October 10, 2016
Via Email: CCLRules@dfps.state.tx.us
Department of Family and Protective Services
Child Care Licensing
Texas Register Liaison, Legal Services – 465
DFPS E-611, PO Box 149030
Austin, Texas 78714-9030
RE: Chapter 746 – Minimum Standards for Child Care Centers – Proposed Rules. Subchapter E. Child/Caregiver Ratios and Group Sizes; Subchapter Q. Nutrition and Food Services; Subchapter F. Developmental Activities and Activity Plan; Subchapter D. Professional Development
Thank you for the opportunity to submit comments on the proposed rule changes for Chapter 746 – Minimum Standards for Child Care Centers. We thank the Department of Family and Protective Services (DFPS) and the Child Care Licensing Division for its work over the last year to review the minimum standards in Chapter 746, hold stakeholder forums, and gather input on changes that would help improve the health, safety, and wellbeing of children in child care centers.
Texans Care for Children is a statewide non-profit, non-partisan, multi-issue children’s policy organization that works to drive policy change to improve the lives of Texas children today for a stronger Texas tomorrow. We collaborate with community leaders and local partners around the state to identify challenges facing children and families and develop potential policy solutions to improve the well-being of Texas children and families.
We are deeply concerned that DFPS is not proposing critically-needed improvements in the area of group size and child-to-caregiver ratios (Subchapter E); nutrition and food service (Subchapter Q); developmental activities and activity plans (Subchapter F); and professional development (Subchapter D). DFPS must prioritize improvements in these areas to ensure that children in child care centers have sufficient supervision, access to healthy foods, and opportunities for active play. Stronger child care minimum standards allow child care centers and parents to partner to help children stay safe, be physically active, develop their minds, and form healthy eating habits at an early age.
Texans Care for Children’s full comments to DFPS are available here.
