OPR tells Senate committee S.119 should license early childhood educators in nonpublic settings

The Vermont Senate Committee on Government Operations heard March 2025 that the Office of Professional Regulation (OPR) supports S.119, a bill to license early childhood educators working with children ages 0 to 8 in nonpublic settings, and recommends a three-tier credentialing system (ECE 1–3) with phased implementation and transitional measures for current practitioners.

OPR General Counsel Jennifer Cohen told the committee that OPR “does fully support S.119 and the licensure of early childhood educators as set forth in the proposed legislation before you,” and that the office reached that view after conducting a Sunrise review to test whether regulation is needed “because OPR is a public protection agency.” The Sunrise process applied the statutory criteria in Chapter 57 of Title 26, Cohen said, and concluded that licensure meets the public-protection tests in law.

The Sunrise review recommended individual licensure for lead educators in family childcare homes and center-based preschool programs regulated by the Child Development Division (CDD). OPR said a uniform licensure system would create clearer preparation pathways, align practice standards with public school expectations, and provide individual accountability through OPR’s public disciplinary processes. Cohen said those elements would “ensure public protection by establishing streamlined preparation pathways” and reduce harms associated with low-quality early care and education.

Committee members pressed OPR staff on how the proposed licensure would interact with existing regulation. Jennifer Cohen and OPR acting director Mike Warren said the legislation would not immediately change CDD facility regulations or automatic staff-to-child ratios; rather, OPR’s licensure would provide portable, individual credentials that facilities could use to verify qualifications. Cohen said the Community College of Vermont’s Northern Lights program currently tracks coursework and that a public license lookup at OPR would make vetting applicants easier for hiring facilities.

Members also asked whether licensure would raise costs and whether it would affect wages. OPR staff said licensure generally correlates with higher wages because it professionalizes practice through education and competency standards. Cohen noted the state has previously studied costs: a RAND financial analysis completed around 2023 modeled increased educator requirements and projected associated costs, and OPR said those estimates have informed prior policymaking.

Several senators sought clarification on why OPR, rather than the Agency of Education (AOE) or CDD, would administer licensure. Cohen and other witnesses pointed to a 2022 systems analysis (the transcript cites a final report on Vermont child care and early education systems) that described the current mixed-delivery system as structurally complex and recommended governance changes. OPR said it has worked with AOE and CDD during the Sunrise review and would administer licensure through a profession-specific board, as OPR does for other licensed fields.

Committee discussion noted the bill’s reliance on phased implementation and transitional licensing to allow existing educators time to meet new requirements. Senators asked for more detail on classroom ratios and how CDD might streamline regulations later if individual licensure is established; OPR said those are implementation questions for subsequent rulemaking or for CDD to address in its regulations.

The committee did not take a final vote. Chair Senator Brian Collamore said the committee will continue the matter at upcoming meetings next week and beyond, and OPR pledged to return with staff to assist as the committee drafts or revises bill language.

Less critical details: OPR recommended licensure only for lead educators in nonpublic settings, not for public-school teachers who already work under AOE standards; members repeatedly requested clearer cross-agency implementation plans and information on how licensure would affect facility-level regulation and staff-to-child ratios.