Frequently Asked Questions about VT Center Based Child Care and Preschool Programs Regulations

This page is organized in same way of the Child Care Licensing Regulations: Center Based Child Care and Preschool Programs. If you have a question about a regulation, look for the section the regulation is in, and then look for the regulation.

Section 1 – Introduction
Section 2 – General Provisions

Section 3 – Administration and Operation

Section 4 – Parent/Family Engagement in Their Children’s Care
Section 5 – Health, Safety and Nutrition

Section 6 – Teaching and Learning
Section 7 – Program Personnel/Staffing  

Appendix A – Signs and Symptoms of Illness Chart
Appendix B – Regarding Cribs

Section 1 – Introduction

Section 2 – General Provisions

We currently have two separate buildings joined by a playground with two separate licenses. How do we move from two separate licenses to a single license for all buildings under the new regulations? 

This question relates to CBCCPP rule  After 9/1/2016, you may contact your Licenser and work with your Licenser to determine the process for condensing to one license. 

Now that I have done my water testing, what will I need to do for water testing in the future?

If your water system has a permit, then you will only need to do a flush lead water test each year if the initial test didn't pass (CBCCPP rule  For more information on passing the first draw lead water test required after 9/1/2016, go to page 23 of the CBCCPP Guidance Manual (  For more information on doing the flush sample lead water test, go to page 24 of the CBCCPP Guidance Manual.

If your water system doesn't have a permit, then you may have two things required for future water testing:

  • Once every 6 years, you will need to do the water testing required in CBCCPP rule  For more information on doing this water test, also go to page 24 of the CBCCPP Guidance Manual.
  • If your first draw lead water test required after 9/1/2016 didn't pass, then you will also need to do a flush lead water test each year (CBCCPP rule  For more information, go to pages 23 and 24 of the CBCCPP Guidance Manual.

You may also find "Appendix II Water System Testing and Safety Guidelines" in your CBCCPP Guidance Manual ( helpful.

Section 3 – Administration and Operation

My school system has merged this year.  What do I need to do?

The Division has handled many of these over the last 2 years.  We have developed a streamlined way for you to send new governing body documentation to us, a memo from July 2017 describes this process.  Our licensing supervisors will review the documentation for accuracy and completeness.  Once we have everything needed, we will enter the information into your program's BFIS account.  You will receive a new license certificate.  Please be sure to print this and post it as required.  Please know that financial payments may not be processed until the required documentation is received and processed.

For CBCCPP rule (staffing schedule), am I required to document when the planned schedule has been changed during the week?

Yes, the rule requires you document the exact days, hours and the group with whom each staff member worked.  If on any given day, you need to modify the schedule, you will want to note the change of assignment on the staff schedule.  Feel free to use the sample form from the CDD website titled Staffing Plan ( or create your own form. 

Section 4 – Parent/Family Engagement in Their Children’s Care


Section 5 – Health, Safety and Nutrition

 We currently do not have documentation of our children’s well-care exams so do they need to have a health exam within 45 days from 9/1/2016?

This questions relates to CBCCPP rule 5.1.2. No, children do not need to have a new exam.  Or can they get a print out from the doctor about their last exam – regardless of when that was?  Documentation from an exam within the past year will be sufficient to meet this licensing rule.  The Division will be providing a sample document that may be used.  It is not required to use any particular form.  What is important is whether there is medicine or health information of which you should be aware while caring for a child.  This may be as simple as a one or two sentence statement by the child’s doctor at the foot of a current immunization record that includes the date of the last well-care exam and the doctor’s signature.  Compliance will be expected to have been achieved no later than 9/1/2017 for all children enrolled. 

Should I be contacting children’s doctors’ offices directly for copies of health exams? 

No, parents should be contacting their child’s doctor’s office and request the information be sent to the parent to bring to you or be sent directly to you.

What immunizations should a child have to participate in child care? 

This question relates to CBCCPP rule 5.1.3.  Vermont laws exist regarding immunization requirements and when children would be required by law to be excluded from child care and/or school.  If you have questions about what is required and options for families, please contact the Vermont Department Health Immunization program.

Are pull ups considered diapers? 

This question relates to CBCCPP rule 5.2.3.  Yes, a pull up is considered a type of diaper and children should be changed when they are wet or have had a bowel movement/diarrhea.  Should a child in a pull up need to be changed laying down, diaper changing procedures would apply.  If a staff member is able to change a diaper or pull up on a child while the child is standing, especially if the child is bigger or is learning to use the toilet, then proper disposal of the soiled pull up/diaper and handwashing should still occur.

Can the hand washing sink be used for hand washing after entering the room or after wiping a nose and also be used for getting a drink of water or food prep? 

This question relates to CBCCPP rule  Children should be served water from a sink designed for food preparation.  Handwashing after handling bodily fluids should occur in a sink designed for handwashing after toileting.  This protects against cross contamination.

Section 6 – Teaching and Learning


Section 7 – Program Personnel/Staffing

How long do I have to meet the qualification requirements?

It has been over 15 years since the regulations have been updated.  A regulated child care program is a business that supports children’s learning, growth, and development.  Research shows that education impacts the quality of care and education adults provide children.  The Child Development Division made some tough decisions about how to increase the minimum standard for qualifications appropriately. 

All providers and staff are expected to meet the qualifications despite how many years someone has been in the profession. CBCCPP staff have two years to meet qualifications.  If more time is needed at the end of this time, a variance may be submitted.  Solid variance requests will explain how come you need more time, how much time you will need, and how you will use this extra time.

The place to begin thinking about a plan for meeting qualifications and if you have questions about options that will help support compliance with qualifications, please refer to the Child Development Division’s website ( and/or reach out to Vermont Northern Lights.  Now is also the best time to send up-to-date resumes, high school diplomas, college transcripts, and degree information to Northern Lights using their Professional Development Verification Cover Sheet (  Find Northern Lights staff emails and other information on their website  As you learn about the many options available to use to achieve compliance with qualifications, you may have questions about money available to support the cost.  Please refer to the Child Development Division’s website for grant options ( 

Whether you need to get a high school diploma, a college degree, or complete some college coursework; start with learning about how what you have done over the years will help you reach your goal.  Then develop a plan.  The Child Development Division will spend the  next two years for CBCCPP programs providing technical assistance to support compliance being achieved.  Please remember that this extra time is for staff already employed prior to 9/1/2016.  New staff hired after 9/1/2016 are required to meet the qualifications at the time of employment.

What may be used to meet annual professional development requirements?

CBCCPP Rule 7.4.3 identifies the criteria professional development needs to meet.  College courses, workshops, online training options, conferences, and etcetera are some examples of what may be used to complete annual professional development.  Most 3 credit college courses are equivalent to 45 clock hours.  When documentation of any type is sent to Vermont Northern Lights to be added to your BFIS Quality and Credential Account, use this Verification Cover Sheet ( to know what is needed for professional development to be verified and entered.  Under each type of documentation listed on the Verification Cover Sheet, it lists what is needed to be included in the documentation.  If you have questions or need assistance, please contact Vermont Northern Lights by accessing their website

Do all Center Based Programs need to employ a business manager?

  • The quick answer is no; no center based program is required to employ a business manager. 
  • CBCCPP Rule requires program directors for programs serving 13 or more children to obtain a 3 credit college course in managing an early care and education program that includes budgeting and financial management.   Information regarding courses that meet this requirement will be shared in the upcoming months.  The option to allow CBCCPP to use business managers was created based on feedback from several CBCCPP who wanted this option.
  • If a CBCCPP is opting to use a business manager in place of the director completing the course required by CBCCPP Rule, then the business manager has to have at least an associate degree in business per CBCCPP Rule 7.6.1.  To learn more about what is expected when a business manager is being used, please read the rules in section 7.6 of the regulations.  If you are using a business manager, then you will be required to follow the rules in section 7.6 of the regulations.

I have a CBCCPP license and have been trying to hire a new Teacher Associate to lead a group of children.  I found a great candidate who meets Teacher Associate qualifications under the former Early Childhood Program (ECP) Regulations but doesn't under the new CBCCPP Regulations.  Can I still hire this person?

Yes, you may…if you file a variance request, the individual passes background clearances, if the variance request clearly documents how the candidate will meet the new CBCCPP Regulations for the Teacher Associate position, and if you describe what supervision and on-site training will be in place until qualifications are met.  In this situation, you will want to submit the variance request for CBCCPP rule 1.3.3.  When approved, this candidate will have until 9/1/2018 to meet qualifications.

I have a CBCCPP license and have been trying to hire a new Teacher Associate to lead a group of children.  I have finally found a great candidate who is willing to complete the educational requirements but doesn't meet Teacher Associate qualifications under the former regulations or the current regulations.  What can I do?

You may file a variance request for CBCCPP rule requesting this candidate be identified as meeting Teacher Associate qualifications.  These variance requests will have to demonstrate the candidate's skills and abilities with working with children, include a clear outline of how the candidate will achieve compliance with qualifications under CBCCPP rule, and how the program will be able to ensure the type of care and education for the children in the classroom in which the individual would be working.  In addition, the candidate would need to pass all background clearances.  CDD will consider the strength of the candidate's skills, the plan for completing educational requirements, and the program's ability to supervise and provide on-site training.  CDD will also review the program's regulatory history.

A classroom teacher has completed the college coursework to meet staff qualifications and is now completing college coursework to meet the degree criteria (e.g. math, science, etcetera).  Does this person need to complete the 15 hours of annual professional development in addition to the college coursework?

Research shows that education of the provider makes a difference on the optimal development of children. Based on this information, CDD supports staff obtaining college degrees.  In support of obtaining appropriate degrees CDD considers the following information. If a staff member completes the college coursework to meet the staff qualifications in the CBCCPP rules in subheading 7.3.2 and has an IPDP that identifies the goal of obtaining a degree (which also meets one of the qualifications in the CBCCPP rules in subheading 7.3.2); CDD will allow the remaining college coursework hours (math, science, and etcetera) to count towards the 15 hours of professional development required in CBCCPP rule 7.4.4.  This means that the staff member will not have to take 15 hours of training in addition to college coursework.

It is important to note that college courses in math, science and etcetera by themselves do not meet professional development requirements.  It is the fact that these are needed to complete a degree program that makes this compliant with the CBCCPP rule 7.4.4 requirement.  It is also important for the staff member to obtain their college transcript that reflects completion of the college coursework and send it to NLCDC using the Professional Development Verification Cover Sheet.  (Link to the current version of this form:

While this will not result in these courses being listed in the staff member's Professional Development tab in their BFIS Quality and Credential account, the transcript will be uploaded under "Documents" and accessible to CDD Licensing Staff for confirmation of having complied with CBCCPP rule 7.4.4. 

Please carefully read the Professional Development Verification Cover Sheet and follow instructions to avoid having to resend documentation.

I need to hire for a CBCCPP Teacher Assistant position.  What do I do if I can't find someone who has already completed the Fundamentals for Early Childhood Professionals' course?

The new Trainee position is the old Teacher Assistant position.  So, you may still hire someone who is 18 years old or older and has no experience or education in early care and education.  Under these licensing regulations, this person meets Trainee qualifications if they have a high school diploma or GED.  Like the old Teacher Assistant position, this person has 1 year to complete educational training (see CBCCPP rule for specific choices).  As a Trainee, this staff member may count in ratio and may be left alone with children just like the old Teacher Assistant position because of CBCCPP rule  If you look at the definition for staff, you see that Trainee is included in the definition of staff.  CBCCPP rule clarifies that a Trainee who is 18 years of age or older may be left alone with children.  The only limitation is that CBCCPP rule requires a Trainee work in the CBCCPP as long as a staff member who meets Teacher Assistant qualifications or higher is present in the CBCCPP too.  Please notice that this rule doesn't require they be in the same room together just that they are both in the CBCCPP together.

I am the director of a CBCCPP program that has a licensed capacity over 12 children.  We do not have a business manager and I meet the director qualifications.  Do I need to do any additional education?

CBCCPP rule requires you complete a management college course.  Please work with Northern Lights at CCV to confirm whether any of the college courses on your transcript meet this requirement.  If you don't have a college course that meets this requirement, then you will need to complete this before you will be all set with meeting director qualifications.

Is it true that as the program director I have to complete a course that meets CBCCPP rule

Well, the answer depends on two things. 

  • If your program employs a Business Manager that has an Associate, Bachelor or Master's Degree in Business; then you do not need to take the course required in CBCCP rule
  • If your program has a license capacity of 12 or fewer children, then you also do not need to take the course required in CBCCPP rule

If either of the two bullets apply to your program, then you are all set and don't need to take this course.  If the two bullets don't apply, then you will want to talk with Northern Lights at CCV to confirm you haven't already taken a course that meets the criteria for the requirement in CBCCPP rule  We recommend you call or email the Professional Development Hotline (  If you do need to take a course, Northern Lights at CCV staff will be able to help you find a course to take.

Appendix A – Signs and Symptoms of Illness Chart

Appendix B – Regarding Cribs

Contact Us

Reeva Murphy, Deputy Commissioner
Child Development Division (CDD)
280 State Drive
Waterbury, VT 05671-1040
Phone: (802) 241-3110 or 1-800-649-2642
Fax: (802) 241-0846

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