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A rule proposed by the Department of Health will make it increasingly difficult for summer camp operators to maintain adequate staffing ratios needed to ensure that working parents have access to summer programming for school-aged youth after schools close in June, NJBIA says.  

In recently submitted comments on the proposed rule, NJBIA Vice President of Government Affairs Althea D. Ford noted that camp counselors, who are primarily between the ages of 18 and 23, already undergo name-based criminal history background searches as a condition of employment, which provide quick results.   

Requiring prospective hires to be fingerprinted as well by June 15 as part of a criminal background check process, however, will flood the state-contracted agency processing fingerprint applications with tens of thousands of applications in a short time period, she said. This will lead to hiring delays impacting mandated staffing ratios and consequently leave working parents without the childcare they had been counting on. 

“This rule proposal fails to consider the operational timeline for youth camp operations,” Ford wrote in her April 19 letter to the state Department of Health. 

“If adopted, there will be an influx of over 40,000 to 50,000 individuals across private, nonprofit and municipal camps attempting to schedule and secure fingerprinting appointments over the next 6-8 weeks with approximately 20 state-contracted IdentoGo locations prior to beginning their June 2024 summer camp employment,” Ford said. 

“This swell of requests will overwhelm the current fingerprinting system and will create detrimental operating delays for youth camps,” Ford said.  

“The rule proposal places camps at significant risk of non-compliance and creates uncertainty every pre-season when fingerprinting appointments cannot be completed, results are delayed, and camps cannot meet ratios,” Ford said. “Consequently, camps will have to limit enrollment when staff are unable to start working, thus limiting access to school-aged summer programming.” 

Childcare, and programming for school-aged children during the summer, is essential to working parents and the lack of or inconsistent access to care challenges their ability to show up for work, Ford said. 

“As proposed, the Department’s rules will hinder the delivery of vital care services for the over 100,000 children that utilize camp services during the 2024 summer season and will place an undue burden on the providers that seek to offer these services,” she said.