P.O.Box 34401 

  Cordova Tenn.  38134

Telephone: 901-691-9396                               Fax; 901-552-4283

www.mycpea.com

 6/7/2008                                         gharris@mycpea.com

The Honorable Phil Bredesen
Tennessee State Capitol
Nashville, TN 37243-0001

Dear Governor Bredesen:

As your constituent, I am writing this letter to urge you and your appropriate state agencies to act swiftly to implement the state requirements under the Workforce Investment act.

Tennessee. Department of Human Services Childcare licensing office refuses to recognize the training and/or Credentials of Career Training Institute. Career Training Institute is authorized by Tennessee Higher Education and in good standing.  The definition outlined in DHS’s rule’s are as follows.

• Chapter 1240-4-3licensure rules for child care centers (9/03/2006)
• 1240-4-3-.01 scope and purpose. 1240-4-3-.02 definitions.
•  For purposes of this Chapter, the following definitions are applicable
• (8)  C.D.A. Child Development Associate. An early childhood educational credential granted by the National Council for Professional Recognition

 Workforce Investment Act of 1998(Public Law 105-220),  provides the framework for a unique national workforce preparation and employment system designed to meet both the needs of the nation’s businesses and the needs of job seekers and those who want to further their careers. Title I of the legislation is based on some of these following elements:

• Training and employment programs must be designed and managed at the local level where the needs of businesses and individuals are best understood.
• Customers must be able to conveniently access the employment, education, training, and information services they need at a single location in their neighborhoods.
• Customers should have choices in deciding the training program that best fits their needs and the organizations that will provide that service. They should have control over their own career development.ect…

 National Council for Professional Recognition was created by National Association for the Education of Young Children (NAEYC). This program is in Washington DC.

Millions of Tennessee Dollars are feeding Washington DC’s economy each year by DHS rule concerning the CDA Credentials.

Through Career Training Institute (CTI), Tennessee offers an equivalent CDA training program authorized by Tennessee Higher Education Commission. This program would keep million of Tennessee training dollars in our state stimulating our economy. Other states, including The State of Mississippi opts to Credential their own childcare staff thus keeping that money in their state. Our goal is to keep our training dollars in Tennessee.

Tennessee childcare centers have an obligation to provide high quality care for children, as well as to ensure high standards in teaching, research and public service. Therefore, each Center’s teachers should seek and maintain a Child Development Associate Credential.

Department of Human services rule takes away the choice of the students in deciding the training programs that best fits their needs.

When The Department of Human Services refuses to accept the training Credentials of a State Authorized training facility, it constitutes a violation in the regulations of Title VII of EEOC. This violets the Sherman Trust Act and is a monopoly.

The Sherman Anti-Trust Act of 1890

SECTION 2 Every person who shall monopolize, or attempt to monopolize, or combine or conspire with any other person or persons, to monopolize any part of the trade or commerce among the several States, or with foreign nations, shall be deemed guilty of a felony, and, on conviction thereof, shall be punished by fine not exceeding ten million dollars if a corporation, or, if any other person, three hundred and fifty thousand dollars or by imprisonment not exceeding three years, or by both said punishments, in the discretion of the court.

I urge you to remove the unfair and discriminatory rule #8 of 1240-4-3-.01 scope and purpose. 1240-4-3-.02 definitions .This restricts the public’s ability to choose their training providers, while providing preferential treatment only for the market makers and industry insiders. Removing this rule would guarantee that every childcare provider would have the choice in their training providers without discrimination.

It is of critical importance to the maintenance of fair markets that you

level the playing field for the public with regard to private training facilities.

Respectfully,

Geraldine Harris

President CPEA

cc: file

U.S. Department of Labor
Alexis M. Herman, Secretary

Employment and Training Administration
Ray Bramucci, Assistant Secretary

Office of Policy and Research
Gerard F. Fiala, Administrator

rep.barbara.cooper@legislature.state.tn.us 

rep.ulysses.jones@legislature.state.tn.us

rep.leslie.winningham@legislature.state.tn.us