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Committee backs republication of COMAR 13A.15 to expand recognition pathway for family childcare providers
Summary
The committee voted unanimously to recommend republication of proposed COMAR 13A.15 (education programs in nonpublic nursery schools) after MSDE revised the draft to address public comments about staffing and space requirements for family childcare providers.
The Education Policy Committee recommended that the full State Board republish proposed COMAR 13A.15, the regulation governing educational programs in nonpublic nursery schools, after MSDE revised the draft to address public concerns about family childcare providers’ ability to meet staffing and space requirements.
MSDE staff (Sarah Neville Morgan joined by Jenna Smith) told the committee these regulations were first drafted in 2022 to ensure family childcare providers could access blueprint publicly funded pre‑K slots. When the initial draft drew substantial public comment and scrutiny from the Administrative, Executive and Legislative Review Committee, MSDE paused and revised the proposal. After additional public comment cycles and stakeholder review (including a May session with the State Board’s early childhood subcommittee and the Office of Child Care advisory council), MSDE recommended changes responding to 24 recent comments that focused on staffing and where the program may operate within a family childcare home.
MSDE said the revisions remove requirements that would force family childcare providers to hire additional staff and clarify that the educational program does not have to take place in a specific room in the home; the provider may serve as both teacher and education program administrator. MSDE also reported that creating the regulation is not the only pathway for family childcare providers to participate in pre‑K expansion: MSDE established an application pathway and partnered with the Maryland Family Childcare Alliance and its Aspire program to provide coaching and grant‑management support for family childcare providers applying for pre‑K expansion slots.
MSDE asked the committee to grant permission to republish the revised regulation for another public‑comment period so the department can return later with a package for adoption. Doctor Lewis moved and Mr. Paul seconded a motion to recommend republication; the committee voted unanimously to recommend republishing the revised COMAR 13A.15 to the full board for review.
