The Sephardic Community Federation (SCF) played a critical role in successfully reaching an agreement with the New York City Department of Health and Mental Hygiene (DOH) that would improve the health and safety of our children, and prevent the possible closure of yeshivot throughout New York City. The agreement came in the wake of newly proposed regulations by the DOH.
The significant financial investments necessary to comply with the new regulations and the drastic change in policy led many yeshivot throughout the city to become concerned that these new requirements would ultimately lead to their closure or would have forced them to increase tuition.
Pursuant to Article 47 of the New York City Health Code, a religious school is currently not required to have a permit to operate a day care service if it is part of an elementary school. The DOH recently announced plans to modify Article 47 and rescind the NPR (No Permit Required) exemption for religious schools throughout New York City. As part of its proposal, the DOH set forth a long list of requirements with which religious schools would have to comply. The proposed changes would require all child care services for children less than six years of age to hold a DOH permit.
SCF, the umbrella government relations and public policy organization of the Sephardic Jewish community, which has nearly 10,000 students in yeshivot, got involved and worked to ensure that the DOE recognized the myriad concerns and possible complications associated with its proposal.
SCF Executive Director David Greenfield sent a letter to DOH Commissioner, Dr. Thomas Frieden requesting that the public comment period on the proposed regulations be extended in order to provide schools ample time to respond on this critical issue.
“The safety of our children is of paramount importance to us and the responsibility of operating child care facilities is something that our community takes very seriously,” Greenfield wrote. “It is therefore impossible for an issue of this magnitude to be properly analyzed and addressed in such a short time period. We believe that additional time is required in order to thoroughly review the department’s proposed modifications to Article 47 and to properly assess the inevitable impact that they would have if they are ultimately enacted.”
Greenfield had several conversations with the Commissioner regarding this issue, at which point his office agreed to extend the public comment period. By doing so, the Commissioner delayed the impending implementation of the new regulations and provided yeshivot with additional time to study the proposal and respond accordingly.
Among the proposed regulations is a certification requirement for teachers. For example, teachers of children between the ages of two and six would have to have a college degree and New York State certification. Currently, there are many yeshivot whose teachers do not meet this requirement.
Greenfield noted that the primary area of concern was that the DOH was attempting to regulate not just health and safety issues, but curriculum issues as well. Greenfield, together with several other prominent Jewish community leaders, met with Commissioner Frieden and explained to him that any reasonable regulation that pertains to improving the health of our children and keeping them safe is certainly welcome; however, the certification requirements and the teacher to child ratio were particularly troubling.
After much discussion, Commissioner Frieden agreed in principle to remove any of the proposed requirements that would affect how the yeshivot educate their students. The Commissioner agreed that the DOH would only seek to regulate areas which fall under the heading of health and safety.
“By listening and responding to our concerns, Commissioner Frieden demonstrated that he truly understands the unique needs of yeshivot. I thank the Commissioner for his willingness to work together with us to improve the health and safety of our children,” said Greenfield
“We are committed to protecting our children, just as I know Commissioner Frieden is committed to protecting our children,” said SCF President Sam Sutton, “There is nothing more important than the safety of our children, and we look forward to joining together with the DOH to achieve that objective.”
