How to provide feedback on proposed standards for daycare centers

A childcare modernization project is underway at the Minnesota Department of Human Services (DHS).

In 2021, legislators passed a law requiring the DHS to revise standards for licensed daycare centers. The DHS has released a draft of the proposed standards and is asking for public input. After the comment period is over, the DHS will revise the rules further and send a draft to the legislature for final action in the 2025 session.

Generally, licensed daycare centers are already stringently regulated in Minnesota. So, these proposed standards are a bit of an improvement. As I wrote previously, for instance, under the proposed standards

someone with a high school diploma will no longer be required to become an assistant teacher first. Instead, they can directly become a teacher with two years of experience and some credits. Similarly, someone with a bachelor’s degree would need about 3 months of experience instead of 6 months. Previously, someone with a Child Development Associate (CDA) credential needed 1,560 hours or 9 months hours of experience to become a teacher. New proposed rules would require 6 months or 1,040 hours of experience.

These proposals, however, do not go far enough to address the shortage of qualified staff.

While post-secondary credits are reduced for people with high school diplomas, proposed standards would require that half of those credits be in child development. This restriction would still limit the pool of applicants. While family childcare providers can transition and become teachers at daycare centers, they would need 6-semester post-secondary credits.

Minnesota’s neighboring states have much more affordable childcare in part because they have less stringent rules.

In South Dakota, North Dakota, and Iowa, staff dealing directly with children must only meet age and training requirements. Sure, child-care workers in North Dakota operate under supervision, but those supervisors only need to have a school diploma and one year of child-care experience. While Wisconsin does require child-care workers to have college credits, it only requires two courses for teachers and one course for assistant teachers. Moreover, a center can hire an assistant teacher with no prior experience, and a teacher is only required to have 320 hours of experience, not thousands.

So, even with the current proposed changes, Minnesota would still have some of the most burdensome rules for childcare compared to its neighbors. It does not help that the DHS is also proposing some new rules that will complicate childcare and raise costs for centers.

Under new proposed standards, centers must do the following, among other things,

1. check on sleeping infants every 15 minutes,
2. Set indoor temperatures between 68 and 82 degrees,
3. test their water for contaminants,
4. cover bare soil or test it for lead,
5. document problematic behavior, including steps taken to curb behavior,
6. and notify parents if pesticides will be used

How to provide comments

Minnesota is one of the most expensive states for center-based childcare and that is mainly due to regulation.

Figure 1: Annual cost of center-based infant care as a percent of median household income

While these proposals would improve the hiring process for daycare workers, they do not go far enough to address Minnesota’s stringent requirements. Moreover, newly introduced rules in other areas will have the opposite effect of what the childcare industry needs; lower prices and less complexity.

Tell the DHS that instead of introducing new rules, they should focus on further loosening existing hiring requirements. This will make it easier for daycare centers to find qualified workers, and improve access to childcare for parents.

You can:

1. Send comments to this email: [email protected] or
2. Take an online survey here (until July 31)