SOW Attachment 3 - Final Response to VCAP PSRDM Deviation Request.pdf

Department of Veterans Affairs

Date: August 30, 2023 From: Office of Healthcare Engineering

Subj: Code/Design Deviation Request Response Short Term Childcare – VA Kids Care

To: National Director of Veteran Childcare Programs

Summary of Request (Include project details, location of request, other implications) The Veterans Childcare Assistance Program (VCAP), is requesting a waiver from the PRSDM for the following sections of 5.3 Childcare Development Center;

5.3.1 Adjacencies

When located within a portion of a main VA facility, such as a hospital, Childcare/Development Centers must be located on the ground floor away from the main building entrance with separate access area for drop-off and pick-up. The Childcare facility must also be remote from ambulatory care, Pharmacy, radiology, prosthetics, supply services, loading docks, mail rooms, agent cashier, fire department, and police operations and holding rooms.

5.3.3 Construction

Enclose outdoor play areas with fences that prevent access by unauthorized persons and prevent children from leaving the designated area.

VCAP is also requesting a waiver from following space requirements in PG18-9 for Section 420 Childcare Development Center (va.gov)

VCAP is requesting a waiver from sections of the ”5.3.1 Adjacencies” because the functioning and the target audience of the VCAP program is significantly different from a full-time Day Care Center. The VCAP model (VA Kids Care) is designed for short-term, drop-in childcare for Veterans while they attend medical appointments at the VAMC. The frequency of turn-over and relation to the medical appointments are of significant impact to the location of the VA Kids Care center. The VA Kids Care should be located in close proximity and with easy access to the outpatient clinics to the extent possible. The duration of this childcare function is anticipated to be between thirty minutes to three hours. The ground floor of a Medical Center is typically designated for clinical needs. Requiring this location for the VCAP to be on the first floor for a short-term childcare function may create a burden on patient care.

Allowing other floors and locations for this function creates flexibility for implementing this program. This flexibility is needed to make the program feasible as an amenity for Veterans using the VAMC services.

VCAP is also requesting a waiver from the need of a “separate access area for drop off and pick up” and requiring the facility to be located remotely from “ambulatory care, Pharmacy, radiology functions”. These functions are typically focused on Veteran Outpatient Care, which would be a prime user of the VCAP amenity. VCAP is in agreement with having the VCAP function remote from “prosthetics, supply services, loading docks, mail

Memorandum https://www.cfm.va.gov/til/space/spChapter420.pdf https://www.cfm.va.gov/til/space/spChapter420.pdf rooms, agent cashier, fire department, and police operations and holding rooms”, as these functions would not be conducive to the VCAP program function.

VCAP is requesting a waiver from the space requirements of PG18-9, section 420, as these space requirements were developed for a full-time childcare function with the needs for feeding children, providing academic curriculum, allowing children an outdoor play area, and many of the other support spaces needed for a typical eight to ten-hour full-time Child Care Center. A full-time daycare space program was run using section 420 for the VCAP function and it required space of about 2,000 square feet. This size was required due to the space required for support functions which are not applicable to this short-term drop-in child care function. VCAP anticipates needing 600 to 1,000 square feet to allow for the care of 6 to 8 children during high volume times, and only 3 to 4 children during other times of the day.

Typical VCAP Space Requirements of approximately 600 Square Feet.

Space includes:

ADA Toilet Room with Changing Table Options 60 sq. ft.

Entry for General Control 80 sq. ft.

Sink/ Cabinets for handwashing/ Ref. 20 sq. ft.

Open Area for General Childcare 450 sq. ft.

Total Area 610 sq. ft.

Recommendation and Details: ☒ Clarification ☒ Disapproval of Waivers Details, Clarifications, and Requirements associated with disposition:

The Healthcare Engineering Oversight Committee on Physical Security and Resiliency has conducted a thorough review of the facility’s request. Details of the committee’s analysis and recommendations are below:

1. Short-Term Care: The committee acknowledges the operational plan for VA Kids Care facilities for short-term and drop-in childcare as unique from a full-time childcare facility, which may require designs to address the specific purpose and function.

However, it must be clarified that the “user” and beneficiary of the service is the child(ren) under care. VA’s responsibility is to ensure the safety and security of the user, whether the child(ren) is there all day or for a shorter period. Furthermore, the fact that the turnover is more frequent and unplanned creates significantly more risk to the user, as it is impossible to plan for the duration, volume or type of individual that may present for service. Given this characterization, the committee does not agree that this arrangement presents less risk.

2. Location within Building: The committee acknowledges that ground floor spaces are at a premium in VA medical centers but notes that ground floor spaces offer logistical and life safety benefits that are not present at other floor levels. The committee is not willing at this time to recommend approval of a deviation from the requirement to locate childcare facilities on ground floor levels.

3. Space Entrances: PSRDM section 5.3.1 requires that childcare facilities have “separate access area for drop-off and pick-up.” The committee notes that these separate access areas are not required to be additional building entrances, but that the childcare facilities must have entrances compliant with PSRDM section 5.3.2.

requirements, whether inside or external to existing buildings.

4. Functional Adjacencies: PSRDM section 5.3.1 requires that the childcare facilities be “remote” from certain functional areas. The committee considers this requirement to be achieved if the childcare function is (1) not embedded within any of the identified spaces, (2) has separate entry doors (may be interior to the building), (3) is located with access from a separate hallway or vestibule/atrium area from the identified functional areas, and (4) is not located on a main building passageway or egress path.

Compliance is required with other separation requirements identified in the PSRDM, e.g., PSRDM section 5.10.1.1. requires that “Loading Docks cannot be located adjacent to or within 50 feet (15 m) of the following…Childcare/Development Centers…”

5. Outdoor Play Areas: The PSRDM is not intended to mandate the inclusion of outdoor play areas as part of childcare spaces. However, if outdoor play areas are constructed or available, they must be compliant with the requirements of PSRDM section 5.3.3.

6. Recommendation: The committee recommends disapproval of any deviations from the PSRDM requirements (item 2). The committee also offers the following response in the form of clarification to the requirements of the PSRDM as detailed above (items 3, 4, and 5).

7. Facility Deviations Requests: Facilities in which VA Kids Care facilities are to be implemented may request deviations from, or interpretations of equivalency to, specific PSRDM requirements as part of the project planning; the submissions should include physical security assessments of the proposed space(s) and indicate how the proposed alternative will meet or exceed the physical security protection of the space if it were compliant with PSRDM requirements. The submissions should also include proposed operational plans for the functionality of the spaces, e.g., how staff will ensure appropriate supervision of children, how the facility will plan for varying populations on different days and at different times, how the staff will respond in emergency situations, and how access control will be maintained.

8. Architectural Deviation Request: Note that this review and response is limited to compliance with PSRDM requirements. Feedback and a determination on the space/architectural request will be provided under separate cover.

Recommend Disapproval of Waiver Disapproved

Co-Chair, Healthcare Engineering Committee on Physical Security and Resiliency

Vincent Rizzo, PE Director, Office of Healthcare Engineering

Requires Design Manual Update ☐