This MTL Replaces CCCMPL 41 and FCCMPL 33.

Background:

On November 28, 2022, the Ohio Department of Job and Family Services (ODJFS) implemented two new policies to expand age requirements for child care workers. The new policies were outlined in Child Care Center Manual Procedure Letter (CCCMPL) 41 and Family Child Care Manual Procedure Letter (FCCMPL) 33. High school students/graduates are now permitted to work as a child care staff member (CCSM) in a limited capacity in licensed child care centers and family child care homes. As a CCSM, high school students and high school graduates under the age of eighteen are to meet all CCSM requirements outlined in Chapters 12 and 13 of the Ohio Administrative Code (OAC). 

Rules 5101:2-12-08 and 5101:2-13-08 are effective January 27, 2024

Revised rules:

Rule 5101:2-12-08 "Employee and child care staff member requirements for a licensed child care center"

• Add criteria for enrolled high school students and high school graduates under the age of eighteen to work as CCSM.
• Add a new appendix D to rule 5101:2-12-08, outlining limitations on child supervision and safety requirements for high school students and high school graduates.

Rule 5101:2-13-08 "Employees, child care staff members and substitute responsibilities and qualifications for a licensed family child care provider"

• Add criteria for high school graduates under the age of eighteen to work as CCSM.
• Add criteria outlining limitations on child supervision and safety requirements for high school graduate.
• Revise appendix A to update age requirements for family child care staff members

Additional Information:

For child care centers, supervision of the high school students is the responsibility of the child care center administrator. The center administrator is also responsible for ensuring that another CCSM is assigned to work with the high school student and does not leave them alone at any time when supervising children.

Two new roles are available in the Ohio Professional Registry (OPR) for these child care staff members to use when they create their employment record for the program in the OPR. These roles include "High School Junior" and "HS Senior or Graduate <18."

Child care programs employing minors as a CCSM are to comply with Ohio Minor Labor Law requirements for those less than 18 years of age; including, but not limited to working permits, wage agreements, work hours, and student documentation, as outlined in Chapter 4109. of the Ohio Revised Code (ORC).

Please contact the Child Care Policy Help Desk at childcarepolicy@jfs.ohio.gov or 1-877-302-2347, option 4, if you have any questions.