Day care rules: Screen time a touchy subjectBy DAVE SOLOMON
State House Bureau
July 16. 2017 12:29AM
CONCORD - Don't tell us when to turn it off.
That was the resounding opinion of parents and day care operators on proposed rules governing screen time for children, the New Hampshire Union Leader found after reviewing more than 100 comments submitted to state regulators.
The Department of Health and Human Services is finalizing new rules as part of a massive overhaul of state regulations for licensed child care centers.
The proposed rules govern the jewelry children can wear, the temperatures at which they should be outdoors, the SPF for sunscreen to be applied, the conditions under which children can be expelled and new ID requirements for employees, among other things.
But one of the most commented-on proposals in the 104 pages of regulations involves restrictions on screen time, with many suggesting that the proposed rule restricting screen time to 120 minutes every two weeks, or an hour a week on average, is well-intended but ill-conceived.
Many of the commenters say the rules ignore "the transformative impact technology can have on learning."
"I know of one day care center near us that does a daily afternoon movie, so I understand the desire to rein in certain types of screen time," wrote Allison Welch. "I'd hate to see that effort come at the expense of any program that embraces digital tools as part of a well-developed curriculum."
Much of the feedback on the rule suggests that day care center owners and parents understand the motivation, but think the approach is wrong.
"Typically, educational computer games are an extension of what is being taught in the classroom. It gives the children the autonomy to practice and work on their alphabet, Spanish, math, etc., on their own," according to commenter Amanda Young. "Technology is everywhere when they are older - in elementary classrooms, college, their career. Using computers as a teaching avenue will just make the child more capable in their future. With that said, I am in favor of limiting passive screen time (shows, movies, commercials) in preschool settings as there is scientifically no benefit to this."
Critical of restrictions
The comments were provided by DHHS to the New Hampshire Union Leader with identifying information redacted. Several responses critical of the restrictions on screen time came from the Goddard School faculty and parents.
"I would implore you and your team to look at the evolution of technology in the last 10 years; while it could be argued that some of it has made us stop looking around at the world and looking down at our screens, technology implemented in a controlled, curriculum-based way has opened a world of opportunity and discovery for students of all ages," wrote Anthony Baldini, who with his wife, Samantha, owns and operates Goddard preschools in Derry and Nashua.
Many of those weighing in urged the DHHS to distinguish between "passive" screen time and "educational" screen time, if there is to be any regulation on the matter at all.
"We cannot expect our children in high quality learning centers to sit on the sidelines and not reap the benefits of technology in the classroom," wrote Kim Mattucci, director of Kid's Creative Cove Learning Center & Childcare in Merrimack.
"Yes, screen time should be limited when it comes to movies and TV, but technology is different. Being able to show children the life cycle of a caterpillar in time lapse or visit a foreign land or Skype with another class across the country are important 21st-century skills. Limiting our pre-k and kindergarten children to just 12 minutes a day would not do justice to teaching these skills."
Two years in the making
Much of the input on the new regulations, which have been in the works since 2015, is positive and commends the DHHS staff for the time and effort put into the project. Many of the changes are needed to comply with conditions in federal child care block grants that subsidize child care for low-income families. Those grants totaled $16.5 million in 2017.
Some observations, however, are more colorful than others.
"The limiting of education-based technology to 12 minutes a day is unfounded and idiotic. I do not support this bill," wrote Jillian Thiele, who identified herself as a public school teacher and parent. "Working in education for over 14 years, I see this as nothing but a detriment to our students' lives and futures. Please stop micromanaging our children's opportunities in the classroom."
Other proposals not well-received by those who chose to file comments include a requirement that children older than 18 months must go outside when the temperatures are above 15 degrees Fahrenheit, or below 90 degrees Fahrenheit.
"I can't imagine taking the little ones out in 20 degree temperatures," wrote Cathy Shore of the Wee Care Learning Center in Windham. "Does this also include rain, hail and sleet? I take them out whenever it is reasonable to do so. I think you should respect that I am qualified to make that decision. I come in if the children say they are too cold."
The appeal to allow day care owners and operators to use their own common sense and collective experience resonates throughout the voluminous responses, whether it's about allowing children to wear necklaces, or specifying how to wash their hands.
"I think this is really micro-managing," wrote Shore. "Infants need to have clean hands before they eat . enough said. Some of the older kids can use a sink . let us use our experience and judgment."
Concerns about costs
Also of concern are the costs associated with new training requirements and identification cards for employees. Many of the day care center operators took advantage of the request for feedback from the state to share their concerns about the long-term viability of the industry, and the narrowing of options for parents.
"My concern is that there are so many rules (most overlapping) that no one could run a child care program without stepping on a rule," according to JoAnn Kasper, director of the Little Buttercups Nursery School in Weare.
JoAnn O'Shaughnessy, owner of the Manchester Child Development Center, has owned and operated child care centers in the Queen City for more than 40 years, and has seen rules and regulations grow over time.
"In the last few years, it's become a great concern to me that many of these rules and regulations are threatening our business," she testified at a DHHS hearing. "I'm afraid we will see child care centers closing because of families' inability to pay the necessary increases. There is already a well-known shortage of child care centers with sufficient capacity. What's going to happen in the North Country or in the western part of the state when these regulations come out and centers can't afford to stay open?"
DHHS has notified the Joint Legislative Committee on Administrative Rules that it expects to file the rules as a final proposal for JLCAR to consider at its Aug. 17 meeting. The deadline to file the materials for that meeting is Aug. 3.
Jake Leon, DHHS spokesman, said the Child Care Licensing Unit anticipates making some changes based on the comments, and after consulting with the governor, will submit the final proposal in August.
"The department has received feedback from providers and other stakeholders and continues to work internally on new licensing rules," he said. "Not until the department's internal work is complete will a final rule be submitted for JLCAR's consideration."