UPK Quality Standards Rule Set Draft Modifications

Effective 7/2/25 the UPK ratios change to 1:10 with a max group size of 20.

**Without data to substantiate this move in a mixed delivery system unlike any other in the United States, CDEC is moving ahead with this lower ratio requirement based on NIERR criteria. Colorado requires data informed decision making for public policy. Without ANY data on outcomes, the state is jumping ahead to make this move. Colorado data should show that the change is necessary, not national data. No more apples to oranges. Colorado changes need to be based on Colorado data.

Can you and your business afford moving to 1:10 ratio?  For a 4 year old classroom that is a decrease of 4 children which signifies a loss of $40-60,000 a year for your program (numbers vary by program). If you can't, the time to speak up is NOW. Sign up for public comment at the RAC meeting and Executive Director's Rule Making Hearing. Be specific and let them know the actual costs and impact on your program! CDEC is activating a waiver process for the "possibility" of larger group sizes but without any guidance on what it takes to be approved for such a waiver. A non-specific waiver process assurance is not sufficient as a promise to not financially undermine community based programs statewide.

All families MUST participate in UPK 4.109.A.10.a.

This is an extremely vague regulation. It appears to state that ALL families in

your UPK classroom MUST participate in UPK programming. You read it for

yourself and tell me what it says to you. We can see where it could certainly be

interpreted that way from a compliance perspective. If that is indeed the case, are

all of your families willing to enroll in UPK?

**Do programs that do not want to be rated have a guarantee that CDEC will provide

observations every 3 years for UPK classrooms?

**Why are certified observers not allowed to conduct the observations independently?

After all, this is over 3,050 classrooms that will have to have observations that generally run

3+ hours which is almost 20 classrooms a week in the 3 year period that will be receiving

an observation. What system will be in place to support that new

departmental requirement.

** Note that the department is requesting a $400,000 DECREASE in funding in their budget request #R12 that would normally support programs in rating.

**We need to be CERTAIN that the Resource bank contains all of these resources so that there is not undue pressure placed on programs for implementation.

Public comment can be given at the RAC hearing on 1/11/24 AND at the Executive Director Rule Making hearing on 1/22/24. These rules are not set to be propagated by the Executive Director until the February Rule Hearing.