Senate Bill 0182c2

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    Florida Senate - 1998           CS for CS for SB 182 & SB 1042

    By the Committees on Education, Children, Families and Seniors
    and Senators Kirkpatrick and Holzendorf




    304-1760A-98

  1                      A bill to be entitled

  2         An act relating to early education and child

  3         care; creating the School Readiness Commission

  4         to serve as an advisory body to the State Board

  5         of Education and other state agencies on

  6         matters that relate to school readiness;

  7         providing for the commission to be assigned to

  8         the Executive Office of the Governor for

  9         administrative purposes; providing for the

10         Governor to appoint the members of the

11         commission; providing for the members to be

12         approved by the State Board of Education and

13         confirmed by the Senate; requiring the

14         commission to appoint an executive director;

15         providing for payment of per diem and travel

16         expenses of commission members; establishing

17         duties of the commission; requiring the

18         commission to prepare a system for measuring

19         school readiness; specifying objectives to be

20         measured by such system; requiring the

21         commission to contract with an independent

22         entity to evaluate the measurement system;

23         requiring the commission to make

24         recommendations to the Governor and the State

25         Board of Education; authorizing the commission

26         to adopt rules; establishing a School Readiness

27         Coordinating Council; creating s. 402.265,

28         F.S.; providing legislative intent;

29         establishing the early education and child care

30         program and providing for optional

31         participation; providing for the council to be

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  1         assigned to the Executive Office of the

  2         Governor for administrative purposes; providing

  3         for oversight; providing eligibility for

  4         participation in the program; providing

  5         performance standards and outcome measures;

  6         providing for School Readiness Coalitions;

  7         providing for implementation of programs;

  8         requiring development of a plan and providing

  9         program requirements; requiring a sliding fee

10         scale; providing for funding; requiring a

11         reimbursement rate schedule; providing

12         requirements relating to fiscal agents;

13         providing for parental choice and for payment

14         arrangements; providing for evaluation and

15         reporting; providing that federal requirements

16         control in the case of conflict; exempting

17         family child care providers from increased

18         standards; repealing s. 411.222(4), F.S.,

19         relating to the State Coordinating Council for

20         Early Childhood Services; providing an

21         effective date.

22

23  Be It Enacted by the Legislature of the State of Florida:

24

25         Section 1.  School Readiness Commission.--

26         (1)  The School Readiness Commission is established and

27  assigned to the Executive Office of the Governor for

28  administrative purposes. The commission shall carry out the

29  duties and responsibilities provided in this section and

30  delegated by the State Board of Education and is not subject

31  to control, supervision, or direction by the Executive Office

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  1  of the Governor or the State Board of Education. The

  2  commission shall serve as an advisory body to the State Board

  3  of Education and other appropriate state agencies and entities

  4  on all matters relating to achievement of the first state

  5  education goal, readiness to start school. In addition, the

  6  commission's reports and recommendations shall be made

  7  available to the Governor, the Legislature, the State Board of

  8  Education, other appropriate state agencies and entities,

  9  district school boards, central agencies for child care, and

10  county public health units.

11         (2)  The commission shall be composed of 12 members of

12  the public who shall be business, community, and civic leaders

13  in the state who are not elected to public office and who do

14  not earn their income in the early education and child care

15  industry. Each member shall be appointed by the Governor,

16  subject to approval by three members of the State Board of

17  Education other than the Governor and subject to confirmation

18  by the Senate. Members shall be appointed to 4-year terms of

19  office. However, of the initial appointees, three shall be

20  appointed to 1-year terms, three shall be appointed to 2-year

21  terms, three shall be appointed to 3-year terms, and three

22  shall be appointed to 4-year terms. The members of the

23  commission shall elect a chairperson annually. Any vacancy on

24  the commission shall be filled in the same manner as the

25  original appointment.

26         (3)  The commission shall meet as often as it deems

27  necessary to carry out its duties and responsibilities.

28         (4)  The commission shall appoint an executive director

29  to serve at its pleasure, who shall perform the duties

30  assigned to him or her by the commission. The executive

31  director shall be the chief administrative officer of the

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  1  commission and shall be responsible for appointing all

  2  employees and staff members of the commission, who shall serve

  3  under his or her direction and control.

  4         (5)  Members of the commission shall serve without

  5  compensation, but are entitled to reimbursement for per diem

  6  and travel expenses incurred in the performance of their

  7  duties as provided in section 112.061, Florida Statutes.

  8         (6)  The commission shall:

  9         (a)  Serve as a citizen board to coordinate the efforts

10  toward school readiness in this state and provide independent

11  policy analyses and recommendations to the Governor, the State

12  Board of Education, and the Legislature.

13         (b)  Prepare and submit to the State Board of Education

14  a system for measuring school readiness. The system must

15  include a screening instrument, or instruments, which shall

16  provide objective data regarding the following expectations

17  for school readiness:

18         1.  The child's immunizations and other health

19  requirements as necessary.

20         2.  The child's display of physical development

21  appropriate for kindergarten.

22         3.  The child's compliance with rules, limitations, and

23  routines.

24         4.  The child's successful engagement in kindergarten

25  tasks.

26         5.  The child's demonstration of appropriate

27  interactions with adults.

28         6.  The child's demonstration of appropriate

29  interactions with peers.

30         7.  The child's effective coping with challenges and

31  frustrations.

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  1         8.  The child's demonstration of appropriate self-help

  2  skills.

  3         9.  The child's ability to express his needs

  4  appropriately.

  5         10.  The child's demonstration of verbal communication

  6  skills necessary to succeed in kindergarten.

  7         11.  The child's demonstration of problem-solving

  8  skills necessary to succeed in kindergarten.

  9         12.  The child's following of verbal directions.

10         13.  The child's demonstration of curiosity,

11  persistence, and exploratory behavior.

12         14.  The child's demonstration of an interest in books

13  and other printed materials.

14         15.  The child's paying attention to stories.

15         16.  The child's participation in art and music

16  activities.

17         (c)  Prepare a plan for implementing the system for

18  measuring school readiness in such a way that all children in

19  this state have the opportunity to undergo the screening in

20  the year prior to their entry into kindergarten. The plan must

21  include a way to make the screening instrument and the

22  training required to administer it available to public and

23  private providers of preschool and child care programs, and a

24  way to make the screening available to children who do not

25  participate in such programs.

26         (d)  Establish a method for collecting data from the

27  screening instrument and establish guidelines for using the

28  data so that the measurement, the data collection, and the use

29  of the data serve the statewide goal that all children will be

30  ready for school. The criteria for determining which data to

31  collect should be the usefulness of the data to state

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  1  policymakers and program administrators in administering

  2  programs and allocating state funds.

  3         (e)  Contract with an independent entity for an

  4  evaluation of the measurement system. The evaluation must

  5  provide the information that local and state agencies, the

  6  Governor, and the Legislature need to provide for the

  7  effective administration of programs that serve preschool

  8  children. The evaluation must provide information that will

  9  assist providers of private preschool and child care programs

10  in assessing the success of preschool and child care programs

11  and making decisions about improving program services to

12  prepare children for school.

13         (f)  Recommend to the Governor, the Commissioner of

14  Education, and the State Board of Education rules, and

15  revisions or repeal of rules, which would increase the

16  effectiveness of programs that prepare children for school.

17         (g)  Conduct studies and planning activities related to

18  the overall improvement and effectiveness of school-readiness

19  measures.

20         (h)  Submit an annual report of its activities to the

21  Governor, the President of the Senate, the Speaker of the

22  House of Representatives, and the minority leaders of both

23  houses of the Legislature.

24

25  To ensure that the system for measuring school readiness is

26  comprehensive and appropriate statewide, as the system is

27  developed and implemented, the commission must consult with

28  representatives of district school systems, providers of

29  public and private child care, health care providers, large

30  and small employers, and experts in child development.

31

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  1         (7)  The commission may adopt rules necessary to

  2  administer the provisions of this section relating to

  3  preparation and implementation of the system for school

  4  readiness, data collection, approving local coalition plans,

  5  awarding incentives to coalitions, and contracting for an

  6  evaluation.

  7         Section 2.  School Readiness Coordinating Council.--

  8         (1)  The School Readiness Coordinating Council is

  9  established with responsibility for advising the School

10  Readiness Commission regarding policies facilitating local

11  implementation, providing technical assistance, and helping

12  secure waivers.  The School Readiness Coordinating Council

13  shall consist of:

14         (a)  The Deputy Commissioner of Education Programs in

15  the Department of Education;

16         (b)  The Secretary of Children and Family Services or a

17  designated division director;

18         (c)  The Secretary of Health or a designated division

19  director;

20         (d)  The Chair of the Child Care Partnership Board;

21         (e)  The Executive Director of the State WAGES Board;

22         (f)  The President of the Florida Pediatric Society;

23         (g)  The Chair of the Florida Council of 100;

24         (h)  The President of the Head Start Directors'

25  Association;

26         (i)  The President of the Florida Children's Forum;

27         (j)  The Chair of the Developmental Disabilities

28  Council;

29         (k)  The Director of the Healthy Start Coalition

30  Association;

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  1         (l)  The President of the Florida School Boards

  2  Association;

  3         (m)  The Chair of the Florida Association of Family

  4  Child Care Homes;

  5         (n)  The Chair of a School Readiness Coalition;

  6         (o)  The President of the Florida Association of Child

  7  Care Management;

  8         (p)  The Executive Director of the Early Childhood

  9  Association;

10         (q)  The Chair of the Florida Interagency Coordinating

11  Council for Infants and Toddlers;

12         (r)  The Coordinator of the Florida Parent Resource

13  Organization;

14         (s)  A representative of the Family Network on

15  Disabilities of Florida;

16         (t)  The President of the Children's Services Council

17  Association of Florida;

18         (u)  The Director of the Agency for Health Care

19  Administration;

20         (v)  The President of the State of Florida P.T.A.; and

21         (w)  An additional five members representing the

22  private-sector business community. These five members must be

23  selected by a majority vote of the other members.

24

25  The School Readiness Coordinating Council shall select a chair

26  from among the business community and a vice chair.

27         (2)  School Readiness Coordinating Council members are

28  entitled to receive per diem and expenses for travel, as

29  provided in section 112.061, Florida Statutes, while carrying

30  out the official business of the council.  For administrative

31

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  1  purposes only, the council shall be assigned to the Office of

  2  the Governor.

  3         (3)  The School Readiness Coordinating Council shall

  4  meet and conduct business at least quarterly or as needed to

  5  carry out the duties of the council.

  6         (4)  The School Readiness Coordinating Council shall be

  7  staffed by the Office of the Governor and draw upon state

  8  agency personnel and resources as needed to implement policy

  9  necessary to facilitate the early education and child care

10  program.

11         (5)  Quarterly meetings of the School Readiness

12  Coordinating Council shall be open to the public and

13  opportunity for public comment shall be made available at each

14  such meeting.  The staff of the School Readiness Coordinating

15  Council shall notify all persons who request such notice as to

16  the date, time, and place of each quarterly meeting.

17         Section 3.  Section 402.265, Florida Statutes, is

18  created to read:

19         402.265  Early education and child care program.--

20         (1)  LEGISLATIVE INTENT.--

21         (a)  The Legislature recognizes that high-quality early

22  education and child care programs increase children's chances

23  of achieving future educational success and becoming

24  productive members of society.  It is the intent of the

25  Legislature that such programs be developmental, serve as

26  preventive measures for children at risk of future school

27  failure, enhance the educational readiness of all children,

28  and support family education and the involvement of parents in

29  their child's educational progress.  Each early education and

30  child care program shall provide the elements necessary to

31  help prepare preschool children for school, including health

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  1  screening and referral, a developmentally appropriate

  2  educational program, and opportunities for parental

  3  involvement in the program.

  4         (b)  It is legislative intent that all programs and

  5  services for Florida children in the first 5 years of life,

  6  including health care, child care, child welfare, and formal

  7  education, are school readiness programs.

  8         (c)  It is legislative intent that early education and

  9  child care programs be operated within funding limits on a

10  full-day, year-round basis to enable parents to work and

11  become financially self-sufficient.

12         (d)  It is legislative intent that early education and

13  child care programs not exist as isolated programs, but build

14  upon existing services and work in cooperation with other

15  programs for young children, and that these programs be

16  coordinated and funding integrated to achieve full

17  effectiveness.

18         (e)  It is legislative intent that the implementation

19  of an early education and child care program be optional on a

20  county-by-county basis.  It is further intended that, if a

21  county or counties decide to implement a program, procedures

22  such as, but not limited to, contracting, collocation,

23  mainstreaming, and cooperative or integrated funding shall be

24  used to coordinate all publicly funded early education and

25  child care programs, defined as prekindergarten early

26  intervention programs, Head Start programs, programs offered

27  by public or private providers of child care, preschool

28  programs for children with disabilities, programs for migrant

29  children, Title I programs, subsidized child care programs,

30  teen parent programs, and other services.

31

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  1         (2)  CREATION OF OPTIONAL PROGRAM; EXEMPTIONS.--The

  2  early education and child care program consisting of publicly

  3  funded programs listed in paragraph (1)(e) is established. The

  4  early education and child care program is an optional program.

  5  A county or counties may elect to participate in this program

  6  by following the requirements of this section. If the

  7  provisions of this section are found to be in conflict with

  8  any provisions of ss. 230.2305 and 402.3015, the provisions of

  9  this section shall prevail in any county that chooses to

10  participate in the early education and child care program and

11  obtains plan approval from the School Readiness Coordinating

12  Council.

13         (3)  PROGRAM ELIGIBILITY.--The early education and

14  child care program shall be established for children from

15  birth to 6 years of age. The program shall consist of the

16  programs listed in paragraph (1)(e), be administered by a

17  fiscal agent selected by the School Readiness Coalition, and

18  receive funds pursuant to SB 180 or similar legislation.

19  Within funding limitations, the fiscal agent along with all

20  providers shall make reasonable efforts to accommodate the

21  needs of children for extended-day and extended-year services

22  without compromising the quality of the program.  Eligibility

23  for admission in the early education and child care program is

24  as follows:

25         (a)  Children of participants in the WAGES program are

26  the only children eligible for services funded through the

27  federal Temporary Assistance for Needy Families program.

28         (b)  Children under 6 years of age who are:

29         1.  Children determined to be at risk of abuse,

30  neglect, or exploitation and who are currently clients of the

31  Department of Children and Family Services.

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  1         2.  Children at risk of welfare dependency, including

  2  children of migrant farmworkers, children of teenage parents,

  3  and children from other families at risk of welfare dependency

  4  due to a family income of less than 100 percent of the federal

  5  poverty level.

  6         3.  Children of working families whose family income is

  7  equal to or greater than 100 percent, but does not exceed 150

  8  percent, of the federal poverty level.

  9         (c)  Children who meet the eligibility requirements for

10  the pre-kindergarten early intervention program under s.

11  230.2305(2).

12         (4)  STANDARDS; OUTCOME MEASURES.--

13         (a)  All publicly funded early education and child care

14  programs must meet the following performance standards and

15  outcome measures developed by the Department of Education and

16  the Department of Children and Family Services:

17         1.  They must help prepare preschool children to enter

18  kindergarten ready to learn, as measured by the School

19  Readiness Checklist of the Department of Education.

20         2.  They must provide extended-day and extended-year

21  services when possible.

22         3.  There must be coordinated staff development and

23  teaching opportunities.

24         4.  There must be expanded access to community services

25  and resources for families to help achieve economic

26  self-sufficiency.

27         5.  There must be a simplified point of entry and

28  unified waiting list.

29         6.  They must serve at least as many children as were

30  served prior to implementation of the program.

31

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  1  The fiscal agent is responsible for monitoring and providing

  2  assistance to these programs to achieve the expected

  3  performance standards and outcome measures. The fiscal agent

  4  shall report to the School Readiness Coalition on the

  5  achievement of performance standards with recommendations for

  6  future funding.

  7         (b)  All participating publicly funded early education

  8  and child care programs must implement a comprehensive program

  9  of children and family services that enhance the cognitive and

10  physical development of children to achieve the performance

11  standards and outcome measures specified in paragraph (a). At

12  a minimum, these programs must contain the following elements:

13         1.  Staff-child interaction.

14         2.  Developmentally appropriate curriculum.

15         3.  An appropriate staff-to-child ratio.

16         4.  Continuity of care.

17         5.  Group size.

18         6.  A healthy and safe environment.

19         7.  Varied family components.

20         8.  Quality services at an identified cost.

21         9.  A resource and referral network to assist parents

22  in making an informed choice pursuant to s. 402.27.

23         (5)  SCHOOL READINESS COALITIONS.--

24         (a)1.  Each School Readiness Coalition must consist of

25  at least 12 members. Four members shall be appointed by the

26  district school board, four members shall be appointed by the

27  county commission for the county in which participating

28  schools are located, and four members shall be appointed by

29  the Department of Children and Family Services district

30  administrator. If a coalition has more than 12 members, the

31

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  1  additional members shall be appointed equally by the three

  2  appointing entities.

  3         2.  School Readiness Coalition membership shall

  4  include, in addition to private-sector business leaders, the

  5  local public and private leaders in health care, education,

  6  disabilities, and child welfare systems in each county. Three

  7  members of the coalition must be administrators from each of

  8  the following entities: The central agency for child care, the

  9  district school board, and the Head Start program. School

10  Readiness Coalition membership must include representatives

11  from programs serving children in the early education and

12  child care programs and may include representatives from

13  organizations such as Children's Services Councils, Central

14  Agencies for Child Care, Healthy Start Coalitions, local

15  school boards, child care licensing boards, local WAGES

16  Coalitions, Head Start, municipal and county governments, the

17  Department of Children and Family Services, the County Public

18  Health Unit, and chambers of commerce. A minimum of five

19  coalition members shall be from the private sector.

20         (b)  If a county chooses to participate in the early

21  education and child care program, the School Readiness

22  Coalition will replace the district interagency coordinating

23  council.

24         (6)  IMPLEMENTATION.--

25         (a)  The early education and child care program may be

26  implemented in any county by agreement of the district school

27  system and the Department of Children and Family Services

28  district, with approval of the School Readiness Commission.

29  Approval by the School Readiness Commission must be predicated

30  on the submission of a plan of implementation prepared and

31  submitted by the School Readiness Coalition.

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  1         (b)  The School Readiness Coalition in each county that

  2  chooses to participate in the early education and child care

  3  program shall develop a plan for implementation to meet the

  4  requirements of this section. The plan shall include a written

  5  description of the role of the program in the district's

  6  effort to meet the first state education goal, readiness to

  7  start school, including a description of the plan to involve

  8  prekindergarten early intervention programs, Head Start

  9  programs, programs offered by public or private providers of

10  child care, preschool programs for children with disabilities,

11  programs for migrant children, Title I programs, subsidized

12  child care programs, and teen parent programs. The plan shall

13  also demonstrate how the program will ensure that each

14  3-year-old and 4-year-old child in a publicly funded early

15  education and child care program receives scheduled activities

16  and instruction designed to prepare children to enter

17  kindergarten ready to learn. Prior to implementation of the

18  program, the School Readiness Coalition must submit the plan

19  to the School Readiness Commission for approval. The plan

20  shall be reviewed and revised as necessary, but not less than

21  every 3 years.

22         (c)  The early education and child care program shall

23  include the following minimum standards and provisions:

24         1.  A sliding fee scale, which is the same for all

25  programs, to be implemented and reflected in each program's

26  budget.

27         2.  A choice of settings and locations in licensed,

28  registered, religious exempt, or school-based programs to be

29  provided to parents.

30         3.  Instructional staff who have completed the training

31  course as required in s. 402.305(2)(d)1., as well as staff who

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  1  have additional training or credentials as required by the

  2  respective programs.

  3

  4  All revenues received through the sliding fee scale shall be

  5  used to help fund extended-day and extended-year services.

  6         (d)  Persons with an early childhood teaching

  7  certificate may provide support and supervision to other staff

  8  in the early education and child care program.

  9         (e)  Two or more counties may join for the purpose of

10  planning and implementing an early education and child care

11  program.

12         (7)  REIMBURSEMENT RATE.--The School Readiness

13  Coalition shall develop a reimbursement rate schedule that

14  encompasses all publicly funded early education and child care

15  programs and complies with applicable state and federal laws

16  and regulations.  The reimbursement rate schedule must include

17  the projected number of children to be served and must be

18  submitted to the School Readiness Commission for approval.

19  Informal child care arrangements shall be reimbursed at 50

20  percent of the rate developed for family child care.

21         (8)  REQUIREMENTS RELATING TO FISCAL AGENTS.--The

22  fiscal agent must be a public entity or a private nonprofit

23  organization. The fiscal agent shall be required to provide

24  all administrative and direct funding services as determined

25  by the School Readiness Coalition. The cost of these services

26  shall be negotiated between the fiscal agent and the

27  Department of Children and Family Services. The fiscal agent

28  shall be responsible for monitoring all providers to ensure

29  that coalition funds are expended in the manner and for the

30  purpose required by the funding source. No public funds shall

31  be paid to a provider unless the provider agrees to allow the

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  1  fiscal agent access to fulfill its monitoring

  2  responsibilities.

  3         (9)(a)  PARENTAL CHOICE; PAYMENT ARRANGEMENT.--The

  4  early education and child care program shall be provided in a

  5  manner that ensures, to the maximum extent possible, parental

  6  choice through flexibility in early education and child care

  7  arrangements and payment arrangements, including, but not

  8  limited to, voucher, contract, and direct service provision.

  9  According to federal regulations requiring parental choice, a

10  parent may choose an informal child care arrangement.

11         (b)  When a voucher is provided, each voucher must bear

12  the name of the beneficiary and the program provider and, when

13  redeemed, must bear the signature of both the beneficiary and

14  an authorized representative of the provider. If it is

15  determined that a provider has provided any cash to the

16  beneficiary in return for receiving the voucher, the local

17  coalition shall refer the matter to the Division of Public

18  Assistance Fraud of the the Office of the Auditor General for

19  investigation and shall notify the agency responsible for the

20  funding source.

21         (c)  The Department of Children and Family Services in

22  consultation with the office of the Comptroller shall

23  establish an electronic disbursement system for the

24  dissemination of funds and vouchers in accordance with this

25  subsection. Fiscal agents shall fully implement the electronic

26  funds transfer system within 3 years after plan approval

27  unless a waiver is obtained from the School Readiness

28  Coordinating Council. The fiscal agent may charge an

29  administrative fee not to exceed 1.5 percent of each voucher

30  to offset administrative costs of the early education and

31  child care program.

                                  17

CODING: Words stricken are deletions; words underlined are additions.






    Florida Senate - 1998           CS for CS for SB 182 & SB 1042
    304-1760A-98




  1         (10)  EVALUATION AND ANNUAL REPORT.--Each School

  2  Readiness Coalition shall conduct an evaluation of the

  3  effectiveness of the early education and child care program,

  4  including performance standards and outcome measures, and

  5  shall provide an annual report and fiscal statement to the

  6  School Readiness Commission, the President of the Senate, and

  7  the Speaker of the House of Representatives for review by the

  8  Legislature. This report must conform to the content and

  9  format specifications set by the School Readiness Commission.

10         (11)  CONFLICTING PROVISIONS.--In the event of a

11  conflict between the provisions of this section and federal

12  requirements, the federal requirements shall control.

13         Section 4.  Nothing in this act shall have the effect

14  of increasing the standards that must be met by family child

15  care providers; however, children who receive child care

16  services from family child care providers will participate in

17  school readiness assessment upon entering public or private

18  kindergarten or the first grade.

19         Section 5.  Subsection (4) of section 411.222, Florida

20  Statutes, is repealed.

21         Section 6.  This act shall take effect upon becoming a

22  law.

23

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25

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27

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CODING: Words stricken are deletions; words underlined are additions.






    Florida Senate - 1998           CS for CS for SB 182 & SB 1042
    304-1760A-98




  1          STATEMENT OF SUBSTANTIAL CHANGES CONTAINED IN
                       COMMITTEE SUBSTITUTE FOR
  2                            CS/SB 182

  3

  4  The committee substitute differs from CS/SB 182 and SB 1042 in
    the following ways:
  5
    The School Readiness Commission, not the coordinating council,
  6  has the authority to adopt rules and approve local coalition
    plans.
  7
    The commission must submit an annual report to the Governor,
  8  President of the Senate, and Speaker of the House of
    Representatives.
  9
    Members of the School Readiness Commission must not hold
10  public office or receive income from the early education and
    child care industry.
11
    Local coalitions may choose to have their prekindergarten and
12  subsidized child care funds placed in the Early Education and
    Child Care Trust Fund or they may form a coalition based on
13  cooperation without combining their funds.

14  Eight additional members are added to the School Readiness
    Coordinating Council.
15
    An administrator from each of the three major program
16  providers, Head Start, the school board, and the central
    agency for child care must be appointed to a School Readiness
17  Coalition.

18  Rather than establishing a single priority order for admission
    to the program individual program criteria will apply.
19  Children below the age of 6 years, rather than 13 years, are
    eligible for the program.
20
    Criteria for staff training for individual programs will
21  apply.

22  The early education and child care program may be offered
    through direct operation, contract and voucher.
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