Vermont center-based child care license: the CBCCPP process

The rulebook and the rules in practice are not the same document

Vermont’s center rules are the Licensing Regulations for Center Based Child Care and Preschool Programs. They took effect April 17, 2022 for every new application and every existing license.⁠² Since then, CDD has changed several requirements by memo rather than by formal rulemaking, so reading the rule PDF alone will mislead you in at least three places:

• Director time on site. Rule 6.2.4.1 requires the program director to be present 60% of the hours of operation. Act 76 of 2023 directed CDD to lower that to 40% of the time children are present. CDD granted every center a variance to that effect, retroactive to July 1, 2023, and it lasts until new CBCCPP rules take effect.⁠²⁠⁷
• Substitutes’ training. Effective October 1, 2024, substitutes are no longer fully exempt from annual professional development. They must complete four hours a year, on top of any CPR and first aid certification.⁠⁶
• Emergency plans and immunizations. The same October 1, 2024 memo adds a family reunification process to the required emergency response plan. It also allows a grace period of up to six months for children experiencing homelessness or in foster care to produce immunization records.⁠⁶

CDD posted draft revisions of the center rules in November 2025 and held a webinar on them on November 17, 2025. The public comment period on the drafts has closed, and CDD’s proposed rules page lists “None at this time” under final proposed rules as of 2026-10-12.⁠⁸ The draft carries over the 35 and 75 square foot space standards and writes the 40% director rule into the text.⁠¹⁰ Until a final rule is adopted, the 2022 rules plus the memos are what your licensor will apply.

Does your program need a CBCCPP license?

Under 33 V.S.A. § 3502, no one may operate a child care facility without a license unless exempt.⁠¹ The center rules define a CBCCPP as a program that provides care, education and supervision to children outside their own homes for less than 24 hours a day, “on a regular or continuous basis, whether or not for compensation.”⁠² A nonprofit or free program is covered as well.

Programs the rules treat as CBCCPPs:

• Pre-kindergarten programs run by public and private schools. Public school pre-K has its own list of rule exceptions in section 8.2.⁠²
• Programs serving non-recurring clientele, such as drop-in or seasonal care. A program open six months or less in any 365 days gets a license term applying the section 8.1 exceptions to all children and staff.⁠²

Exempt from licensing:⁠¹⁠²

• Care for children of no more than two families other than your own.
• Hospitals and Department of Health-licensed establishments, and recreational or therapeutic programs, unless the child care is more than incidental to their main purpose.
• Care run by a religious organization during religious services or church-sponsored activities.
• 21st Century Community Learning Centers afterschool programs overseen by the Agency of Education, unless they join the Child Care Financial Assistance Program.
• Recreation programs that meet one of four limits:
  • for children aged 3 to 5, under four hours a day and no more than 13 weeks a year;
  • for school-age children, no more than 13 consecutive weeks;
  • no more than four hours one day a week, or two hours two days a week;
  • a single skill-based activity for children 3 and older.

Two boundaries to check before you choose a license type:

• Family homes. A home-based program is registered or licensed as a family child care home under separate rules (see Vermont registered family child care home). Statute bars anyone who holds a child care facility license from also running a family child care home, and the reverse.⁠¹⁠²
• School-age programs. Afterschool programs have their own rule set, the Afterschool Child Care Program regulations.⁠³

The three-phase application

CDD runs every center application in three phases.⁠³ The Phase I and Phase II resource guides (both revised January 10, 2024) set out the actual sequence:⁠⁴⁠⁵

1. Set up the business entity (Phase I)

   Register the business with the Vermont Secretary of State; municipalities and school districts skip this. Get an EIN from the IRS and keep the IRS letter, because you must send a copy. Then complete the CBCCPP Governing Body Form.⁠⁴ The rules require corporations, partnerships and associations to identify every governing body member, the officers and their terms, and the designated representative.⁠²

2. Submit the financial form

   Send CDD an IRS W-9. The guide warns that the form must be either fully handwritten or fully typed, with no cross-outs or white-out. Digital signatures are not accepted.⁠⁴

3. Request an application in BFIS

   On the BFIS site, use “Apply Online to Become a Licensed Provider” and submit the Initial Visit Request. Enter legal names only.⁠⁴

4. Start background clearance

   The proposed licensee submits a Records Check Authorization Form, followed by fingerprinting.⁠⁴

5. Email the Child Care Business Technician

   assigned to your town, with the IRS letter, Secretary of State registration, Governing Body Form, W-9 and Records Check form attached. Missing items come back as a “Missing Items Letter” in your BFIS account.⁠⁴

6. First licensor visit (start of Phase II)

   Once your Phase I documents are processed, a licensor contacts you within three to four business days to schedule a visit to the proposed site. The licensor reviews the location and your business plan and explains what Phase III will check.⁠³⁠⁵

7. Assemble and enter the Phase II application

   This covers tax and child support standing, insurance, floor plans with room sizes in square feet, zoning, fire safety, water and wastewater, lead testing, staff qualifications, written policies and the emergency response plan. You enter everything in BFIS.⁠⁵ Phase II is complete when the BFIS application is complete and background clearance letters have been issued for the licensee and proposed program director. Staff qualifications must also be documented in their BFIS Quality and Credential Accounts.⁠⁵

8. Final visit (Phase III)

   A licensor contacts you within three to four business days to schedule the final site visit. The licensor issues a site visit report within five days of it, and you must complete any required actions. A licensing supervisor then makes the decision, and the approval or denial letter appears in BFIS. A denial letter states the reasons and your appeal rights.⁠³⁠⁵

A new applicant may receive a provisional license, valid for up to one year, while full compliance is still being determined. You must follow a written compliance plan that CDD has approved during that period.⁠² CDD does not publish an overall processing time for a new license. Licensing questions go to the Licensor on Duty at 1-800-649-2642, option 3, or [email protected].⁠³

Zoning, fire, water and lead: start these first

CDD’s Phase II guide says the most time-consuming parts of the application are zoning, fire prevention compliance, water and wastewater permits, and drinking water testing.⁠⁵ The phases do not have to be done in order, so these can start before you sign the rest of the paperwork.

• Zoning. You must meet the town’s zoning bylaws. The zoning approval must be recorded in the municipal office, and a copy goes with the initial application. A center in an approved public or independent school building does not need to send zoning documentation.⁠² If your town says no zoning approval is needed, record the name, title and phone number of the official you spoke with and the date of the call, and put that in the application.⁠⁵
• Fire safety and accessibility. The center must meet Vermont Division of Fire Safety requirements and the Americans with Disabilities Act.⁠² Some towns’ municipal offices handle fire paperwork and inspections. Elsewhere you contact the regional Division of Fire Safety office to start the occupancy permit.⁠⁵ Once open, you must keep fire systems inspected, keep fire extinguishers tagged, and run evacuation drills at least monthly, with everyone out in under three minutes.⁠²
• Water and wastewater. If the Vermont Water Supply Rule or the Wastewater System and Potable Water Supply Rules require permits, they must be submitted with the initial application.⁠² The Agency of Natural Resources decides whether permits are required, and you send the permits or a Project Review Sheet. If you will cook meals on site, ANR’s approval for meal preparation must be noted on those documents.⁠⁵ Meal approval also appears on the license itself.⁠²
• Drinking water testing. Every tap that could be used for drinking, cooking or brushing teeth must be tested for lead under 18 V.S.A. chapter 24A. Until at least one outlet meets the standard, you must provide bottled water.⁠²⁠⁵ A center on a private water system must also test for total coliform, arsenic, uranium, nitrite, manganese, nitrate and fluoride at a state-certified lab, and must repeat the chemical tests every six years.⁠²
• Lead paint. If the building was built before 1978 and has not been certified lead-free, Essential Maintenance Practices must be performed before licensure under the Vermont Lead Law.⁠² The EMP covers the whole building, including later additions, porches and decks. A certified person must file a compliance statement with the Department of Health every 365 days.⁠⁵

Space and bathroom minimums

Hallways, bathrooms, offices, food preparation areas and cubby or storage areas do not count toward the 35 square feet, and furniture that restricts free movement also comes off.⁠²⁠⁵ The bathrooms counted toward the 1-per-15 ratio may be used only by children, parents and program personnel while the center is open.⁠² Children under 36 months require safety gates on accessible stairways.⁠²

Who can direct the center

The program director must be at least 21. The required qualifications depend on the capacity written on the license:⁠²

At 13 children or more, the director must also finish a three-credit, CDD-approved course in managing an early care program, including budgeting and financial management, within a year of starting. The alternative is to employ a business manager. Before initial licensure you must document that the business manager holds at least an associate degree in Business.⁠²

The director’s education, training and experience must be in their BFIS Quality and Credential Account before initial licensure.⁠² Changing directors later requires notice to CDD before the change.⁠²

Staff tiers and ratios

Vermont defines staff by tier, each with a minimum age and an approved route of credentials:⁠²

• Teacher: at least 20. Career Ladder Level 4, a relevant bachelor’s degree with 12 months of experience, or an Agency of Education teaching license with an early childhood or elementary endorsement.
• Teacher associate: at least 20, with a high school diploma or GED. Career Ladder Level 3, a relevant associate degree with 12 months of experience, the Registered Child Care Apprenticeship certificate, or 21 early childhood credits with 12 months of experience.
• Teacher assistant: at least 18, with a high school diploma or GED. Career Ladder Level 1 or 2, or a CDA with 12 months of experience.
• Trainee: at least 15. Trainees aged 15 to 17 must be directly supervised and may never be left alone with children.
• Classroom aide: at least 18. Aides do not count in ratio.
• Substitute: at least 18, with a high school diploma or GED.

A mixed-age group follows the ratio and group size for its youngest child. Staff members’ own children count in ratio whenever they are present.⁠² Other staffing rules from section 6.2.4:⁠²⁠⁷

• Each group must be led by at least a teacher associate for 75% of the hours of operation.
• At least one teacher assistant or higher must be present whenever children are.
• When seven or more children are present, a second adult who could help in an emergency must be within direct hearing distance.
• The director must be on site at least 40% of the time children are present, under the Act 76 variance.

A violation of group size or staffing requirements is a “serious violation,” which can trigger a mailed parental notification letter.⁠²

Background checks and training before staff work alone

The initial application must include Records Check Authorization forms for the licensee, every staff member and every auxiliary staff member, such as cooks and janitors, followed by fingerprinting.⁠² CDD must finish clearances within 45 days of the Vermont Crime Information Center receiving all documents. It may reuse a check completed within the last five years.⁠² Rule 2.3.8.2.6 lists the convictions and findings that bar a person from operating or working in a center. A few of them, including fraud and drug offenses within five years, allow the person to request a variance from the Commissioner.⁠² After opening, every staff member must resubmit a Records Check Authorization at least every five years.⁠²

Training required by the rules:⁠¹⁠²⁠⁶

• Orientation. Each staff member must complete a CDD-approved orientation before being left alone with children. Statute adds orientation on preventing and reporting child abuse, including sexual abuse and grooming, for everyone working at the facility. CDD treats the mandatory reporting training as separate from general orientation.⁠⁴
• First aid and CPR. At least one person certified in pediatric first aid and infant/child CPR must be on the premises at all times. Every staff member counted in ratio must be certified within three months of starting.
• Annual professional development. Each staff member needs an Individual Professional Development Plan within six months of starting and 15 clock hours of professional development a year, logged in BFIS. CPR and first aid do not count toward the 15 hours. Substitutes owe four hours under the October 2024 memo.

Written policies and the insurance certificate

Your application must include a written emergency response plan.⁠⁵ Since October 1, 2024, it must include a process for reuniting children with their families.⁠⁶ You also need a written parent handbook or equivalent. Rule 4.7 lists more than 20 required topics,⁠² among them:

• your drinking-water lead test results and any remediation plan;
• your expulsion policy;
• unannounced parent access;
• the Child Care Consumer Line number, 1-800-649-2642.

You must carry liability insurance “of a reasonable amount,” plus transportation insurance if you transport children. The rules set no dollar minimum.⁠² The certificate of liability insurance must name the Child Development Division as certificate holder.⁠⁵ Each applicant must also certify good standing on Vermont taxes (32 V.S.A. § 3113) and child support (15 V.S.A. § 795).⁠²

Fees

Neither the CBCCPP rules, 33 V.S.A. § 3502, nor CDD’s Phase I and II resource guides list a license or application fee for a center (as published on 2026-10-12).⁠¹⁠²⁠⁴⁠⁵ CDD’s licensing page does not list one either.⁠³ Ask the Licensor on Duty (1-800-649-2642, option 3) whether any fee applies before you budget. Expect separate costs from other agencies, such as lead and bacterial water tests, fingerprinting and any zoning or Division of Fire Safety permits, which the guides do not price.

The license, annual visits and renewal

The posted license shows the status (full or provisional), the effective and expiration dates, the maximum number of children at one time, the ages served, any terms, and whether meals are approved.⁠² A full license lasts three years.⁠² Within that period:⁠²

• Annual requirements. CDD sends notice 60 days before each license anniversary. Annual requirements must be done by the anniversary: background checks, staff qualifications and professional development, lead EMP, and proof of continuous insurance.
• Visits. CDD must make a licensing visit at least once every 365 days and may inspect at any reasonable hour.
• Posting. Site visit reports and violation notices must be posted for parents for at least 15 days. CDD posts violations on the BFIS public site for at least five years.

For renewal, CDD sends a BFIS notice 60 days before expiration. CDD recommends applying at least 45 days ahead and warns that applications sent within 15 days of expiration may not be processed in time. A timely, complete application keeps your license in force until CDD decides. If your license expires, you must close and reapply as a new program.⁠²

You must notify CDD before any of these changes:⁠²

• changes to indoor or outdoor space;
• a new name, Taxpayer Identification Number, capacity or age range;
• a new director or a new designated representative.

Each site needs its own application, although several buildings at one location may share a single license.⁠² If you disagree with a regulatory action, you have 30 days to appeal in writing, either to a Commissioner’s Review or directly to the Human Services Board.⁠²

Buying an existing center

A license cannot be sold or transferred, so a buyer goes through the full three-phase application as a new licensee. The seller’s license becomes void at the sale.⁠² CDD’s Phase II guide tells buyers to submit Records Check Authorization forms for the staff who will work for them.⁠⁵ It also says to ask the seller early which supplemental programs the center is enrolled in:⁠⁵

• STARS;
• Specialized Child Care;
• the Child Care Financial Assistance Program (CCFAP);
• Prequalified Prekindergarten;
• the Child and Adult Care Food Program.

None of those enrollments transfers automatically, and re-enrolling in each is the buyer’s job, separate from the license.⁠⁵

CCFAP, STARS and prekindergarten funding

CCFAP is Vermont’s child care subsidy, paid to programs on behalf of eligible families. Under Act 76, CCFAP pays based on enrollment rather than attendance: a center’s payment for a child with a certificate is not reduced for occasional absences. Since July 2, 2023, CCFAP state rates no longer depend on the center’s STARS rating.⁠⁹

STARS, Vermont’s quality recognition system, still matters for revenue. A center needs STARS level 3 or higher to be a Specialized Care provider and level 4 or 5 to prequalify for Universal Prekindergarten.⁠⁹ For a child enrolled in Universal Prekindergarten, the 10 weekly hours of publicly funded pre-K are deducted from that child’s CCFAP certificate.⁠⁹

For the statewide picture across care types, see child care center licensing.

Sources

1. 1
   Vermont General Assembly, 33 V.S.A. § 3502, Licensing; registration; exemptions Checked 12 Oct 2026 · Back to text ↑
2. 2
   Vermont Department for Children and Families, Child Development Division, Licensing Regulations for Center Based Child Care and Preschool Programs (effective April 17, 2022) Checked 12 Oct 2026 · Back to text ↑
3. 3
   Vermont Department for Children and Families, Child Development Division, Licensed Home or Program Checked 12 Oct 2026 · Back to text ↑
4. 4
   Vermont Department for Children and Families, Child Development Division, Vermont Child Care Licensing Application: Phase I Resource Guide (revised 1/10/2024) Checked 12 Oct 2026 · Back to text ↑
5. 5
   Vermont Department for Children and Families, Child Development Division, Vermont Child Care Licensing Application: Phase II Resource Guide (revised 1/10/2024) Checked 12 Oct 2026 · Back to text ↑
6. 6
   Vermont Department for Children and Families, Child Development Division, Memo: Child Care Licensing Rule Changes for CBCCPP, effective October 1, 2024 Checked 12 Oct 2026 · Back to text ↑
7. 7
   Vermont Department for Children and Families, Child Development Division, Memo: Program Director Time On-site (July 11, 2023) Checked 12 Oct 2026 · Back to text ↑
8. 8
   Vermont Department for Children and Families, Child Development Division, Proposed Rules (child care licensing) Checked 12 Oct 2026 · Back to text ↑
9. 9
   Vermont Department for Children and Families, Child Development Division, Act 76 Frequently Asked Questions (June 2024) Checked 12 Oct 2026 · Back to text ↑
10. 10
    Vermont Department for Children and Families, Child Development Division, Licensing Rules for Center Based Child Care and Preschool Programs, draft revisions (November 2025) Checked 12 Oct 2026 · Back to text ↑

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