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Regulators recommend licensure for Vermont early childhood educators after Sunrise review
Summary
The Office of Professional Regulation recommended creating an individual licensure system for early childhood educators after a Sunrise review, proposing transitional licensing, a new board, and coordination with Agency of Education and Child Development Division; funding and rollout timing remain unresolved.
The Office of Professional Regulation recommended that Vermont require individual licensure for early childhood educators working in programs regulated by the Child Development Division, saying a Sunrise review found a risk of public harm and that licensure is the appropriate regulatory response.
In a presentation to a legislative committee, Lauren Guterberts, Deputy Secretary of State, said, "If we decide that there is public harm ... spoiler alert, we did decide there is public harm here," and that the state must "assess what level of regulation we should impose." Jen Colon, General Counsel for the Office of Professional Regulation, summarized the Sunrise finding: "We determined that regulation is appropriate in the field and that licensure is the appropriate form of regulation."
The Sunrise review, issued in January and described to the committee, included stakeholder outreach (more than 100 participants in public hearings), input from Vermont AEYC, the Agency of Education, Building Bright Futures, the Child Development Division and other partners, and a 72-page report with appended public comments. OPR staff said most stakeholders supported professionalizing the workforce through individual credentials tied to qualifications.
What the proposal would do: OPR recommended mandatory licensure for lead and assistant teachers working with children ages 0–8 in settings regulated by the Child Development Division (family child care homes and center-based programs). The proposal calls for three tiered credentials (ECE 1, ECE 2, ECE 3), a transitional or legacy pathway for existing family child care providers, and a stand-alone board under OPR to oversee the profession. OPR told the committee it would create a board of roughly 11 members and conduct rulemaking alongside the Agency of Education and the Child Development Division to avoid duplicative requirements.
On funding and fees, OPR staff said licensure would normally be funded by individual licensing fees, but the Senate bill had sought an appropriation from the Childhood Tax Fund to subsidize fees for the first two licensure cycles (roughly the first four years). "The way the current bill is, this will need to be adjusted next year," Guterberts said, noting the proposal would delay issuing licenses until the agency completes rulemaking and outreach. OPR indicated an anticipated earliest issuance window in 2027 with a possible later start in 2028 to allow adequate preparation.
Committee members raised workforce concerns. Representative McGill and others asked whether long‑time providers might retire rather than meet new qualifications; OPR responded the bill includes a transitional license allowing current practitioners multiple years to obtain required qualifications (discussion referenced 6–8 year transition windows as drafted on the Senate side) and a family child care provider track intended to avoid losing existing providers. OPR said it had built in prior‑learning assessment options through community college programs to help experienced educators convert experience to college credit.
Several members asked about overlap with the Agency of Education's educator license used for universal prekindergarten. OPR and committee members said the proposal would not change the Agency of Education requirement for universal pre-K; instead the Senate draft would require a standardized disclosure to families explaining the different credentials (Agency of Education license for universal pre-K, ECE 1–3, family childcare provider) and how to file complaints to both agencies. "This bill does not change that requirement at all," Guterberts said, referring to the AOE requirement for individuals providing universal pre-K.
OPR described enforcement and oversight functions it would carry out, including licensing, complaints investigation and prosecution. The office emphasized that individual licensure would create portability and public transparency about a practitioner’s credentials and complaint history, information not currently available at the individual level in the Child Development Division’s facility‑focused system.
Topics left unresolved included an exact timeline for startup, the scope of any initial fee subsidy, and the final design of transitional pathways and competency standards. Several members suggested building statutory reporting requirements or a review back to the legislature after several years of implementation; OPR said it would welcome a report-back requirement and anticipated useful data after five years of regulation.
The committee agreed to begin formal policy work on the issue in January and to continue discussions about funding, workforce supports, and interagency coordination.
For readers: the Sunrise review referenced Title 26, Chapter 57 (Sunrise review statute), the state’s Act 76 financing work and a RAND Corporation financing study that influenced assumptions about workforce qualifications and cost estimates. The Senate vehicle noted in testimony is S119, and the Childhood Tax Fund was discussed as a potential source for initial subsidies.
