The primary formative years for brain development occur from birth through age 3, and what happens during these early years matters well into adulthood. Since brains are built from the bottom up, quality and safe early learning experiences ensure children have a solid foundation upon which to build as they become the leaders of tomorrow.

As a family child care provider who takes the role of providing a safe and healthy early childhood program very seriously, I have concerns about the rushed implementation of the proposed licensing rule for Maine’s family child care homes and what it means for children, parents and providers.

Within the recent discussion that the proposed rule for the licensing of family child care homes has generated, we are also hearing a lot of reference to quality programs. It is important to understand that while licensing and quality intersect, they play different roles in regards to early childhood programs. Licensing, through the rule for family child care homes, sets minimum health and safety standards that all family child care programs across the state are required to meet. These standards are the same, whether you are a new licensee or one that has offered care for more than 20 years. Quality is building upon those minimum standards to focus on offering a program that includes what has been proven by research to be best practice and supports a child’s development to the highest level. There is only one level to licensing, but there are multiple levels of quality.

It is critical that the rule works for the diverse variety of family child care homes found across the state. The rule needs to be clear to the more than 1,000 family child care homes providing care, as well as the licensing specialists who oversee implementation. It also needs to meet federal guidelines and the requirements of the state of Maine as part of the Child Care and Development Block Grant.

While the rule must be updated over time, it is essential that any proposed changes maintain or improve the standard of care and follow the proper legislative process. The process protects children, families and providers against changes that could put children at risk.

I am concerned that the emergency implementation of the recently proposed rule for licensing of family child care homes bypasses a critical step of the process. By pursuing emergency implementation of the proposed rule, the Department of Health and Human Services would allow the new rule to go into effect prior to legislative review. Deviating from the review process risks permitting changes that would weaken the existing 2009 rule.

For example, the new rule reduces the frequency of required fire drills. Right now, the monthly fire drills build knowledge and comfort for children, parents and providers. When children and providers practice these safety drills regularly, they are better prepared to respond to emergencies. The proposed change leaves children and providers more vulnerable in emergency situations.

The new rule also lowers the standard of safety by allowing larger child-to-staff ratios. Low child-to-staff ratios mean adults are responsible for fewer children and can give the children in their care the appropriate attention. It also allows children to have more one-on-one interactions with a caring adult, which stimulates brain development and strengthens language skills. The low child-to-staff ratios are important indicators of quality, but also critical safety factors.

I urge the Department of Health and Human Services to reconsider its decision to seek emergency implementation of the proposed rule and hope lawmakers will halt implementation until the proposed rule can be thoroughly reviewed.

We all want quality programs for Maine’s children. It is important that we start to have a discussion that moves beyond the minimum standards of licensing, about what is quality in early childhood education. Maine families, communities, and early childhood programs can work together to raise the overall quality of early childhood education across the state.

Tammy Dwyer is the chair of the Family Child Care Association of Maine. She lives in Auburn.