Assistant Superintendent Barry Carter and Deputy Assistant Superintendent Karen Powell of the Louisiana Department of Education on July 17 reviewed proposed revisions to state licensing bulletins designed to implement Act 409 of the 2025 regular legislative session, which requires licensure of many nonpublic prekindergarten programs and adds other child‑safety and reporting obligations.
Carter told the Early Childhood Care and Education Advisory Council that the department is preparing training and outreach for what he said are 254 nonpublic pre‑K programs that will need to apply for licensure and that “the deadline is 01/01/2026 for the new licensures to be put in, okay? So for them to apply for the license by 01/01/2026.”
Powell said most of the bulletin edits are “about complying with and aligning with Act 409” and that the draft changes add or revise definitions, licensure rules, inspection and renewal timing, and several safety and documentation requirements. She told the council the department plans webinars, new‑user guidance for EdLink, and repeated training opportunities through December to help providers make the transition.
Council discussion focused on several implementation details that the department flagged as areas of change or concern. Powell said the revised definition of “early learning center” will explicitly include nonpublic school pre‑K programs so the bulletin can apply consistent requirements across centers and school‑based programs. She added the definition was drafted to exclude registered family day care homes when the law requires that distinction.
On security, Powell described a recent incident in which an unauthorized adult ran through a classroom and police entered to remove the person. She said that experience and provider feedback motivated a proposed requirement that license spaces maintain “a secured single point of entry into the licensed space to provide for supervision of ingress and egress during operating hours or when children are present.” Council members warned the proposed wording could create unintended consequences for some providers. Council member Jonathan Pierce asked for clarification; one provider said buildings with multiple classroom doors or leased spaces might face costly construction or landlord refusals to create a single entry. Council member Tafta Miller cautioned about fire marshal rules and egress requirements and noted that doors with panic bars can be secured to allow emergency exit while restricting ingress. Powell responded that the department intends the requirement to address monitored single‑point entry (supervision of ingress/egress) and not necessarily locked doors; she and Carter agreed to refine the proposed language and to continue stakeholder discussion.
Powell also reviewed a draft provision clarifying that a license is issued to a specific location and that care provided at that location must comply with the license terms year‑round, including before/after care and summer programs. Council members asked whether that language would prevent a licensed child care center from having seasonal unlicensed space for school‑age camps; a department staff member explained the draft clarifies that if a space is used at any time during the year for licensed‑age children it is treated as licensed and must meet license standards, while school campuses can have clearly separated licensed and unlicensed wings. The department said it will provide more examples and guidance in communications and webinars.
On renewals, Powell said the bulletin will clarify the difference between a license’s expiration date and the renewal application submission deadline, and the department recommended using its online system to submit renewal applications “prior to the first day of the month in which the current license expires.” Powell gave an example: if a license expires July 31, the renewal application should be submitted no later than June 30. The department said late submissions disrupt prospective payment processing and can cause payment delays for providers.
The review included several safety‑and‑compliance provisions prompted by recent incidents. Powell described a center that was suspended after public health officials traced a child’s elevated blood‑lead level to the site; in that case the department and Louisiana Department of Health asked the department to close the site. Powell said the draft would allow the department to post notice of a suspension in “special circumstances” where public notification is necessary for child safety; she said the department does not expect to post suspension notices routinely in disasters where closures are evident.
The department also proposed technical changes after finding instances of fraudulent or short‑term insurance policies submitted to meet inspection requirements. Powell said the bulletin will propose that the insurance policy name the department as a certificate holder so LDOE receives notice if a provider’s policy is canceled. A commenter suggested adding a requirement that insurers notify certificate holders within 30 days of substantive policy changes; department staff said they would consult legal staff about the precise language.
On staff conduct and records, Powell said the bulletin will require documentation that staff were told not to use personal devices to photograph or post children on social media; she framed the change as a protective step and said providers had urged the department to avoid making the issue a deficiency when it is hard for centers to police staff private accounts. The council suggested adding the item to orientation materials and annual review procedures.
Powell and Carter emphasized the department will publish guidance, FAQs and monthly webinars to explain new deadlines and requirements, and to help providers with fire marshal and inspection questions. Several council members asked the department to rework wording that might impose unfunded construction mandates or collide with fire‑safety rules. Powell said the department will continue stakeholder engagement and legal consultation before finalizing bulletin language.
No formal motions or votes were taken; council members provided feedback and the department recorded suggested edits for further revision.