Rule-making Standards and Procedures

STAKEHOLDER COMMENT SUMMARY


DEVELOPMENT
The following individuals and/or entities were included in the development of these proposed rules (such as other Program Areas, Legislative Liaison, and Sub-PAC):
Child Care Center Rule Re-write committee, which includes the Early Childhood Association of Colorado, Colorado Children’s Campaign, Colorado Association for the Education of Young Children, Buell Foundation, Early Childhood Council Leadership Alliance; Red Rocks Child Care; Children’s Hospital; Colorado Association for the Education of Young Children; Colorado Department of Public Health and Environment, Colorado Department of Education, Qualistar, Montessori Associations, Denver Public Health and Environment, early childhood licensed program representatives;

Office of Early Childhood (OEC) Sub-PAC

THIS RULE-MAKING PACKAGE
The following individuals and/or entities were contacted and informed that this rule-making was proposed for consideration by the State Board of Human Services:
Early Childhood Association of Colorado, Colorado Children’s Campaign, Colorado Association for the Education of Young Children, Buell Foundation, Early Childhood Council Leadership Alliance; Red Rocks Child Care; Children’s Hospital; Colorado Association for the Education of Young Children; Colorado Department of Public Health and Environment, Colorado Department of Education, Qualistar, Montessori Associations, Denver Public Health and Environment; all licensed child care providers
Are other State Agencies (such as Colorado Department of Health Care Policy and Financing) impacted by these rules? If so, have they been contacted and provided input on the proposed rules?

Yes

X

No

Have these rules been reviewed by the appropriate Sub-PAC Committee?

X

Yes

No

Date presented _October 8, 2015______. Were there any issues raised? ____ Yes __X__ No

If not, why. The county representatives did not have any immediate concerns.

Comments were received from stakeholders on the proposed rules:

X

Yes

No

If “yes” to any of the above questions, summarize and/or attach the feedback received, including requests made by the State Board of Human Services, by specifying the section and including the Department/Office/Division response. Provide proof of agreement or ongoing issues with a letter or public testimony by the stakeholder.
Please see attached letter from Qualistar and stakeholder comments in an Addendum to these rules.

Director Reggie Bicha

Colorado Department of Human Services

1575 Sherman Street

Denver, CO 80203

October 20, 2015

Thank you for the opportunity to express our praise and recommendations regarding the development of the proposed rules regulating child care centers. We share your dedication to improving health and safety for our youngest Coloradans and commend you for recognizing the importance of improving regulations in the early learning setting.

First, we applaud the Department for improving the training standards and documentation for child care health consultants. These requirements will enhance the skills of the only medical professional that regularly monitors the health of children in child care. Specifically, the requirement of completion of a Department approved training within six months for child care health consultants that have not worked as a school nurse or a child care health consultant prior to January 1, 2016, will improve the proficiency of the child care health consultant workforce (7.702.55.C.4). Furthermore, requiring the center to maintain documentation of the child care health consultant’s proof of current licensure in good standing and a brief biography will provide the center with a greater appreciation for the level of education and expertise that the child care health consultant offers them (7.702.55.C.3).

Additionally, we applaud the requirement that all meals and snacks meet the current USDA Child and Adult Care Food Program Meal Pattern Requirements (7.702.65.A.1). This will ensure that more of Colorado’s children receive proper nutrition in care. We are also pleased that the Department has limited the serving of sugar-sweetened beverages in child care (7.702.65.A.2-3). However, we recommend that flavored milk be added as an example of a sugar-sweetened beverage. We also recommend that a breastfeeding policy be added to rule 7.702.4 (S).

We are delighted that the Department has prohibited television and video viewing for children younger than 2 (7.702.68.B). We are pleased with the limitations on the amount of media and incremental length of viewing for children age 2 and older (7.702.68. B). However, we recommend the term “special occasion” be defined in 7.702.

We are pleased with the improvement of rules that encourage physical activity in child care, specifically the inclusion of tummy time for infants, as well as the addition of at least 60 per day of gross motor activities for preschoolers in full-day child care programs. These rules meet the guidelines from Active Start: A Statement of Physical Activity Guidelines for Children Birth to Five Years from The National Association for Sport and Physical Education (NASPE). However, we strongly propose an additional rule requiring gross motor activities for toddlers. We recommend that, like preschoolers and infants, providers who care for toddlers follow the NASPE guidelines and provide 30 minutes of gross motor activities in a full day program. We also suggest that gross motor activity be teacher led.

We are pleased with the Department’s recognition that staff training in social emotional development is an important element of workforce development for child care professionals, a commitment that is specifically highlighted in rule 7.702.43.K.

We are disappointed in the absence of rules that promote breastfeeding. We recommend that the Department follow the state of Mississippi, which requires child care centers to provide breastfeeding mothers with a sanitary place that is not a toilet stall to breastfeed their children or express milk. Miss. Code Ann. § 43-20-31.

We are pleased that rules 7.702.43(N) and 7.702.55(C)(6) require that child care staff responsible for review and maintenance of child immunizations and child care health consultants complete the Colorado Department of Public Health and Environment’s (CDPHE) immunization course annually. Furthermore, we are thrilled that rule 7.702.62(A) aligns with CDPHE’s documentation of immunization status and exemptions. However, we are disappointed that the proposed rules do not go further to implement evidence based immunization practices.

We encourage the Department to clarify the language that describes the labeling of medications, safe storage of medications, adequate training, and the administration of emergency medications. We know that the administration of medications is one of the most important safety issues in child care and we look forward to seeing clarifying language on how medications are managed in child care settings.

Again, thank you for the opportunity to comment on the proposed rules regulating child care centers. We are pleased to see the Department taking steps to improve the health and safety of Colorado’s youngest residents. Please feel free to contact Qualistar Colorado with any comments or concerns. Please contact: Heather Frenz, Director of Healthy Child Care Colorado at 303.336.6822 or [e-mail]. We look forward to continuing to work with the Department to improve the health and safety of child care in the state of Colorado.

Sincerely,

Kathryn V. Harris

President and CEO

(12 CCR 2509-8)

7.702 RULES REGULATING CHILD CARE CENTERS (LESS THAN 24-HOUR CARE)

All child care centers must comply with the CURRENT “General Rules for Child Care Facilities” 7.701, as well as the “Rules Regulating Child Care Centers (Less Than 24-Hour Care)” 7.702, “RULES REGULATING SPECIAL ACTIVITIES” 7.719, and the “Rules and Regulations Governing the Sanitation of Child Care Centers in the State of Colorado” C.R.S. 25-1.5-101(1)(h), AND THE USDA CACFP PART 266.20(1.5).

All infant nurseries and toddler nurseries must meet all of the requirements for centers in 7.702 except where rules specific to infant or toddler nurseries replace other rules. Rules that apply only to infant and toddler nurseries appear in bold type/italics at the end of sections. These rules either replace other rules in that section or are in addition to other rules in that section. The “contents” pages also indicate rules that apply only to infant nurseries and toddler nurseries .

7.702.1 (None) [Rev. eff. 6/1/12]

7.702.2 7.702.1 DEFINITIONS [Rev. eff. 6/1/12]

A. Child care centers, less than 24-hour care (referred to as “centers”), provide comprehensive care for children when the parents or guardians are employed or otherwise unavailable to care for the children. Child care centers may operate twenty four (24) hours a day, but the children are cared for at the center fewer than twenty four (24) hours a day.

B. Child care centers, less than 24-hour programs of care, include the following types of facilities:

1. A “large child care center” provides care for 16 or more children between the ages of 2 1/2 and 168 years.

2. A “small child care center” provides care for 5 through 15 children between the ages of 2 and 168 years.

3. An “infant nursery PROGRAM” provides care for children between the ages of 6 weeks and 18 months.

4. A “toddler nursery PROGRAM” provides care for children between the ages of 12 months (when walking independently OR WITH A HEALTH CARE PROVIDER’S STATEMENT) and 36 months.

5. “Preschool” is a part-day child care program for 5 or more children between the ages of 2 1/2 and 7 years.

6. “Kindergarten” provides a program for children the year before they enter the first grade.

7. “FULL DAY PROGRAM” ENROLLS CHILDREN FOR FIVE (5) OR MORE HOURS PER DAY.

8. “PART DAY PROGRAM” ENROLLS CHILDREN FOR A MAXIMUM OF UP TO FIVE (5) HOURS PER DAY. INDIVIDUAL CHILDREN SHALL NOT ATTEND MORE THAN ONE (1) FIVE (5) HOUR SESSION PER DAY.

7 9. A “drop-in child care center” provides occasional care for 40 or fewer children between the ages of 12 months and 13 years of age for short periods of time not to exceed six (6) hours in any 24-hour period of time or fifteen (15) hours in any seven (7) day period of time.

7.702.3 7.702.2 ADMINISTRATION

(See also “Administration” at 7.701.5, General Rules for Child Care Facilities)

A. The governing body must appoint a director who will be responsible to the governing body and who will be delegated the authority and responsibility for the operation of the center according to its defined purpose and policies.

B. The governing body must formulate the purpose and policies to be followed by the center. It must have a regular planned review of such purpose and policies to determine that the center is in compliance with licensing rules.

C. The governing body is responsible for providing necessary facilities, adequate financing, qualified personnel, services, and program functions for the safety and well-being of children in accordance with these rules.

D. ANY CENTER HAVING A DIRECTOR ASSIGNED TO A CLASSROOM SHALL HAVE QUALIFIED AND ADEQUATE STAFF FOR DUTIES ASSIGNED, ALLOWING THE DIRECTOR OR QUALIFIED STAFF THE ABILITY TO ATTEND TO THE DUTIES OF A DIRECTOR AS THEY ARISE.

D E. The director of the center is responsible for administering the center in accordance with licensing rules. The director must plan and supervise the child development program, plan for or participate in selection of staff, plan for orientation and staff development, supervise and coordinate staff activities, evaluate staff performance, and participate in the program activities.

E F. The director of a part-day preschool program operated by an accredited public school system is responsible for administering the center in accordance with licensing rules and supervising the EARLY childHOOD development program. The director OR STAFF DESIGNATED BY THE GOVERNING BODY must plan for or participate in orientation and staff development, supervise or coordinate staff activities, participate in the evaluation of staff performance, and participate in program activities.

7.702.4 7.702.3 POLICIES AND PROCEDURES

7.702.41 7.702.31 Statement of Policies and Procedures

AT THE TIME OF ENROLLMENT, AND UPON AMENDMENT THE CENTER MUST GIVE THE PARENT(S)/GUARDIAN(S) THE CENTER’S POLICIES AND PROCEDURES, AND PROVIDE THE OPPORTUNITY TO ASK QUESTIONS. BY SIGNING THE POLICIES AND PROCEDURES DOCUMENT, THE PARENT(S)/GUARDIAN(S) AGREE TO FOLLOW, ACCEPT THE CONDITIONS OF, AND GIVE AUTHORIZATION AND APPROVAL FOR THE ACTIVITIES DESCRIBED IN THE POLICIES AND PROCEDURES. WRITTEN COPIES MUST BE AVAILABLE EITHER ELECTRONICALLY OR IN HARD COPY. THE PROVIDER MUST OBTAIN A SIGNED DOCUMENT STATING THAT THE PARENT(S)/GUARDIAN(S) HAVE RECEIVED THE POLICIES AND PROCEDURES. A written statement of the center's policies and procedures must be made available to parents and guardians and to staff and POLICIES must include the following:

A. The center's purpose and its philosophy on child care.

B. The ages of children accepted.

C. Services offered for special needs children in compliance with the Americans with Disabilities Act.

DC. The hours the center is open, specific hours during which special programs are offered, holidays when the center is closed.

ED. The policy PROCEDURE regarding inclement and excessively hot weather.

FE. The procedure concerning admission and registration of children.

GF. An itemized fee schedule.

HG. The procedure for identifying where children are at all times.

H. The policy on discipline CENTER’S PROCEDURE ON GUIDANCE, POSITIVE INSTRUCTION, SUPPORTING POSITIVE BEHAVIOR, DISCIPLINE AND CONSEQUENCES, INCLUDING HOW THE CENTER WILL:

1. CULTIVATE POSITIVE CHILD, STAFF AND FAMILY RELATIONSHIPS.

2. CREATE AND MAINTAIN A SOCIALLY AND EMOTIONALLY RESPECTFUL EARLY LEARNING AND CARE ENVIRONMENT.

2 3. IMPLEMENT TEACHING STRATEGIES SUPPORTING POSITIVE BEHAVIOR, PRO-SOCIAL PEER INTERACTION AND OVERALL SOCIAL AND EMOTIONAL COMPETENCE IN YOUNG CHILDREN.

3 4. PROVIDE INDIVIDUALIZED SOCIAL AND EMOTIONAL INTERVENTION SUPPORTS FOR CHILDREN WHO NEED THEM; INCLUDING METHODS FOR UNDERSTANDING CHILD BEHAVIOR;AND DEVELOPING, ADOPTING AND IMPLEMENTING A TEAM-BASED POSITIVE BEHAVIOR SUPPORT PLAN WITH THE INTENT TO REDUCE CHALLENGING BEHAVIOR AND PREVENT SUSPENSIONS AND EXPULSIONS.

4. ACCESS AN EARLY CHILDHOOD MENTAL HEALTH CONSULTANT OR OTHER SPECIALIST AS NEEDED.

J I. The procedure, including notification of parents or guardians, for handling children's illnesses, accidents, and injuries.

KJ. The procedures for responding to emergencies such as lost children, tornadoes, and fires.

LK. The procedure for transporting children, if applicable, including transportation arrangements and parental permission for excursions and related activities.

ML. The written policy and procedure governing field trips, television and video viewing, and special activities, including the staffs responsibility for the supervision of children.

NM. The policy PROCEDURE on children's safety related to riding in a vehicle, seating, supervision, and emergency procedures on the road.

ON. The procedure for releasing children from the center only to persons for whom the center has written authorization.

PO. The procedures followed when a child is picked up from the center after the center is closed or not picked up at all, and to ensure that all children are picked up before the staff leave for the day.

QP. The procedure for caring for children who arrive late to the center and their class/group is away from the center on a field trip or excursion.

RQ. The procedure for storing and administering children's medicines and delegation of medication administration in compliance with Section 12-38-132, C.R.S., of the “Nurse Practice Act”.

SR. The procedure concerning children's personal belongings and money.

TS. The policy concerning Meals and snacks.

UT. The policy on Diapering and toilet training.

VU. The policy regarding Visitors to the center.

WV. The policy on Parent and staff conferences to inform the parents or guardians of the child's behavior, progress, and social and physical needs.

XW. The procedure for filing a complaint about child care (see 7.701.5, General Rules for Child Care Facilities).

YX. The policy regarding the Reporting of child abuse (see 7.701.5, General Rules for Child Care Facilities).

ZY. The policy regarding Notification when child care service is withdrawn and when parents or guardians withdraw their children from the center.

Z. HOW DECISIONS ARE MADE AND WHAT STEPS ARE TAKEN PRIOR TO THE SUSPENSION, EXPULSION OR REQUEST TO PARENTS OR GUARDIANS TO WITHDRAW A CHILD FROM CARE DUE TO CONCERNS ABOUT THE CHILD’S BEHAVIORAL ISSUES. THESE PROCEDURES MUST BE CONSISTENT WITH THE CENTER’S POLICY ON GUIDANCE, POSITIVE INSTRUCTION, DISCIPLINE AND CONSEQUENCES, AND INCLUDE DOCUMENTATION OF THE STEPS TAKEN TO UNDERSTAND AND RESPOND TO CHALLENGING BEHAVIOR.

7.702.42 7.702.32 Communication, Emergency, and Security Procedures [Rev. eff. 4/1/15]

A. The center must notify the parents or guardians in writing of significant changes in its services, policies, or procedures so that they can decide whether the center continues to meet the needs of the child.

B. For security purposes, a sign-in/sign-out sheet or other mechanism for parents and guardians must be maintained daily by the center. It must include, for each child in care, the date, the child's name, the time when the child arrived at and left the center, and the parent or guardian's signature or other identifier.

C. The center must have a working telephone with the number available to the public. Emergency telephone numbers of the following must be posted near the telephone: a 911 notice, where 911 is available, or rescue unit if 911 isn't available; a hospital or emergency medical clinic; the local fire, police, and health departments; and Rocky Mountain Poison Control. The telephone must be available to staff at all times that the center is in operation.

D. The center must be able to provide emergency transportation to a health care facility at all times.

E. The director of the center or the director's delegated substitute must have a means for determining at all times who is present at the center.

F. A written policy regarding visitors to the center must be posted and a record maintained daily by the center that includes at a minimum the visitor's name and address and the purpose of the visit. At least one piece of identification must be inspected for individuals who are strangers to personnel at the center.

G. The center must release the child only to the adult(s) for whom written authorization has been given and is maintained in the child's record (see 7.702.101). In an emergency, the child may also be released to an adult for whom the child's parent or guardian has given verbal authorization. If the staff member who releases the child does not know the adult, identification must be required to assure that the adult is authorized to pick up the child.

H. The center must have a procedure for dealing with individuals not authorized by the parent or guardian of a child who attempts to have the child released to them.

I. The center must have a written emergency procedure to report communicable illnesses to the local health department pursuant to regulations of the Colorado Department of Public Health and Environment.

J. The center must have a written procedure for closing the center at the end of the day to ensure that all children are picked up.

7.702.43 7.702.33 Personnel Policies, Orientation, and Staff Development [Rev. eff. 6/1/12]

A. The duties and responsibilities of each staff position and the lines of authority and responsibility within the center must be in writing.

B. At the time of employment, staff members must be informed of their duties and assigned a supervisor.

C. Prior to working with children, the EACH staff member must read and be instructed about the policies and procedures of the center, including those related to hygiene, sanitation, food preparation practices, proper supervision of children, and reporting of child abuse. Staff members must sign a statement indicating that they have read and understand the center's policies and procedures.

D. STAFF HIRED PRIOR TO SEPTEMBER 29, 2016, MUST COMPLETE A DEPARTMENT APPROVED PRESERVICE TRAINING BY SEPTEMBER 30, 2016. ALL STAFF HIRED AFTER SEPTEMBER 30, 2016 MUST COMPLETE A DEPARTMENT APPROVED PRESERVICE TRAINING PRIOR TO WORKING WITH CHILDREN. THE TRAINING MUST INCLUDE:

1. 
   BUILDING AND PHYSICAL PREMISES SAFETY, INCLUDING IDENTIFICATION OF AND PROTECTION FROM HAZARDS THAT CAN CAUSE BODILY INJURY SUCH AS ELECTRICAL HAZARDS, BODIES OF WATER, AND VEHICULAR TRAFFIC.
   

2. HANDLING AND STORAGE OF HAZARDOUS MATERIALS AND THE APPROPRIATE DISPOSAL OF BIO CONTAMINANTS.

E. EACH STAFF MEMBER WORKING WITH INFANTS UNDER TWELVE (12) MONTHS OLD MUST COMPLETE A DEPARTMENT APPROVED SAFE SLEEP TRAINING BY DECEMBER 31, 2015. EACH STAFF MEMBER HIRED AFTER DECEMBER 31, 2015, MUST COMPLETE A DEPARTMENT APPROVED SAFE SLEEP TRAINING PRIOR TO WORKING WITH INFANTS UNDER TWELVE (12) MONTHS OLD.

F. EACH STAFF MEMBER WORKING WITH CHILDREN UNDER THREE (3) YEARS OF AGE MUST COMPLETE A DEPARTMENT APPROVED PREVENTION OF SHAKEN BABY/ABUSIVE HEAD TRAUMA TRAINING BY SEPTEMBER 310, 2016. EACH STAFF MEMBER HIRED AFTER SEPTEMBER 310, 2016, MUST COMPLETE A DEPARTMENT APPROVED ABUSIVE HEAD TRAUMA TRAINING PRIOR TO WORKING WITH CHILDREN UNDER THREE (3) YEARS OF AGE.

FG. All staff must complete at least 1-1/2 hours of training in universal precautions within 3 months of employment at the center and at least every 3 years thereafter A DEPARTMENT APPROVED STANDARD PRECAUTIONS TRAINING THAT MEETS CURRENT OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION (OSHA) REQUIREMENTS PRIOR TO WORKING WITH CHILDREN. THIS TRAINING MUST BE RENEWED ANNUALLY AND COUNTS TOWARDS ONGOING TRAINING REQUIREMENTS. Renewal of universal precautions training may be part of the first-aid training.

H. WITHIN THIRTY (30) CALENDAR DAYS OF EMPLOYMENT AND ANNUALLY, ALL EMPLOYEES AND REGULAR VOLUNTEERS MUST BE TRAINED USING A DEPARTMENT APPROVED TRAINING ABOUT CHILD ABUSE PREVENTION, INCLUDING COMMON SYMPTOMS AND SIGNS OF CHILD ABUSE.

I. WITHIN THIRTY (30) CALENDAR DAYS OF EMPLOYMENT AND ANNUALLY ALL EMPLOYEES AND REGULAR VOLUNTEERS MUST BE TRAINED ANNUALLYUSING A DEPARTMENT APPROVED TRAINING ON HOW TO REPORT, WHERE TO REPORT AND WHEN TO REPORT SUSPECTED OR KNOWN CHILD ABUSE OR NEGLECT.

DJ. The child care center must ensure that all staff are familiar with the licensing rules governing child care centers within 90 THIRTY (30) CALENDAR days of employment at the center.

EK. The center must have a staff development plan that includes a minimum of fifteen (15) clock hours of training each year for all staff. The training must relate to one or more of the following areas-child growth and development, healthy and safe environment, developmentally appropriate practices, guidance, family relationships, cultural and individual diversity, and professionalism. ALL STAFF WHO WORK WITH CHILDREN MUST COMPLETE A MINIMUM OF FIFTEEN (15) CLOCK HOURS OF TRAINING EACH YEAR BEGINNING WITH THE START DATE OF THE EMPLOYEE. AT LEAST THREE (3) CLOCK HOURS PER YEAR MUST BE IN THE FOCUS OF SOCIAL EMOTIONAL DEVELOPMENT.

L. ONGOING TRAINING AND COURSES SHALL DEMONSTRATE A DIRECT CONNECTION TO ONE OR MORE OF THE FOLLOWING COMPETENCY AREAS:

1. CHILD GROWTH AND DEVELOPMENT, AND LEARNING OR COURSES THAT ALIGN WITH THE COMPETENCY DOMAINS OF CHILD GROWTH AND DEVELOPMENT;

2. CHILD OBSERVATION AND ASSESSMENT;

3. FAMILY AND COMMUNITY PARTNERSHIP;

4. GUIDANCE;

5. HEALTH, SAFETY AND NUTRITION;

6. PROFESSIONAL DEVELOPMENT AND LEADERSHIP;

7. PROGRAM PLANNING AND DEVELOPMENT;

8. TEACHING PRACTICES;

a. EACH ONE (1) SEMESTER CREDIT HOUR COURSE WITH A DIRECT CONNECTION TO THE COMPETENCY AREA LISTED IN SECTION 7.702.43, L, 1-8, TAKEN AT A REGIONALLY ACCREDITED COLLEGE OR UNIVERSITY SHALL COUNT AS FIFTEEN (15) CLOCK HOURS OF ONGOING TRAINING.

b. TRAINING HOURS COMPLETED CAN ONLY BE COUNTED DURING THE YEAR TAKEN AND CANNOT BE CARRIED OVER.

M. TO BE COUNTED FOR ONGOING TRAINING, THE TRAINING CERTIFICATE MUST HAVE DOCUMENTATION THAT INCLUDES:

1. THE TITLE OF THE TRAINING; AND,

2. THE COMPETENCY DOMAIN; AND,

3. THE DATE AND CLOCK HOURS OF THE TRAINING; AND,

4. THE NAME OR SIGNATURE, OR OTHER APPROVED METHOD OF VERIFYING THE IDENTITY OF TRAINER OR ENTITY; AND,

5. EXPIRATION OF TRAINING IF APPLICABLE; AND,

6. CONNECTION TO SOCIAL EMOTIONAL FOCUS IF APPLICABLE.

N. WITHIN THIRTY (30) CALENDAR DAYS OF EMPLOYMENT AND ANNUALLY ALL STAFF RESPONSIBLE FOR COLLECTION, REVIEW AND MAINTENANCE OF THE CHILD IMMUNIZATIONS RECORDS MUST COMPLETE THE DEPARTMENT APPROVED COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT (CDPHE) IMMUNIZATION COURSE.

GO. If volunteers are used by the center, there must be a clearly established policy in regard to their function, orientation, and supervision. See also Section 7.702.54,D E.

P. WITHIN THIRTY (30) DAYS OF THE LAST DAY OF EMPLOYMENT, STAFF MEMBERS MUST BE PROVIDED A LETTER VERIFYING THEIR EXPERIENCE AT THE CENTER. THE LETTER MUST CONTAIN THE CENTER’S ADDRESS, PHONE NUMBER AND LICENSE NUMBER, THE EMPLOYEE’S START AND END DATE AND THE TOTAL NUMBER OF HOURS WORKED WITH CHILDREN. HOURS WORKED WITH INFANTS AND TODDLERS MUST BE DOCUMENTED SEPARATELY FROM HOURS WORKED WITH OTHER AGE GROUPS. THE LETTER MUST BE SIGNED BY A DIRECTOR, OWNER OR HUMAN RESOURCES AGENT OF THE CENTER OR GOVERNING BODY.