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National Resource Center for Health and Safety in Child Care


8.1 IDENTIFIABLE GOVERNING BODY/ACCOUNTABLE
INDIVIDUAL
STANDARD 8.001
Governing body of the facility
The facility shall have an identifiable governing body or person with the responsibility for and authority over the operation of the center or program. The governing body shall appoint one person at the facility, or two in the case of co-directors, who is responsible for day-to-day management. The administrator for facilities licensed for more than 100 children shall have no other assigned duties. Responsibilities of the person responsible for the operation of the facility shall include, but shall not be limited to, the following:
a) Ensuring stable and continuing compliance with all applicable rules, regulations, and facility policies and procedures;
b) Developing and implementing policies that promote the achievement of quality child care;
c) Ensuring that all written policies are updated and used, as described in this chapter;
d) Hiring, firing, assigning roles, duties, and responsibility to, supervising, and evaluating personnel;
e) Providing orientation of all new parents, employees, and volunteers to the physical structure, policies, and procedures of the facility. See Orientation Training, STANDARD 1.023 through STANDARD 1.025
f) Notifying all staff, volunteers, and parents of any changes in the facility's policies and procedures;
g) Providing for continuous supervision of visitors and all non-facility personnel;
h) When problems are identified, planning for corrective action, assigning and verifying that a specific person corrects the problem by a specified date;
i) Arranging or providing repair, maintenance, supplemental education, or other services at the facility;
j) Providing or arranging for inservice training for staff and volunteers, based on the needs of the facility and qualifications and skills of staff and volunteers. See Continuing Education, STANDARD 1.029 through
STANDARD 1.036;
k) Recommending an annual budget and managing the finances of the facility;
l) Maintaining required records for staff, volunteers, and children at the facility;
m) Providing for parent involvement, including parent education. See Parent Relationships, STANDARD 2.044 through
STANDARD 2.057;
n) Reporting to the governing or advisory board on a regular basis as to the status of the facility's operation;
o) Providing oversight of research studies conducted at the facility and joint supervision of students using the facility for clinical practice.

RATIONALE: Management principles of quality improvement in any human service require identification of goals and leadership to ensure that all those involved (those with authority and experience, and those affected) participate in working toward those goals. Problem-solving approaches that are effective in other settings also work in early childhood programs. This standard describes accepted personnel management practices. General administrative management starts with the principle of "unity of command" with role definitions clearly defined and communicated along with performance expectations, and implementation of routinely scheduled evaluation of staff performance. For any organization to function effectively, lines of responsibility must be clearly delineated, with an individual who is designated to have ultimate responsibility.

COMMENTS: Management to ensure that policy is carried out includes providing staff and parents with written handbooks, training, supervising with frequent feedback, and monitoring with checklists. A national survey of model health and safety practices in facilities, a project through the American Public Health Association (APHA) and the American Academy of Pediatrics (AAP), found exemplary facilities that had effective surveillance procedures. For example, in one of these facilities, an observation checklist was developed covering every area of the facility from parking lot to classrooms. Two individuals were assigned to walk around the center noting whether all items on the checklist were in good order. The two individuals were a parent and a staff member, or the director and a staff member. When any deficiencies were found, the process included identifying a person responsible for correcting the problem and a date by which correction should occur.
A comprehensive site observation checklist is available in the print version of Model Child Care Health Policies. Copies of this publication can be purchased from the National Association for the Education of Young Children (NAEYC) or from the American Academy of Pediatrics (AAP). Contact information for the NAEYC and the AAP can be found in Appendix BB.

TYPE OF FACILITY: Center
STANDARD 8.002
written delegation of administrative authority
There shall be written delegation of administrative authority, designating the person in charge of the facility and the person(s) in charge of individual children, for all hours of operation.

RATIONALE: Caregivers are responsible for the protection of the children in care at all times. In group care, each child must be assigned to an adult to ensure individual children are supervised and individual needs are addressed. Children should not be placed in the care of unauthorized family members or other individuals.

TYPE OF FACILITY: Center
STANDARD 8.003
access to facility records
The designated person in charge shall have access to the records necessary to manage the facility and shall allow regulatory staff access to the facility and records.

RATIONALE: Those with responsibility must have access to the information required to carry out their duties and make reasonable decisions.

TYPE OF FACILITY: Center
8.2 MANAGEMENT AND HEALTH POLICIES AND STATEMENT OF SERVICES
STANDARD 8.004
content of policies
The facility shall have policies to specify how the caregiver addresses the developmental functioning and individual or special needs of children of different ages and abilities who can be served by the facility. These policies shall include, but not be limited to, the items described in STANDARD 8.005 and below:
a) Admission and Enrollment;
b) Supervision;
c) Discipline;
d) Care of Acutely Ill Children;
e) Child Health Services;
f) Use of Health Consultants
g) Health Education
h) Medications;
i) Emergency Plan;
j) Evacuation Plan, Drills, and Closings;
k) Authorized Caregivers;
l) Safety Surveillance;
m) Transportation and Field Trips;
n) Sanitation and Hygiene;
o) Food Handling, Feeding, and Nutrition;
p) Sleeping
q) Evening and Night Care Plan;
r) Smoking, Prohibited Substances, and Firearms;
s) Staff Health, Training, Benefits, and Evaluation;
t) Maintenance of the Facility and Equipment;
u) Review and Revision of Policies, Plans, and Procedures, STANDARD 8.040 and STANDARD 8.041.

The facility shall have specific strategies for implementing each policy. For centers, all of these items shall be written.

RATIONALE: Facility policies should vary according to the ages and abilities of the children enrolled to accommodate individual or special needs. Program planning should precede, not follow, the enrollment and care of children at different developmental levels and with different abilities. Neither plans nor policies affect quality unless the program has devised a way to implement the plan or policy.

TYPE OF FACILITY: Center; Large Family Child Care Home; Small Family Child Care Home
STANDARD 8.005
initial provision of written information to parents and caregivers
At enrollment, and before assumption of supervision of children by caregivers at the facility, the facility shall provide parents and caregivers with a statement of services, policies, and procedures that shall include at least the following information along with the policies listed in STANDARD 8.004:
a) The licensed capacity, child:staff ratios, ages and number of children in care. If names of children and parents are made available, parental permission for any release to others shall be obtained;
b) Services offered to children including daily activities, sleep positioning policies and arrangements, napping routines, guidance and discipline policies, diaper changing and toilet learning/training methods, child handwashing, oral health, and health education. Any special requirements for a child shall be clearly defined in writing before enrollment;
c) Hours and days of operation;
d) Admissions criteria, enrollment procedures, and daily sign-in/out policies, including forms that must be completed;
e) Policies for termination and notice by the parent or the facility;
f) Policies regarding payments of fees, deposits, and refunds;
g) Planned methods and schedules for conferences or other methods of communication between parents and staff;
h) Plan for Urgent and Emergency Medical Care or Threatening Incidents. See Emergency Procedures, STANDARD 3.048 through STANDARD 3.052; and Plan for Urgent Medical Care or Threatening Incidents, STANDARD 8.022 and STANDARD 8.023.
i) Evacuation procedures and alternate shelter arrangements for fire, natural disasters, and building emergencies. See Evacuation Plan, Drills, and Closings, STANDARD 8.024 through STANDARD 8.027;
j) Nutrition. Schedule of meals and snacks. See General Requirements, STANDARD 4.001 through STANDARD 4.010; Requirements for Special Groups or Ages of Children, STANDARD 4.011 through STANDARD 4.025 and Plans and Policies for Food Handling, Feeding, and Nutrition, STANDARD 8.035 and STANDARD 8.036;
k) Policy for food brought from home. See Food Brought from Home, STANDARD 4.040 and STANDARD 4.041;
l) Policy on infant feeding. See Nutrition for Infants, STANDARD 4.011 through STANDARD 4.021 and Plans and Policies for Food Handling, Feeding, and Nutrition, STANDARD 8.035 and STANDARD 8.036;
m) Policies for staffing including the use of volunteers, helpers, or substitute caregivers, child:staff ratios, deployment of staff for dif-ferent activities, authorized caregivers, me-thods used to ensure continuous supervision of children. See Child:Staff Ratio and Group Size, STANDARD 1.001 through
STANDARD 1.005;
n) Policies for sanitation and hygiene. See Hygiene and Sanitation, Disinfection, and Maintenance, STANDARD 3.012 through STANDARD 3.040;
o) Non-emergency transportation policies. See Transportation, STANDARD 2.029 through STANDARD 2.038;
p) Presence and care of any pets or any other animals on the premises. See Animals, STANDARD 3.042 through STANDARD 3.044;
q) Policy on health assessments and immunizations. See Daily Health Assessment, STANDARD 3.001 and STANDARD 3.002; Preventive Health Services, STANDARD 3.003 through STANDARD 3.004; and Immunizations, STANDARD 3.005 through STANDARD 3.007;
r) Policy regarding care of acutely ill children, including exclusion or dismissal from the faci-lity. See Child Inclusion/Exclusion/Dismissal, STANDARD 3.065 through STANDARD 3.068; Caring for Ill Children, STANDARD 3.070 through STANDARD 3.080; and Plan for the Care of Acutely Ill Children, STANDARD 8.011 and STANDARD 8.012;
s) Policy on administration of medications. See Medications, STANDARD 3.081 through STANDARD 3.083; and Medication Policy, STANDARD 8.021;
t) Policy on use of child care health consultants. See STANDARD 1.040 through
STANDARD 1.044;
u) Policy on health education. See STANDARD 2.060 through STANDARD 2.067.
v) Policy on smoking, tobacco use, and prohibited substances. See Smoking and Prohibited Substances, STANDARD 3.041 and Policy on Smoking, Tobacco Use, Prohibited Substances, and Firearms, STANDARD 8.038 and STANDARD 8.039;
w) Policy on confidentiality of records. See STANDARD 8.054.

Parents and caregivers shall sign that they have reviewed and accepted this statement of services, policies and procedures.

RATIONALE: The Model Child Care Health Policies has all of the necessary text to comply with this standard organized into a single document. Each policy has a place for the facility to fill in blanks to customize the policies for a specific site. The text of the policies can be edited to match individual program operations. Since the task of assembling all the items listed in this standard is formidable, starting with a template such as Model Child Care Health Policies can be helpful.

COMMENTS: Parents are encouraged to interact with their own children and other children at drop-off and pick-up times and during visits at the center. Parents and caregivers, including volunteers, may have different approaches to routines than those followed by the facility. Review of written policies and procedures by all adults prior to contact with the children in care helps ensure consistent implementation of carefully considered decisions about how care should be provided at the facility.

For large and small family child care homes, a written statement of services, policies and procedures is recommended but not required. If the statement is provided orally, parents should sign a statement attesting to their acceptance of the statement of services, policies and procedures presented orally to them. Model Child Care Health Policies can be adapted to these smaller settings.

Copies of the current edition of Model Child Care Health Policies can be purchased from the National Association for the Education of Young Children (NAEYC) or from the American Academy of Pediatrics (AAP). Contact information for the NAEYC and the AAP is located in Appendix BB.

TYPE OF FACILITY: Center; Large Family Child Care Home; Small Family Child Care Home


ADMISSION AND ENROLLMENT POLICY
STANDARD 8.006
nondiscrimination policy
The facility's written admission policy shall be nondiscriminatory in regard to race, culture, sex, religion, national origin, ancestry, or disability. A copy of the policy and definitions of eligibility shall be available for review on demand.

RATIONALE: Nondiscriminatory policies advocate for quality child care services for all children regardless of the child's citizenship, residency status, financial resources, and language differences.

COMMENTS: Facilities should be able to accommodate all children except those whose needs require extreme modifications beyond the capability of the facility's resources. However, facilities should not have blanket policies against admitting children with disabilities. Instead, a facility should make an individual assessment of a child's needs and the facility's ability to meet those needs. Federal laws do not permit discrimination based on disability (Americans with Disabilities Act). Inclusion of children with disabilities in all child care and early childhood educational programs is strongly encouraged. See Chapter 7, Children Who Are Eligible for Services Under the Individuals with Disabilities Education Act (IDEA), for more information on the Americans with Disabilities Act (ADA).

TYPE OF FACILITY: Center; Large Family Child Care Home; Small Family Child Care Home
STANDARD 8.007
exchange of information upon enrollment
Arrangements for enrollment of children shall be made in person by the parents or legal guardians. The facility shall advise the parents/legal guardians of their responsibility to provide information to the facility regarding their children.

RATIONALE: Parents or legal guardians must be fully informed about the facility's services before delegating responsibility for care of the child. The facility and parents must exchange information necessary for the safety and health of the child.

TYPE OF FACILITY: Center; Large Family Child Care Home; Small Family Child Care Home


DISCIPLINE POLICY
STANDARD 8.008
Content of Written discipline policy
Each facility shall have and implement a written discipline policy that outlines positive methods of guidance (described in Discipline, STANDARD 2.039 through STANDARD 2.043) appropriate to the ages of the children enrolled. It shall explicitly describe positive, nonviolent, non-abusive methods for achieving discipline. These shall include the following:
a) Redirection;
b) Planning ahead to prevent problems;
c) Encouragement of appropriate behavior;
d) Consistent, clear rules;
e) Children involved in solving problems.

All caregivers shall sign an agreement to implement the facility's discipline policy.

All facilities shall have written discipline policies.

RATIONALE: Caregivers are more likely to avoid abusive practices if they are well-informed about effective, non-abusive methods for managing children's behaviors. Positive methods of discipline create a constructive and supportive social group and reduce incidents of aggression.

COMMENTS: Examples of appropriate alternatives to corporal punishment for infants and toddlers include brief, verbal expressions of disapproval; for preschoolers, "time out" (such as an out-of-group ac-
tivity) under adult supervision; for school-age children, denial of privileges. A helpful resource for discussion of staff-child interactions is the National Association for the Education of Young Children's (NAEYC) Guide to Accreditation. Contact information for the NAEYC is located in Appendix BB.

TYPE OF FACILITY: Center; Large Family Child Care Home, Small Family Child Care Home
STANDARD 8.009
implementation of discipline policy
The caregiver shall implement a policy that promotes positive guidance and discipline techniques and prohibits corporal punishment, psychological abuse, humiliation, abusive language, binding or tying to restrict movement, and the withdrawal or forcing of food and other basic needs, as outlined in STANDARD 2.043. A policy explicitly stating the consequence for staff who exhibit these behaviors shall be determined and reviewed and signed by each staff member prior to hiring.

RATIONALE: Corporal punishment may be physical abuse or may become abusive very easily. Emotional abuse can be extremely harmful to children, but, unlike physical or sexual abuse, it is not adequately defined in most state child abuse reporting laws. Corporal punishment is clearly prohibited in small family child care homes in 47 states, and is prohibited in centers in 50 states (1, 2). Research links corporal punishment with negative effects such as later criminal behavior and impairment of learning (3-5). Primary factors supporting the prohibition of certain methods of punishment include current child development theory and practice, legal aspects (namely that a caregiver is not acting in place of parents with regard to the child), and increasing liability suits.

TYPE OF FACILITY: Center; Large Family Child Care Home; Small Family Child Care Home
STANDARD 8.010
policy on childrens' acts of aggression
The facility shall have policies for dealing with acts of aggression and fighting (such as biting and hitting) by children. These policies shall include:
a) Separation of the children involved;
b) Immediate attention to the individual child or caregiver who was bitten;
c) Notification to parents of children involved in the incident, if an injury requires first aid or medical attention, as specified in Incidence Logs of Illness, Injury, and Other Situations That Require Documentation, STANDARD 8.061 through STANDARD 8.064;
d) Review of the adequacy of the caregiver supervision and appropriateness of facility activities;
e) Administrative policy for dealing with recurrences.

RATIONALE: Aggressive acts, both intentional and unintentional, occur in out-of-home care settings (6, 7). Administrative guidelines are necessary for the management of recurrent acts of aggression and should be developed within the facility based on the resources and structure of the facility. Potential injuries and infections that may be incurred when caring for young children are health and safety hazards for caregivers. Training and educational materials should be provided to caregivers to help them understand how best to prevent and respond to these situations.

COMMENTS: In general, reducing child:staff ratios and child group sizes, having training for caregivers, and using positive guidance and discipline techniques that care for the victim and avoid rewarding the aggressor with attention, will help to decrease acts of aggression (such as biting and hitting). For additional information on discipline policy, see also Discipline, STANDARD 2.039 through STANDARD 2.043.

Biting and hitting are manifestations of different emotional feelings at different ages. Biting is a common behavior in the infant or toddler who is expressing a feeling. Hitting may be an immature behavior with no malicious intent.

TYPE OF FACILITY: Center; Large Family Child Care Home; Small Family Child Care Home

PLAN FOR THE CARE OF ACUTELY ILL CHILDREN AND CAREGIVERS
STANDARD 8.011
content and development of the plan for care of ill children and caregivers
The facility's plan for the care of ill children and caregivers shall be developed in consultation with the facility's health consultant. See STANDARD 1.040 through STANDARD 1.044. This plan shall include:
a) Policies and procedures for urgent and emergency care;
b) Admission and inclusion/exclusion policies. Conditions that require that a child be excluded and sent home are specified in Child Inclusion/Exclusion/Dismissal, STANDARD 3.065 through STANDARD 3.068;
c) A description of illnesses common to children in child care, their management, and precautions to address the needs and behavior of the ill child as well as to protect the health of other children and caregivers. See Infectious Diseases, STANDARD 6.001 through STANDARD 6.039;
d) A procedure to obtain and maintain updated individual emergency care plans for children with special health care needs;
e) A procedure for documenting the name of person affected, date and time of illness, a description of symptoms, the response of the caregiver to these symptoms, who was notified (such as a parent, legal guardian, nurse, physician, health department), and the response;
f) The standards described in Reporting Illness, STANDARD 3.087 and STANDARD 3.088; and Notification of Parents, STANDARD 3.084 and STANDARD 3.085.
g) Medication Policy. See STANDARD 8.021.

All child care facilities shall have written policies for the care of ill children and caregivers.

RATIONALE: The policy for the management of ill children should be developed in consultation with health care providers to address current understanding of the technical issues of contagion and other health risks. In group care, the facility must address the well-being of all those affected by illness: the ill child, the staff, parents of the ill child, other children in the facility and their parents, and the community. Where compromises must be made, the priority of the policy should be to meet the needs of the ill child. The policy should address the circumstances under which separation of the ill child from the group is required; the circumstances under which the caregiver, parents, legal guardian, or other designated persons need to be informed; and the procedures to be followed in these cases. The policy should take into consideration:
a) The physical facility;
b) The number and the qualifications of the facility's personnel;
c) The fact that children do become ill frequently and at unpredictable times;
d) The fact that working parents often are not given leave for their children's illnesses (8).

Infectious diseases are a major concern of parents and caregivers. Since children, especially those in group settings, can be a reservoir for many infectious agents, and since caregivers come into close and frequent contact with children, caregivers are at risk for developing a wide variety of infectious diseases. Following the infection control standards will help protect both children and caregivers from communicable disease. Recording the occurrence of illness in a facility and the response to the illness characterizes and defines the frequency of the illness, suggests whether an outbreak has occurred, may suggest an effective intervention, and provides documentation for administrative purposes.

COMMENTS: Facilities may comply by adopting a model policy and using reference materials as authoritative resources. The Model Child Care Health Policies, the print or internet version available from NAEYC and the AAP, may be helpful; or see the Red Book or Preparing for Illness, a booklet which translates the recommendations of the Red Book for child care providers, available from the AAP. Check for other materials provided by the licensing agency, resource and referral agency, or health department. Training for staff on management of illness can be facilitated by using Part 6: Illness in Child Care, of the video series developed to illustrate how to comply with the standards in Caring for Children. The video series is available from the AAP and NAEYC. See the sample symptom record in Appendix F. The sample symptom record is also provided in Healthy Young Children produced by the NAEYC. See also a sample document for permission for medical condition treatment in Appendix W. Contact information for the National Association for the Education of Young Children (NAEYC) and the American Academy of Pediatrics (AAP) can be found in Appendix BB.

TYPE OF FACILITY: Center; Large Family Child Care Home; Small Family Child Care Home
STANDARD 8.012
exclusion and alternative care for children
At the discretion of the person authorized by the child care provider to make such decisions, children who are ill shall be excluded from the child care facility for the conditions defined in STANDARD 3.065 through STANDARD 3.068.

When children are not permitted to receive care in their usual child care setting and cannot receive care from a parent or relative, they shall be permitted to receive care in one of the following arrangements, if the arrangement meets the applicable standards:
a) Care in the child's usual facility in a special area for care of ill children;
b) Care in a separate small family child care home or center that serves only children with illness or temporary disabilities;
c) Care by a child care worker in the child's own home.

RATIONALE: Young children who are developing trust, autonomy, and initiative require the support of familiar caregivers and environments during times of illness to recover physically and avoid emotional distress (9). Young children enrolled in group care experience a higher incidence of mild illness (such as upper respiratory infections or otitis media) and other temporary disabilities (such as exacerbation of asthma or eczema) than those who have less interaction with other children. Sometimes, these illnesses preclude their participation in the usual child care activities. Most state regulations require that children with certain conditions be excluded from their usual care arrangement (10). To accommodate situations where parents cannot provide care for their own ill children, several types of alternative care arrangements have been established.

When children with possible communicable diseases are present in the alternative care arrangements, preventing the further spread of disease is a priority. Although most facilities claim to adhere to general principles of prevention and control of communicable disease, in a study of such practices, only one facility followed strict isolation procedures (11). In another study, a facility providing care for ill children demonstrated no additional transmission of communicable disease from the children served to the rest of the well children attending the usual child care
facilities (12).

COMMENTS: Working parents should be entitled to family sick leave days to care for their ill children. Professionals and the public generally agree that when a child is seriously ill, or when it is not yet clear that the illness is a mild one, the parent should be able to stay home with the child. When a child is recuperating from a mild illness that precludes participation in the child's usual child care setting, parents may need alternative arrangements. At a minimum, working parents should be able to use their own sick or personal days to care for their ill children. However, children are ill frequently; some parents need help in making alternative arrangements for the days when the child is not very ill and the parents need to be at work. Facilities unable to care for ill children should be supportive and helpful to parents, giving them ideas for alternative arrangements. However, the responsibility for care cannot be transferred from the parent to the child care provider unless the caregiver is willing to accept this responsibility. The decision to accept responsibility for the care of ill children should rest with a designated person at the child care facility, who must weigh staffing and programmatic considerations that affect this decision. Though considerations may vary from one instance to another, parents must know who will make the decision.

Sometimes a child can be included in the facility's regular group of children, with modified activities. Sometimes a center can set up a "get well room" where ill children not able to participate with the regular group can receive care. Some centers have set up satellite small family child care homes for their enrolled children. Ideally, the children know the caregiver because the caregiver works at the center when no child is ill. Similarly, a child's regular small or large family child care home provider could include the child in the regular group if appropriate, or might have a "get well room," if adequate supervision can be provided. Other alternative care arrangements include a worker sent by a home health agency or from a pool of caregivers to the child's home, arrangements in a pediatric unit of a hospital, pediatric office, or other similar setting. Special facilities caring only for ill children should meet more specialized requirements.

For more information regarding caring for ill children, see STANDARD 3.070 through STANDARD 3.080.

TYPE OF FACILITY: Center; Large Family Child Care Home; Small Family Child Care Home


HEALTH PLAN FOR CHILD HEALTH SERVICES
STANDARD 8.013
written procedure for obtaining preventive health service information
Each facility shall develop and follow a written procedure for obtaining necessary medical information including immunizations (see Recommended Childhood Immunization Schedule in Appendix G) and periodic preventive health assessments (see Recommendations for Preventive Pediatric Health Care in Appendix H) as recommended by the American Academy of Pediatrics (AAP) and the Health Care Financing Administration of the U.S. Department of Health and Human Services (13, 14). Facility staff shall encourage parents/legal guardians to schedule these preventive health services in a timely fashion.

Documentation of an age-appropriate health assessment that includes an update of immunizations and screenings shall be filed in the child's record at the facility within 6 weeks of admission and following each subsequent routinely scheduled preventive health care visit. The staff of the facility shall review the admission and all subsequent reports of the child's health assessment visits that occur while the child is enrolled and shall offer a list of concerns for the parents to bring to upcoming check-up visits. Medical information shall include any information needed for the special medical care of the child. Questions raised by child care staff shall be directed to the family or, with parental permission, to the child's health care
clinician for explanation and discussion of the implications for care.

Centers shall have written procedures for the verification of compliance with recommended immunizations and periodic health assessments of children. Centers shall maintain confidential records of immunizations, periodic health assessments and any special medical considerations.

RATIONALE: Health assessments are important to ensure prevention, early detection of remediable problems, and planning for adaptations needed so that all children can reach their potential. When age-appropriate health assessments and use of health insurance benefits are promoted by child care providers, children enrolled in child care will have increased access to immunizations and other preventive services (15). With the expansion of eligibility for medical assistance and the new federal subsidy of state child health insurance plans (Title XIX and Title XXI of the Social Security Act), the numbers of children who lack insurance for routine preventive health care should be limited to those in middle income families whose parents' employers do not provide coverage.

Requirements for the documentation of preventive health care provides an important safety net for children of busy parents who may be unfamiliar with or lose track of the schedule their children should follow for routine care. At least one state audits a sample of child health records in every child care center and large family child care home for compliance with a licensing requirement for documentation that enrolled children are up-to-date with the AAP
schedule. Over several years of audit, the aggregated data have been used to target pockets of need, leading to a steady improvement in services. In conversation with S.S. Aronson, MD (September 2000), compliance with immunization requirements was documented for over 90% of the children in 1999; screening tests were documented for up to two-thirds of the children, depending on the test.

The facility must have accurate, current information regarding the medical status and treatment of each child so it will be able to determine and adjust its capability to provide needed services.

COMMENTS: The facility should expect and encourage regular health assessments. Assistance for caregivers and low income parents can be obtained through the Medicaid Early Periodic Screening and Diagnostic Treatment (EPSDT) program (Title XIX) and the state's version of the federal Child Health Insurance Program (S-CHIP or Title XXI) (17).
Most states require that child care providers document that the child's health records are up-to-date to protect the child and other children whom the under-immunized child would expose to increased risk of vaccine-preventable disease. State regulations regarding immunization requirements for children may differ, but the child care facility should strive to comply with the national, annually published, Recommended Childhood Immunization Schedule, from the American Academy of Pediatrics' (AAP), Centers for Disease Control and Prevention (CDC), and the Academy of Family Practice (AFP). See Appendix G. Contact information for the AAP, CDC, and AFP is located in Appendix BB.

A child's entrance into the facility need not be delayed if an appointment for health supervision is scheduled. Often appointments for well-child care must be scheduled several weeks in advance. In such cases, the child care facility must obtain a medical history report from the parents and documentation of an appointment for routine health supervision, as a minimum requirement for the child to attend the facility on a routine basis. The child should receive immunizations as soon as practical to prevent an increased exposure to vaccine-preventable diseases.

Local public health staff (such as the staff of immunization units, EPSDT programs) should provide assistance to caregivers in the form of record-keeping materials, educational materials, and on-site visits for education and help with surveillance activities. A copy of a form to use for documentation of routine health supervision services is available from the National Association for the Education of Young Children (NAEYC) or the AAP in the Model Child Care Health Policies. Contact information for the NAEYC and the AAP is located in Appendix BB.

As more child care providers begin to use computers to reduce the complexity of record-keeping, they may want to use software for checking immunization status for age and documentation of the child's status for other services of routine preventive care. Such software for immunization checks is in common use nationally (18). Clinic Assessment Software Application (CASA) is a menu-driven relational database developed by the National Immunization Program of the Centers for Disease Control and Prevention (CDC) as an assessment tool for immunization clinics and health care providers. This application is used for the data entry and analysis of immunization status. It includes reminder and recall tracking capabilities as well as other special features. CASA produces reports from a menu and provides programmatic feedback on the up-to-date status of individual children and for a group of children in an age range set by the user. In conversation with S.S. Aronson (July 2001), customized, non-commercial software (called ECELSTRAK) that checks children's status for all routine health supervision services (screenings and immunizations) is being used for a statewide audit of child care health records in Pennsylvania's licensing of child care facilities. Commercial software that incorporates the decision rules for routine health supervision services is being developed and may be commercially available soon.

Health professionals can photocopy, then update old reports with strike-outs, added dates, and initials over the course of several visits. Having to fill out the form brings up the issue of the child's use of child care as part of the check-up visit and fosters discussions related to the child's adjustment and the parent's satisfaction with the arrangements.

For a sample Child Health Assessment that includes immunization and preventive health records, see Appendix Z. See STANDARD 8.053 for information on confidentiality and access to records.

TYPE OF FACILITY: Center; Large Family Child Care Home; Small Family Child Care Home
STANDARD 8.014
documentation of exemptions and exclusion of children who lack immunizations
Exemptions from the requirement for up-to-date immunization made for religious or medical reasons shall be documented in the child's record. A child whose immunizations are not kept up-to-date shall be excluded after three written remin-ders to parents over a 3-month period. If more than one immunization is needed in a series, time shall be allowed for the immunizations to be obtained at the appropriate intervals.

RATIONALE: National surveys document that child care has a positive influence on protection from vaccine-preventable illness (20). Immunizations should be required for all children in child care settings. Facilities must consider the consequences if they accept responsibility for exposing a child who cannot be fully immunized because of immaturity to a child who may bring disease to the facility because of refusal to be immunized. Although up to 6 weeks after the child starts to participate in child care may be allowed for the acquisition of immunizations for which the child is eligible, parents should maintain their child's immunization status according to the nationally recommended schedule to avoid potential exposure of other children in the facility to vaccine-preventable disease.