Promoting Quality in Afterschool Programs
Through State Child Care Regulations
June 2006

The Afterschool Investments Project

The Child Care and Development Fund (CCDF) provides federal resources for child care that support both direct services and quality enhancements. The U.S. Department of Health and Human Services’ Child Care Bureau awards CCDF grants to states, territories, and tribes. With nearly half of the children receiving services being of school or kindergarten age, CCDF provides significant funding for afterschool care in a variety of settings. The majority of CCDF dollars are used to provide subsidies to eligible low-income children under age 13. A portion of CCDF funding is also used for quality improvement initiatives, such as professional development and technical assistance, with the goal of building the capacity of states to deliver quality services including programs before and afterschool, during summers, and on school holidays.

To support state efforts to provide quality afterschool opportunities, the Child Care Bureau awarded a technical assistance contract on out-of-school time to The Finance Project and its partner, The National Governors Association Center for Best Practices. The Afterschool Investments project provides technical assistance to Child Care and Development Fund grantees and other state and local leaders who support afterschool efforts. The goals of the project include:

• Identifying ways that states and communities are using Child Care and Development Fund (CCDF) subsidy and quality dollars to support out-of-school time programs, and sharing these practices and approaches with other states;
  
  
• Identifying administrative and implementation issues related to CCDF investments in out-of-school time programs, and providing information and context (about barriers, problems, opportunities) as well as practical tools that will help CCDF administrators make decisions; and
  
  
• Identifying other major programs and sectors that are potential partners for CCDF in supporting out-of-school time programs, and providing models, strategies, and tools for coordination with other programs and sectors.

• Develops state profiles of afterschool resources, policies, and issues;
  
  
• Creates tools and materials to support the development and sustainability of afterschool efforts; and
  
  
• Provides technical assistance at meetings and conferences around building state collaborations for afterschool.

For more information about the project or to submit a request for technical assistance or information, contact The Finance Project at (202) 587-1000 or by email at afterschool@financeproject.org, or visit http://www.nccic.org/afterschool

Table of Contents

Overview

Introduction

The ABCs of State Child Care Licensing Regulations

Licensing Requirements

Challenges Associated with Licensing Afterschool Programs

Strategies and Solutions to Make Licensing Work in Afterschool Programs

How to Align Child Care Licensing with Other State Efforts to Promote Quality

Conclusion

Resources

Acknowledgements

Appendix: Challenges and Strategies for Licensing Afterschool Programs

Overview

State child care regulations seek to ensure the basic health and safety of children in child care and promote their positive development. Afterschool programs--which occur in a range of settings--have diverse goals, and may not look like traditional center-based child care--may be challenged in efforts to meet these licensing requirements. This strategy brief describes child care licensing regulations and the challenges that states face in applying them to afterschool programs. These challenges include:

• Crafting regulations that are flexible enough to apply to all afterschool programs;
• Determining which regulations should apply to certain programs and settings;
• Acknowledging barriers that some programs face in meeting regulations; and
• Addressing the perspectives of multiple sponsors and purposes of afterschool programs in policy.

The publication also presents strategies that states can use to adapt licensing regulations to address these challenges. Finally, the brief provides information and examples for states considering ways to align child care licensing with other state strategies to promote afterschool program quality, such as:

• Using state-level groups, networks, or coalitions to facilitate conversations that make connections between state child care licensing requirements and emerging afterschool program quality standards;
• Identifying common ground between child care licensing regulations and afterschool program quality standards; and
• Considering explicit linkages between child care licensing regulations and afterschool program quality standards.

For the purposes of this paper, afterschool programs refer broadly to programs that take place before and after-school, during summer, holidays, and across the full range of program settings. Many of the issues raised in this strategy brief are relevant for both center-based and family child care providers serving school-age youth. However, the challenges and strategies presented most often relate more to traditional center-based child care programs than to family child care providers.¹ While each state must design policies based on its own unique circumstances, this paper outlines a number of options for consideration.

Introduction

Afterschool programs--in schools, family homes, child care centers, community-based organizations, and other settings--have provided safe places and enriching opportunities for children after school for decades. In recent years, afterschool programming has expanded as public and private leaders have seen its potential to more effectively meet the needs of children, parents, schools, and communities. Moreover, recent research highlights the contributions of afterschool programs in improving academic achievement, helping youth develop crucial workforce skills, preventing risky behavior, and promoting positive youth development.²

Afterschool programs occur in diverse settings, use various approaches, and have multiple goals. School-age child care, funded by the federal Child Care and Development Fund (CCDF) and other sources, seeks to keep children safe and secure and provide enriching activities while their parents work. Other public programs, such as the federal 21st Century Community Learning Centers (21CCLC) program, aim primarily to raise students’ academic achievement.³ State accountability for student achievement under No Child Left Behind (NCLB), along with relevant changes to 21CCLC and related programs, have heightened the importance of linkages between the school-day curriculum and that of out-of-school time programs. Moreover, afterschool programs often have other goals, such as preventing teen pregnancy or reducing juvenile crime.

Although all afterschool programs share the desire to provide quality opportunities for children and youth, the mechanisms and policies that states, organizations, and communities use to encourage and improve program quality are varied and numerous. Quality benchmarks often are associated with program approaches or agency priorities and may address issues such as ensuring facility safety, preventing risky behavior, and promoting student academic achievement.

While child care regulations represent the baseline of adequate program quality, other strategies are used to promote higher levels of quality. For example, many states use quality rating systems that link to child care licensing requirements and provide incentives for programs to meet higher quality levels.⁴ In addition, several national, state, and local entities across the education, child care, and youth development fields have begun to develop quality standards explicitly for afterschool programs. In some cases, national quality standards, such as those underlying accreditation by the National AfterSchool Association, may be linked to state quality strategies.

The ABCs of State Child Care Licensing Regulations

Every state has child care licensing regulations, also referred to as health and safety requirements, which aim to promote the safety of all children in regulated care settings. Regulations specify a baseline of adequate quality as determined by each state. Child care licensing regulations and their application vary widely across states. For example, state and local laws determine whether or not specific programs, settings, or circumstances require licensing or some other related degree of regulatory oversight. Implementation of state licensing regulations also varies widely across states. Even states with similar regulations may differ greatly in how they monitor or enforce the requirements. State differences make it difficult to generalize broadly. Instead, this paper attempts to identify some themes and trends, accompanied by multiple examples.

Federal law requires child care providers receiving Child Care and Development Fund (CCDF) dollars to meet health and safety requirements in three core areas: prevention and control of infectious diseases, including immunizations; building and physical premises safety; and health and safety training of providers.⁵ To implement this federal mandate, many states require certain child care providers, particularly center-based programs receiving CCDF subsidies, to be licensed. Many states also require a child care program--as defined by the state or a locality--to be licensed or in some other way registered simply to operate, regardless of whether the program receives child care subsidies.

CCDF funds do support some child care providers who are exempt from state licensing standards, but still meet federal health and safety guidelines. While exemptions vary by state, typically child care provided by relatives, in-home caregivers, or family child care centers serving only a few children is exempt from licensing.⁶ These license-exempt providers meet critical needs for many families, often providing care during non-traditional hours and allowing siblings to stay together with the same caregiver.

Licensing Requirements

Although child care regulations are more typically associated with traditional child care centers or family child care providers, many states require afterschool programs in other settings, such as schools or municipal recreation centers, to be licensed. Licensing regulations vary state by state in their content and target audiences, but they most often focus on physical environment, child-staff ratios and maximum group size, staff qualifications and background, health and hygiene, and program activities.

Physical Environment
With few exceptions, buildings and settings that house publicly available activities must meet safety requirements for their physical plants to ensure states are not putting citizens in danger. These include schools, courthouses, hospitals, universities, and recreation centers. Not surprisingly, states seek to ensure that places where children spend their time also meet safety requirements. Child care facilities, just like other public places, must comply with fire codes, be accessible to individuals with disabilities, be structurally sound, be free from potential hazards, and provide accessible exits in the event of an emergency.

States inspect and certify facilities serving children to ensure they provide an environment free from hazards or fire risks as well as adequate space for age-appropriate activities. Assessments focus on aspects of building infrastructure (e.g., the number of children per bathroom), playground equipment safety, and related space requirements (e.g., a certain square footage per child). Regulations often also prohibit certain spaces (e.g., bathrooms and exit routes) from being used for multiple purposes.⁷

Child-Staff Ratios and Maximum Group Size
To help ensure the safety of children and quality of adult-child interactions, licensing requirements typically include both child-staff ratios and maximum group sizes. Child-staff ratios, which generally increase with the age of children in care, ensure that an adequate number of adults are present to supervise children and support regular interactions between children and staff.⁸ Group size requirements limit the total number of children in an individual classroom or space, facilitating a greater sense of community. Smaller groups also are associated with reduced risk of disease transmission, higher levels of safety, and more developmentally appropriate activities.⁹

Staff Qualifications and Background
Child care staff education and ongoing training have a positive impact on the quality of care for children of all ages.¹⁰ State child care regulations specify minimum qualifications for providers of care at all levels, although the specific requirements vary by state. States may also prescribe a criminal background check for staff and volunteers caring for children. In addition, most states require ongoing training for child care professionals, including training in children’s health and safety.

Health and Hygiene
To promote health among children in child care, regulations may monitor the safety and nutrition of the food served, immunizations for children, the maintenance of basic hygiene at facilities serving children (e.g., regular hand washing), and CPR and first aid certifications among staff.

Program Activities
Child care licensing regulations often specify the activities that child care providers must offer. This generally includes unstructured and structured time, activities that promote children’s physical and intellectual development, and meal times and rest periods. For example, regulations may require a program to offer opportunities for children to develop trusting relationships with their peers and staff and provide special interventions for children with disabilities.

State child care agencies or related offices typically monitor licensed programs to determine whether the programs are meeting requirements. The state child care agency that administers CCDF funds often also houses the licensing office that enforces requirements through program monitoring.¹¹

Challenges Associated with Licensing Afterschool Programs

According to the Children’s Foundation, all 50 states require some or all providers of school-age child care programs to be licensed or regulated.¹³ Widespread agreement exists on the need to ensure quality in afterschool programs. Yet implementation is complex, because afterschool programs differ in their goals, structure, location, and hours of operation. State licensing requirements originally were developed to meet the needs of younger children, usually from birth to age five, in center-based settings. Regulations designed with this younger population in mind often can be difficult to adapt for afterschool programs. Some states address this issue through separate or embedded school-age regulations, but the following challenges remain.¹⁴

Crafting Regulations That Are Flexible Enough to Apply to the Wide Range of Afterschool Options
Extending licensing requirements to the growing number and range of afterschool programs means addressing multiple settings, varying goals, and differing circumstances (e.g., an age group of from birth to age 12 or one that is middle-school specific). For example, under current rules, many afterschool programs would not meet staff qualification requirements as specified in their state’s child care regulations. This happens when child care regulations specify that all teachers must have training in child development, often a Child Development Associate (CDA) credential or a bachelor’s degree in early childhood education. Such a regulatory requirement would not account for the various qualifications that support effective afterschool staff, including training as an elementary or secondary school teacher, youth worker credentials, or training in areas such as arts education. With the increasing demand for afterschool programs, states are seeking ways to ensure licensing requirements promote programs serving school-age children and youth without compromising quality.

Determining Which Regulations Should Apply to Certain Programs and Settings
States sometimes exempt afterschool programs from some licensing requirements. For example, some states have opted to exempt afterschool programs that are run and monitored under the auspices of other public or nonprofit agencies. In these cases, the state assumes that a system other than the child care system will monitor quality. Some states also choose to exempt programs that care for children for a very limited number of hours per week. Some regulations designed for children spending many hours in care may not always make sense for those in programs for a limited period. For example, school-age children attending a drop-in program for one or two hours may not need a rest period. In some cases, states choose to register license-exempt programs. By registering licenseexempt programs, states maintain access to basic information on exempted providers and can encourage them to take advantage of training and other resources to improve quality. When states choose to exempt providers, it is usually for programs such as:

• Part-day programs (drop-in programs or programs operating for less than a specified number of hours);
• School-based programs that meet building codes for public spaces;
• Programs that are both school-based and school-administered and meet building codes for public spaces;
• Drop-in programs, including Boys and Girls Clubs or largely recreational programs;
• Programs that are accountable to a national group for program quality, such as Boys and Girls Club or Junior Achievement;
• Faith-based programs; and
• Military-based programs that have their own regulations.¹⁵

Although some programs may be exempt from all requirements, others may be exempt only from specific requirements. Many are exempt from subsets of requirements, particularly those related to the facilities that house the program. Further complicating the picture, some licensing requirements apply to programs regardless of CCDF funding, while other requirements only apply to programs receiving CCDF subsidies or other public dollars.

Exempting certain program types or settings can cause afterschool practitioners to question the consistency or fairness of state policies. Oftentimes, when programs are exempt from licensing requirements, questions about the health and safety of children and who is monitoring programs arise. For example, if a school-based program is exempt, it may be unclear who is responsible for certain functions that are spelled out in regulations (such as food safety, administering medication, etc). In addition, if accountability for exempt programs is not transparent, limited or incorrect information could create confusion about accountability outside of the child care system. Finally, providers exempt from some or all requirements may be seen as having an unfair advantage (lower costs) over more traditional or other center-based programs that must meet all requirements.

Acknowledging Barriers that Some Programs Face in Meeting Regulations
Even if programs agree that the licensing standards are important, meeting programming, staff training, physical environment, and other requirements can be challenging. Many programs, especially those run by smaller community-based providers and even schools, may lack the resources to meet regulations, particularly those related to facilities. For states with quality rating systems, meeting requirements at the top of the scale, which is often tied to National AfterSchool Association accreditation standards, is especially challenging.¹⁶

Addressing the Perspectives of Multiple Sponsors and Purposes of Afterschool Programs in Policy Discussions
Central to any discussion on child care licensing for afterschool programs are deeply rooted philosophical differences about the role, function, and purposes of afterschool programs.¹⁷ Although most observers agree afterschool programs should provide high-quality care, disagreements arise on what this means in practice. Differences in opinion on what programs should emphasize can create challenges in crafting licensing requirements that support varied goals and circumstances. The picture is further complicated when practices from education, childcare, youth development, and other fields are melded together to meet the developmental, physical, cognitive, and social-emotional needs of children.

Philosophical and programmatic differences in the goals of systems--particularly between the education and child care systems--translate into systemic inconsistencies. The child care system ties dollars to specific eligible children, while the education system typically ties dollars to program operation and numbers of children served. CCDF subsidies requires a parental copayment. 21stCCLC programs may charge fees, but they must use scholarships and sliding-fee payment scales to ensure their accessibility to all families, especially low-income families. These historic and programmatic differences sometimes emerge in the child care licensing arena. When programs are held accountable by different sets of regulations, resulting tensions may exacerbate turf battles. Varying requirements for similar programs can breed ill will and competition among the programs and staff.

These systemic differences can contribute to a feeling among providers within a particular system that limited resources from "their" system should not be shared with "competing" providers from other systems. Aligning child care licensing to better meet the needs of public and private afterschool settings can fuel competition for market share among providers. Real or perceived competition for resources can be an incentive to avoid compromise when it comes to improving licensing regulations for school-age programs.

Similar conflicts exist in the delivery of prekindergarten services, with most states seeking to ensure programs reach all children in need by providing services through multiple settings, including schools, child care centers, and community-based organizations. Afterschool leaders may learn from these preschool efforts that such a mixed delivery model has the potential to break the traditional barriers between education and child care and address the needs of children in working families.¹⁸

Strategies and Solutions to Make Licensing Work in Afterschool Programs

States can use several strategies to mitigate some of the unique challenges of child care licensing for afterschool programs. They can implement separate school-age regulations, add specific supplemental sections to center or family child care regulations, or embed requirements specific to school-age programs throughout child care regulations.²¹ In 2005, 13 states had separate school-age child care requirements as part of their licensing standards to address the particular characteristics and variety of afterschool programs.²² These regulations seek to more directly acknowledge the different developmental needs of youth as they enter school and move toward adolescence. For example, through the program activity sections of their regulations, states can outline desired goals for programs, such as helping youth make informed decisions; providing youth with choices in how they use their time; stimulating cognitive, physical, and social-emotional development; fostering community awareness; and encouraging increasing levels of responsibility.

In several key areas, states can seek to craft child care regulations that align to the broad range of afterschool programs. This section focuses on major areas where states are moving toward alignment with the particular circumstances and needs of afterschool programs. These areas are physical environment, child-staff ratios and maximum group size, staff qualifications and background, health and hygiene, and program activities (see the summary table "Challenges and Strategies for Licensing Afterschool Programs").

Physical Plant Requirements
Physical plant requirements are often the largest barrier for afterschool programs seeking licensure because frequently they are the most costly with which to comply. Even if funding is available, programs often operate in schools, churches, or city buildings where they have no authority over building maintenance or upkeep. In seeking to craft physical plant requirements that appropriately address the needs of school-age children and youth, policy makers should consider the following questions and possible solutions around particular challenges for afterschool programs.

Are Physical Plant Policies Age-Appropriate? A safe physical space is different for toddlers and school-age children. For example, school-age children do not need space for napping and diapering, and they may not require as much assistance as younger children in exiting a building in case of an emergency. Separate or supplemental licensing requirements for school-age children can address the age-appropriateness of physical plant policies.

Can Inconsistent Building Code Requirements Be Addressed or Streamlined? Many regulations originally established with child care centers in mind create a burden for afterschool programs in settings such as public schools, community centers, and park and recreation facilities. For example, some school-based programs report different and often more stringent district requirements during afterschool hours than during the school day. Some argue that if the school buildings are safe during the school day, then they should also be deemed safe during afterschool hours. Yet because numerous public school buildings suffer from decaying or poorly maintained infrastructure, some policymakers and child advocates contend that these spaces should not house children for additional activities until they are renovated.

States have used a few strategies to address inconsistencies in building code requirements. Most often, they are revising child care physical plant requirements to align and build on related fire and safety rules governing public facilities. One approach is adopting a uniform building code as a basis for minimum requirements and enacting additional, age-appropriate physical plant requirements for all programs serving children. A uniform code can also pave the way for more consistent monitoring.

• In Washington, the most recent revisions to the state child care regulations applied a uniform building code to all publicly supported facilities, adding age-appropriate requirements for centers and other programs on top of the requirement. Leaders chose to use the International Residential Code of the International Code Council for all state-funded facilities, including schools and child care centers.

For school-based programs in particular, some states choose to accept fire and safety code requirements as determined by education departments or individual school districts. This can reduce redundancy while providing quality assurances from another public agency.

• In South Dakota, child care regulations developed in 2001 recognize building codes and construction rules governing schools. These new regulations have eliminated the need for public schools seeking licensing to submit floor plans to both education and child care agencies.
  
  
• In Michigan, state law specifically exempts child care centers established and operated by a local school district or a state-approved nonpublic school from licensing rules with respect to fire prevention and fire safety providing that the center is located in a school building that is approved by the state fire marshal. In 2003, the law was amended to allow school-age programs operating in public schools to request exemption from all licensing regulations if (1) the program has been operating for at least four years; (2) there have been no substantial violations of the administrative rules or the act; and (3) there is a resolution of support from the local school board. They must also agree to follow "out-of-school time standards" set by the state Department of Education.
  
  
• In New Hampshire, school-based afterschool programs are exempt from local fire, health, and zoning requirements of child care licensing regulations, but several other requirements still apply. Afterschool programs that are both school-based and school-administered are exempt from all licensing requirements.

Other states require school-based programs to be licensed as a means of ensuring health and safety--particularly if there are concerns about the adequacy of the education system’s physical plant requirements.

Do Program Providers Have Authority Over the Space in Which They Operate? Afterschool programs often operate through community partnerships that seek to maximize the use of buildings in the community, such as schools, recreation centers, or places of worship. Such partnerships often result in agreements between organizations in which one party conducts program activities and monitors the children and another party owns and maintains the physical space. This can make it hard for programs that do not have control over their facilities to meet licensing requirements.

Policymakers can consider revisions to physical plant requirements that are flexible enough to cover a broader range of facilities, such as schools and faith-based organizations, while still promoting basic safety. States can also opt to provide funding and/or training support to programs seeking to meet physical plant requirements. Similarly, states may decide to provide training for licensing regulators/monitors on the different school-age program settings--especially for older children-- and the ways that school buildings and other settings can be monitored by education or other systems to enable more informed judgments on facility issues.

• The Illinois Quality Counts mini-grants program provides funds to providers, coupled with technical assistance from child care resource and referral agencies, to help providers meet physical plant and other requirements for licensing.²³

Child-Staff Ratio and Maximum Group Size Requirements
Group size and ratio requirements help to ensure adequate supervision of children. Both research and common sense indicate that adequate supervision as well as individual attention are critical to quality care for children. At the same time, the amount of individual attention needed varies greatly by age. This reasoning is reflected in the requisite child-staff ratios included in many state regulations. Some states have only two sets of child-staff ratio requirements--one for preschool-age children and one for school-age children--while others have multiple requirements that evolve and apply as children get older.

The variation in activities and structure can challenge policy makers seeking a uniform requirement for afterschool programs. In states where ratio and group size requirements are largely uniform, policymakers may want to assess whether requirements should vary by age or by type of activity. The following questions can help guide those discussions:

Can Regulations Be Tied to Children of Specific Ages? States can require different child-staff ratios and group sizes for school-age children that change as the children get older. For example, Iowa and Mississippi have different ratios for children ages 5 to 9 and children ages 10 and older.²⁴ Many states do not regulate group size; of the states that do regulate group size, many of them increase the maximum group size for older children (see "State Child-Staff Ratios and Maximum Group Size Requirements in School-Age Care for Center-Based Providers").

Can School-Age Ratios or Group Sizes Be Coordinated with Requirements for Programs Operated by Other Systems? States seeking consistent policies to promote the quality of afterschool programs require a common vision across multiple agencies. Coordination among state education departments, child care agencies, and other systems that support programs for school-age children (e.g., juvenile justice and parks and recreation) is necessary to develop requirements that meet different needs. States can consider aligning education standards and child care requirements that specify child-staff ratios and maximum group size. For example, states can review child-staff ratio or group size requirements for 21st Century Community Learning Centers and other state programs. By looking at requirements across a variety of systems, states may be able to craft regulations that are flexible enough to meet multiple needs.

Staff Qualification Requirements
When child care regulations narrowly specify staff training in early childhood development, they often do not reflect the broader range of qualifications held by school-age program staff at all levels. Afterschool directors and staff frequently have education degrees, youth worker certification, or social work or counseling credentials. Although such staff qualifications are arguably even better suited to afterschool programs, they may not meet the state’s child care regulatory requirement that all staff have early childhood development credentials. Policymakers need to consider several questions when addressing staff qualification requirements for afterschool programs.

Do Regulations Recognize a School-Age Care Credential? Many states’ child care regulations recognize a school-age child care credential (SACC) from particular institutions. SACC credentials are often aligned with National AfterSchool Association standards and provide states with a foundation for a broader range of afterschool program staff qualifications. Many states recognize these credentials, and states are increasingly developing them statewide. In 1995 Wisconsin developed a Wisconsin School-Age Credential following the United States Army model.²⁵ In the FY 2004-2005 state CCDF plans, Florida, Indiana, and New York reported having developed separate SACC credentials.²⁶ Idaho, New York, and the District of Columbia offer financial supports to practitioners pursuing a SACC credential.²⁷

Do Regulations Recognize Qualifications That Suit the Unique Staffing Needs of Afterschool Programs? Through either separate school-age regulations or a supplement to existing regulations, states can develop appropriate staff qualification requirements or competencies for afterschool providers. Rather than require caregivers in licensed centers to possess a degree in early childhood education, Massachusetts, Oklahoma, Pennsylvania, and several other states allow administrators and lead school-age caregivers to have one of several relevant degrees, such as in human services or elementary or secondary education (see "Staff Qualifications: Examples from State Regulations").

Do Regulations Recognize the Unique Challenges of Staffing Afterschool Programs? Due to their limited hours of operation, afterschool programs usually employ large numbers of part-time staff and volunteers. Staff may hold other jobs during the day (e.g., teaching) that limit their time to pursue additional training or education. The part-time nature of the afterschool workforce also makes it difficult for staff to pay for training. State leaders may want to offer training opportunities during times when staff are more likely to be available, to subsidize training or education opportunities, and to look for ways to convert part-time staff into full-time staff (i.e. hiring afterschool staff as aides during the school day.)

A final but not uncommon staffing challenge for afterschool programs relates to criminal background checks. The requirement to run criminal background checks on caregivers can be difficult for many afterschool providers to comply with, because programs traditionally rely on volunteers and have limited capacity to complete background checks. To support required criminal background checks, states can provide resources or turn to intermediary organizations to help programs perform the checks.

Program Activity Requirements
Program activities that are appropriate for children below age 5 differ widely from those appropriate for children in school-age care. For example, infant and toddler regulations may include program goals such as promoting basic verbal skills and working with parents to ease separation anxiety. School-age children, on the other hand, benefit from activities that support positive development and complement their school-day activities, including arts, physical activity, and community service. Furthermore, as children age, the developmental appropriateness of activities also changes; what is appropriate for a kindergarten student or first grader does not typically meet the needs of a fifth- or sixth-grade student. (see "School-Age Program Activities: Examples from State Regulations" below to learn how states have promoted activities that serve the interests and developmental needs of school-age youth.)

Policymakers and administrators can consider the following questions as they review licensing requirements with regards to afterschool programs.

Do Regulations Support Positive Youth Development? Licensing regulation can encourage programs to incorporate strategies and activities that support research-based principles in the youth development field. For example, regulations could specify that programs offer age-appropriate opportunities for children to exercise autonomy and participate in the selection of their own afterschool activities. States can also use licensing regulations to support schoollinked program activities that help children transition from the school day to the less structured afterschool environment. For example, the state could indicate that school-age children should experience a change of pace from the school day by being afforded opportunities to explore nonacademic interests.

Do Program Activity Requirements Encourage Explicit Linkages Between Schools and Afterschool Programs? Many child development experts cite the need for afterschool programs to build on and adapt school-day curricula and learning while providing children with experiences that do not look or feel like school. Enhanced state accountability for student achievement under No Child Left Behind makes ties between schools and afterschool programs all the more critical.²⁸ Many researchers, including the National Research Center for Health and Safety in Child Care and others, recommend that regulations encourage a minimal level of communication between teachers and afterschool providers so afterschool providers can better understand the child’s behavior and needs.²⁹ Regulations can also specify that time be set aside during afterschool programs for homework completion and assistance. Finding ways to allow afterschool program staff to straddle the school day is one strategy for making this important link.

Other Child Care Licensing Requirements
Additional requirements typically included in state regulations cover the following areas:

• hygiene and health promotion;
• nutrition and food service;
• processes for serving children with disabilities;
• immunization requirements; and
• monitoring and enforcement.

Seemingly minor requirements can create complexities for programs. In states where schoolbased afterschool programs must be licensed, schools sometimes face conflicting requirements. For example, in some jurisdictions, schools are required to use one type of bleach to clean classrooms under education regulations and another type of bleach to clean classrooms under child care regulations. Flexibility and improved training of monitors can help eliminate some conflicts in the application of regulations.