, and Education Directors. Any efforts to expand the pool of candidates who can apply and work in these positions would be a major help.

  Comment added September 22, 2025 1:47pm

• stacy Rose-McFarland

  I appreciate the Department’s initiative in clarifying operating hours and the roles of EDs, as well as concern that quality and safety on site should always be paramount. However, the proposed language in §47.13(c) and §47.01 creates a standard for EDs that is both unworkable and unreasonable.

  §47.13(c) requires an ED to be on site “no less than 8 hours per day during the program’s core operating hours,” while §47.13(c)(1) requires the ED or an ED designee to be on site whenever any child is present. This makes sense until you do the math on how much time, and more crucially when, an ED designee can actually cover. The new “ED designee” provision limits coverage to time outside core operating hours or to ED absences that “do not exceed a total of 60 cumulative days in a 12-month period.” Because “core operating hours” (§47.01) cover the entire instructional day (excluding only drop-off/pick-up), this combination effectively eliminates the ED’s ability to take a daily lunch break or brief personal break without risking non-compliance or burning through the 60-day cap in a matter of weeks.

  These provisions are not reasonable given the realistic day-to-day operations of educators. Instruction and supervision are continuous throughout the day with rolling breaks, not a universal pause. There is not a standardly set time for an ED to step away. ED work is also inherently team-based and requires the participation of many moving actors: coaching teachers alone is dependent upon the schedule of a dozen or so people. This does not even begin to mention handling family issues, responding to incidents, ensuring the site is in compliance with relevant standards, and coordinating with supply and food vendors. Expecting one individual to be physically on site without relief during nearly all operating hours is unrealistic and undermines staff and program well-being. In small programs that can’t afford a second administrator, this burden is exacerbated.

  Relaxing this language would not reduce quality and safety of education programs. Programs already screen and train administrative staff, and the collaborative environment in education often leads to people holding skills beyond their strict job description. Because of this, it is important to lax micromanagement of task delegation; educators and administrators know the skills of their peers better than any standard could. Allowing a qualified designee to serve as acting ED for short intervals maintains safety and continuity while respecting the basic human needs of the ED. Prohibiting this during core hours provides no added protection to children, but it does put an undue burden onto staff in a sector with high burnout.

  Some recommendations moving forward:
  Allow designee coverage during core operating hours for short intervals. Allow designees to be appointed by qualified administrators on site with some form of review (multiple people signing off on who is qualified).
  Exclude brief coverage from the “60 cumulative days” cap. Make clear that short, intra-day designee coverage does not count toward the 60-day annual limit intended for longer ED absences.
  Offer a compliance pathway. Require programs to identify designees in the safety plan (§47.11) and integrate them within the existing coverage structures. Though mandated already elsewhere, ensure designees have ED’s contacts such that they are easily reachable.
  Flex the 8-hour rule. Permit reasonable exceptions for legally required breaks and short administrative needs.

  These recommendations both help the department formalize responsibilities and help educators maintain reasonable operating standards such that the best quality education and complete attention can be given to our communities. By treating our EDs fairly, we treat our schools fairly, and ensure everyone is safe and cared for.

  Comment added September 22, 2025 3:03pm

• Oi

  Re: Amended Article 47 – Impact on Childcare Centers
  We respectfully submit the following recommendations and requests for clarification regarding teacher
  qualifications under the amended Article 47. These changes, if applied without flexibility, could have
  significant impacts on non-3K childcare centers’ ability to recruit and retain staff.
  Key Recommendations
  • Accept foreign experience: Recognize documented early childhood teaching experience from
  licensed childcare centers abroad.
  • Broaden accepted fields: Expand eligible fields of study/experience for preschool teachers
  (ages 3+) to include Child Development, Psychology, Elementary Education, Social Work, Art
  Education, Music Education, Physical Education, Speech and Language Pathology,
  Occupational Therapy, Human Services, Nursing (pediatric/early childhood), Montessori
  Certification, and Teacher of Languages (Linguistics).
  • Preserve staffing equity: Ensure childcare centers without Universal 3K are not disadvantaged
  by DOE-level requirements that make it difficult to compete for teachers.
  • Revise experience requirement: Allow teachers with 3 years of verified teaching experience
  (instead of 5) to qualify as lead preschool teachers. Many assistants thrive and grow into
  excellent leads within this timeframe, and a degree itself is not equivalent to three years of
  training.
  Clarifications Needed
  • Age transitions: Can children remain with the same teacher until 3 years 11 months (3.11), or
  must they change classrooms immediately upon turning three?
  • CDA requirements: If a teacher holds a CDA, is a study plan still required? If so, what is the
  completion timeline, and can short breaks in enrollment be permitted? Does a teacher need to
  prove they are enrolled in school or have a plan to enroll in school within a certain time
  window?
  • Experience-based qualifications: Will a teacher with only a high school diploma but 3+ years of
  verified experience (supported by references and resume) qualify to serve as a preschool
  group teacher under the new rules?
  Without clear guidance and flexibility, the new requirements may unintentionally create inequities
  between DOE 3K programs and private childcare centers. We urge DOH to provide clarity, expand
  eligibility, and allow broader recognition of professional and international experience so that all schools
  can continue to deliver high-quality early childhood education.
  Detailed Advocacy Points
  Acceptance of Foreign Experience
  • Accept documented foreign daycare/early childhood teaching experience toward teacher
  qualifications.
  • Many strong candidates come with years of licensed teaching abroad; this should be recognized.
  Expanded Acceptable Fields of Study/Experience (Ages 3+)
  • Child Development
  • Psychology (child-focused)
  • Elementary Education
  • Art Education
  • Music Education
  • Physical Education
  • Social Work (child/family-focused)
  • Speech and Language Pathology (early childhood focus)
  • Occupational Therapy (pediatric focus)
  • Human Services (child/family-focused)
  • Nursing (pediatric/early childhood background)
  • Montessori Certification (AMS/AMI)
  • Teacher of Languages (Linguistics)
  Equity Between DOE and Non-DOE Centers
  • Not all schools have Universal 3K.
  • If DOH requires childcare centers to meet the same qualifications as DOE/3K programs,
  staffing will become nearly impossible because:
  • – Teachers will prefer DOE jobs (shorter hours, summers off, DOE benefits).
  • – Childcare centers without 3K will struggle to attract and retain teachers.
  Clarification Needed on New Requirements
  • Age transitions: Can children remain with the same teacher until 3 years 11 months (3.11), or
  must they change classrooms immediately upon turning three?
  • CDA requirements: If a teacher holds a CDA, is a study plan still required? If so, what is the
  completion timeline, and can short breaks in enrollment be permitted? Does a teacher need to
  prove they are enrolled in school or have a plan to enroll in school within a certain time
  window?
  • Experience-based qualifications: Will a teacher with only a high school diploma but 3+ years of
  verified experience (supported by references and resume) qualify to serve as a preschool
  group teacher under the new rules?
  Key Requests
  • Accept foreign daycare teaching experience.
  • Broaden eligible fields of study/experience for preschool teachers.
  • Revise experience requirement from 5 years to 3 years to allow qualified assistants to move
  into lead teacher roles sooner.
  • Provide flexibility for non-3K centers so they can remain competitive in hiring.
  • Clarify CDA requirements, age transition rules, and experience-based qualifications.

  Comment added September 22, 2025 4:04pm

• J Wold

  For childcare businesses like ours to remain successful, updates to the City Health Code are not just helpful, they are necessary.

  • Staff requirements must be revised so that programs are not placed at constant risk of violations. The current standards make it difficult to hire and retain qualified staff, especially when competing with DOE salaries and benefits. Allowing foreign degrees to be recognized would also expand the hiring pool, making it easier to find highly qualified educators who bring valuable experience and cultural perspectives.

  • The role of the Educational Director also needs to be reconsidered. Small daycares cannot compete with the DOE’s structure, and without changes, we risk losing strong leaders who are vital to the quality of our programs.

  • Class size and staff-to-child ratio rules are currently too restrictive. With strict limits, daycares cannot increase enrollment to balance the rising costs of salaries, rent, and supplies. At the same time, we cannot raise tuition when families have free universal 3K and 4K programs as alternatives.

  Without these changes, small childcare businesses face mounting financial strain and the risk of closure. Updating the code is not just about compliance, it is about sustainability. Small, community-based daycares are a cornerstone of New York City’s early childhood landscape, and these adjustments are essential to ensure they can survive and continue serving families.

  Comment added September 22, 2025 5:00pm

• Kate Hoy

  On behalf of the InterAgency Council of Developmental Disabilities Agencies and the providers we represent, I wish to offer the following comments:
  1. We recommend clarification of the proposed language of 47.13 to avoid confusion. As it currently stands, providers were concerned that educational directors would be obligated to be present for 8 hours. Some programs are in operation for less than 8 hours. Please amend to clarify that depending on their specific programming, the core hours can be less than 8 hours, in which case an Educational Director must be onsite for the entire time.
  2. We are concerned about the way the proposed regulation defines who can serve as an Educational Director designee. The language being used says that:

  “a preschool Group Teacher who has a bachelor’s degree in Early Childhood Education or a related field of study and two years of experience in a preschool program can serve as the ED Designee for their preschool or an infant toddler program.”

  The problem is that this wording appears to exclude other qualified administrative staff from being eligible, which I do not believe was the intent. As written, a professional who holds a NYS SDL certificate is eligible to serve as a superintendent of a school district but apparently cannot cover as the director of a preschool center.

  In 4410 schools, we often have roles such as clinical coordinators, clinical directors, or IEP coordinators who are more than qualified to step into this role when needed and whose coverage would be far less disruptive than pulling a classroom teacher away from children. Daycare centers may not employ these types of administrative positions, but 4410 programs do, and they should be recognized in this context.

  The language really should not be limited to “group teacher.” A better formulation would be “a staff member who has a bachelor’s degree in Early Childhood Education or related field of study and two years of experience in a preschool program.”

  That would allow programs to identify administrative staff who are already responsible for oversight functions and who hold advanced NYSED credentials, without creating unnecessary disruption to classroom operations.

  DOH has already begun asking programs for the designee form and list of names, so this is not theoretical; it is being asked for upon program inspection. I think it is important we address this gap and push for clarification before programs are forced into compliance positions that make little sense in practice and were not intended by the regulation.

  Thank you for the opportunity to provide comment.

  Comment added September 22, 2025 5:43pm