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Home Daycare License Requirements in Massachusetts (2026)

Opening a home daycare in Massachusetts means getting a family child care home license from the Massachusetts Department of Early Education and Care. Here is exactly what that takes in 2026 — your capacity limit and ratios, the training and background checks, the application steps, and the postings and enrollment forms you need — sourced to the state’s own rules and dated.

In brief — Massachusetts

Licensing agency
Massachusetts Department of Early Education and Care
Program / rule
Start by deleting a phrase you have almost certainly been given: in Massachusetts there is no such thing as a "large family child care home" license. The phrase exists in the statute, and it exists in guides copied from the statute, but it does not exist in the rulebook that decides your file. Search the full 54-page text of 606 CMR 7.00 as the Department of Early Education and Care and the Secretary of the Commonwealth both serve it on 26 August 2026 and the string "large family" appears exactly zero times. What the regulation defines instead, at 606 CMR 7.02, is a single license class: "Family Child Care - Temporary custody and care provided in a private residence during part or all of the day for no more than ten children younger than 14 years old or children younger than 16 years old if such children have special needs. Family child care shall not mean an informal cooperative arrangement among neighbors or relatives, or the occasional care of children with or without compensation therefore." One class, ceiling of ten. The statutory two-tier scheme of "family child care home" capped at six and "large family child care home" above six survives in M.G.L. c. 15D, Sections 1A, 2(c), 6(a), 7(a), 7(b), 7(d) and 8(c), but the Board of Early Education and Care collapsed it into one regulatory class when 606 CMR 7.00 replaced 102 CMR 7.00 and 8.00 on 22 January 2010, and it has stayed collapsed ever since. If a checklist tells you to apply for a "large family child care license," there is no such application in LEAD. There is one family child care application, and what varies is the number you are licensed for. What actually varies with capacity is your qualifications and how many adults must be in the room. EEC states the three tiers on its public Learn about Family Child Care page: up to 6 children; "Up to 8 children: A licensed Family Child Care provider may enroll up to 8 children in their program without an assistant if at least 2 of the children are school age"; and "Up to 10 children: A licensed Family Child Care provider may enroll up to 10 children in their program if there is an approved assistant working with them." The regulation behind that is the multi-age grouping table at 606 CMR 7.10(4)(d) through (h), the only ratio table a family child care home ever uses. At 7.10(4)(d): six or fewer children, one educator, "No more than three children younger than two years old, including at least one toddler who is walking independently. Additional children must be older than 24 months." At 7.10(4)(e): seven or eight children, one educator, same infant limit, and the decisive sentence, "All children over capacity of six must be school age." At 7.10(4)(f): six or fewer children, two educators, "No more than six children younger than two years old." At 7.10(4)(g): seven to ten children, two educators, "No more than six children younger than two years old, including no more than three infants." At 7.10(4)(h): seven to ten children, three educators, "No more than six infants. Additional children must be 15 months of age or older." Read those five lines as one sentence: you can serve seven or eight alone only if the extra children are school age, and you cannot see ten children without a second adult on the floor. The age definitions inside that table are not intuitive, and they are where enrolment plans die. 606 CMR 7.02 defines "Infant - A child who is younger than 15 months old"; "Toddler - A child who is at least 15 months of age, but younger than 33 months old"; "Preschooler/Preschool Child - Any child at least two years and nine months old but not yet attending first grade"; "Kindergarten Child - A child who is five years old or who will attend first grade the following year"; and "School Age Child - A kindergarten child, or a child who is attending a public or approved private elementary school." So the "at least two of whom must be school age" condition for a licence of seven or eight is not satisfied by two four-year-olds, nor by a five-year-old who has not yet started kindergarten. In practice the seventh and eighth slots are before-and-after-school slots, not full-day slots. "Multi-age Grouping" is itself defined as "Ten or fewer children from birth through 13 years (or 16 years, if such children have special needs) assigned to a single group." Now the counting rule, the single most expensive misunderstanding in Massachusetts family child care: your own family counts against your licensed capacity. 606 CMR 7.03(5)(c), titled "Determining Capacity," reads: "The following children will be considered to be in the care of educators: 1. every child who lives in the family child care home who is younger than a school age child; 2. every child who lives in the family child care home who is home schooled, regardless of age; 3. every child younger than ten years old who lives in the residence and is present for more than three consecutive hours on each of five consecutive days, excluding weekends and holidays; 4. every person younger than 14 years old who does not live in the residence and is present during the time that child care is being provided; 5. during overnight care, every person younger than 18 years old who is present in the home." Take clause 2 seriously: a home-schooled thirteen-year-old of your own occupies a slot all day, with no age relief. Applicants routinely budget a ten-child business, then discover at the pre-licensing visit that their own two preschoolers and one home-schooled child have taken three of the ten. 606 CMR 7.03(2) states the consequence flatly: "At no time shall a program admit, supervise or provide care for more than the maximum number of children indicated on the license." Where you may operate is narrower than "my home." 606 CMR 7.03(5)(e) provides that "family child care may only be provided in a dwelling that provides complete independent living facilities for one or more persons including permanent provisions for living, sleeping, eating, cooking, and sanitation," and then permits exactly three arrangements: the dwelling must "be occupied for living purposes on a full time basis by either the licensee, or an individual personally known to the licensee, as the occupant's legal residence," or be unoccupied and either "located physically on the same property as the licensee's permanent residence and such residence is a single family home," or in a side-by-side duplex where the licensee lives in the other unit, or "located in a structure with a maximum of three stories, with no more than one dwelling unit located on each floor level," the licensee living in one of the others. A rented storefront or a vacant apartment across town both fail. And 606 CMR 7.03(5)(f) closes the obvious workaround in one line: "A family child care licensee may not hold more than one family child care license." You cannot scale by opening a second home under your own name. Space is measured, not estimated. 606 CMR 7.07(15)(c)1 requires the licensee to provide "a. a minimum of 150 square feet of approved activity space for one or two children; b. a minimum of 225 square feet of approved activity space for three to six children; c. 35 square feet of approved activity space for each child when serving seven to ten children," and 7.07(15)(c)2 adds that the space "can be located on no more than two adjacent floors." "Approved Activity Space" is defined at 606 CMR 7.02 as space that "shall include only usable floor space exclusive of hallways, bathrooms, and portions of rooms or areas that contain furniture or equipment suitable only for adult use." Outdoors, 606 CMR 7.07(7) requires "an outdoor play area of at least 75 square feet per child who is outside at any one time," providing "both direct sunlight and shade" and free of hazards "including but not limited to: a busy street, a parking lot, poisonous plants, water hazards, debris, broken glass, chipping, peeling or flaking paint, dangerous machinery or tools," any of which "must be removed or fenced by a sturdy, permanently installed barrier which is at least four feet high"; 7.07(8)(a) adds that porches and decks "must be inspected and approved by the Department before use by child care children." One inspection you do not need and one you do: 606 CMR 7.07(2) demands a building-code certificate only from programs "not located in a residence" or licensed "for more than ten children," so a family child care home never triggers it, but 7.07(3) still requires "evidence of compliance with applicable fire codes," and 7.07(4) requires well-water inspection within one year of licensure, updated at each renewal. Your licence runs three years, and that number is specific to family child care. 606 CMR 7.03(5)(b): "A regular license or approval is valid for three years from the date of issuance unless revoked, suspended, or made probationary." Compare 606 CMR 7.03(6)(b)2 for small group and large group programs: "A regular license or approval is valid for two years." Renewal under 7.03(3) requires that you "file a written application for renewal on forms provided by the Department and pay any required application fee not less than 30 days before the date of expiration," and the protective clause is worth memorising: "Provided that the application for renewal is filed timely, the license, certificate or letter of approval will remain in effect until the Department makes a final determination on the application." Miss the thirty days and that protection disappears. Renewal also requires that you "participate in a license renewal meeting approved by the Department." There is a live conflict between the statute and the regulation on provisional licences. M.G.L. c. 15D, Section 7(d) authorises EEC to issue a provisional licence to a "family child care home or large family child care home ... which has not previously operated," for not more than six months, with a hard outer limit of twelve consecutive months. But the provisional-licence text in the regulation appears only at 606 CMR 7.03(6)(b)1, inside "Additional Requirements for Small Group and School Age and Large Group and School Age Child Care Programs." The family child care subsection, 7.03(5), contains no provisional-licence provision at all. Do not plan on opening under a provisional family child care licence while you finish your paperwork. If you need to stop for a while, the mechanism is inactive status, and it is family-child-care-specific. 606 CMR 7.03(5)(d): "A Licensee who voluntarily ceases or suspends providing care while remaining licensed may elect inactive status. To become inactive, a licensee must notify the Department that care has ceased, and must return to the Department the license. Child care may resume after the licensee has requested that the Department return the license and has indicated to the satisfaction of the Department that the child care home is in compliance with all relevant EEC licensing regulations. While the license is inactive, the Department will not include the licensee on its roster of active educators." EEC's 2026 temporary-closure policy, FO-26-03, confirms the split in a footnote: the LEAD Temporary Closure transaction is for group and funded programs, while "FCC programs needing to close temporarily may enter Inactive Status, as allowed for by 606 CMR 7.03(5)(d)." Going inactive removes you from the public directory, so families searching for care will not find you. The assistant regime is the historic Massachusetts trap, and it is a trap of hours, not of headcount. 606 CMR 7.02 defines two grades: "Certified Assistant - A person who holds a certified assistant certificate issued by the Department; who, at minimum, meets the qualifications of a provider licensed to care for six children; and who works with or substitutes for the licensee in a family child care home," and "Regular Assistant - A person who holds a regular assistant certificate issued by the Department; does not meet the qualifications of the licensee for whom they are working; and who may replace a licensee or certified assistant on a limited basis." The operative rules are at 606 CMR 7.09(15)(c). A certified assistant "who meets the qualifications of the licensee may replace the licensee at any time, provided notice is given to parents in advance," while one qualified only for six children "may substitute for a provider licensed to care for up to ten children for up to 25 hours in a 12 month period." A regular assistant "may be alone on the premises with up to six children for up to 25 hours in a 12 month period, or up to eight hours in a seven day period, provided s/he is currently certified in first aid and CPR," and "In programs licensed to care for seven or more children, a regular assistant may provide care only under the supervision of a licensee or certified assistant." EEC's own policy statement on regular assistants, still published on the family child care policies list, closes the loophole every applicant tries: "no provider may leave their child care children with an uncertified assistant for more than a total of 8 hours per week or a total of 25 hours per year, no matter how many assistants he/she uses." The limit attaches to your home, not to the individual, so hiring three regular assistants does not buy you seventy-five hours. The same policy grants the reciprocal point people miss in their favour: "a regular assistant may substitute for and be left alone with the children in any number of different family child care homes for up to 8 hours per week or 25 hours per year per family child care home." And the sentence that makes a ten-child business possible at all: "Regular assistants may work with a provider or Certified Assistant for any length of time when the provider or Certified Assistant is on the child care premises." Twenty-five hours a year of solo coverage is not a vacation plan. If you intend to take time off you need a certified assistant at your own qualification level, and under 606 CMR 7.08(8)(c) parents must be told in advance. Your qualifications are tiered to the capacity you are asking for, and this is where brief-level summaries go wrong. 606 CMR 7.09(15)(a) sets the floor: "All educators must be at least 18 years of age." 7.09(15)(b) requires that before a first family child care licence you submit "evidence of current certification in basic first aid and CPR that is age appropriate for all of the children in care," and then, for six or fewer children, one of: "one year of experience as a parent"; "one year of full-time experience, or the equivalent, in caring for children younger than 12 years of age"; "nine months of full-time experience in caring for children younger than 14 years of age and completion of 15 hours of training, approved by the Department, not including the EEC educator orientation"; "six months of full-time experience in caring for children younger than 12 years of age and completion of 30 hours of training"; or "qualification as a teacher or site coordinator by EEC." For seven or eight children the applicant must have completed "within one year prior to application a pre-service training approved by the Department" plus either two years as a family child care licensee or certified assistant, or one year of that plus one additional year with unrelated children in a group setting or EEC teacher or site coordinator certification. For nine or ten children the applicant must have "completed within one year prior to application a five hour pre-service training approved by the Department" and either "three years of experience as a family child care licensee or certified assistant" or one year of that plus two additional years with unrelated children in a group setting, with three college credits in education substituting for six months of the additional experience and six credits for nine months. Note what that means: the top tier is not open to a first-time applicant. You license at six, build the years, then apply up. Set that against M.G.L. c. 15D, Section 8(c), which directs the Board to write standards for large family child care homes including "a prerequisite that a provider have at least 3 years of experience in licensed family child care and have completed at least 5 hours of specialized training before licensure as a large family child care provider and at least 10 hours of training each subsequent year." The regulation's nine-to-ten-child tier does carry the five-hour pre-service training, but it offers routes to the top tier on one year of licensed experience plus substitutes, where the statute on its face says three years in licensed family child care. If your regional office insists on three years, they are reading the statute; if they accept the one-year route, they are reading 606 CMR 7.09(15)(b)3. Get the answer in writing before you count on it. EEC's public requirements page, read on 26 August 2026, adds its own drift: it lists "EEC teacher, lead teacher, or director certification" where 7.09(15)(b)1.e says "qualification as a teacher or site coordinator by EEC," and appends the warning "Babysitting does not count as child care experience," which appears nowhere in the regulation but is how licensors apply it. Training you must do before you ever open, in order: register with EEC to obtain a Professional Qualifications (PQ) number; create a StrongStart account, StrongStart being EEC's learning management system at strongstart.eoe.mass.gov; complete the online "Potential Provider Training," 1.5 hours in two parts, known in the field as PPT 1 and PPT 2 and available in English, Spanish, Portuguese and Mandarin; and attend the in-person three-hour "Family Child Care Potential Educator Meeting," the PEM, held at one of EEC's regional offices. The regulation's hook is 606 CMR 7.03(1)(b), which conditions a licence on the fact that "within one year prior to licensure the licensee (or his or her designee) has attended an orientation to early education and care approved by the Department." The one-year window is real: an orientation completed two years before you file does not count. Since 1 July 2026 there is an additional training layer that is not in the regulation and that you will be cited for missing. EEC policy FO-26-04, "EEC Essentials 2.0 Training Requirements," released 6 May 2026 with an effective date of 1 July 2026 and applicable to "All EEC-licensed Child Care and Funded Programs," provides that "All educators and administrators working directly with children and counting in staff-to-child ratios in EEC-licensed or funded programs must complete the EEC Essentials 2.0 training package, regardless of the frequency that they work. This includes volunteers, interns, and substitutes who are counted in ratio. In family child care (FCC) programs, the FCC licensee, certified assistants, and regular assistants must complete the training package." The early-childhood package is thirteen courses, takes about twelve hours, and must be completed "prior to working in EEC-licensed or funded programs"; thereafter every applicable person must complete the two-part "EEC Essentials Refresher for Early Childhood," about three hours, "on or before June 30th each year." Completion counts toward required professional development hours only "the first time it is taken," and "the First Aid and CPR overview training is not an approved First Aid or CPR Training Course and will not result in First Aid or CPR certification." Compliance monitoring began on 1 July 2026, and the licensee must keep proof of completion in a personnel record for every person, available to licensors on request. Any Massachusetts guide written before May 2026 is missing twelve hours of mandatory training and an annual June 30 deadline. Ordinary professional development remains light by comparison: 606 CMR 7.09(15)(f) requires five hours a year for educators working more than 25 hours a year but less than ten hours a week, ten hours a year for those working more than ten hours a week, and "At least one third of the required professional development must address diverse learners"; 7.09(15)(e) adds that "Training in first aid and CPR may not be counted toward Professional Development hours." Health clearance recurs: 7.09(11) requires a physical examination within one year before licensure plus immunisation evidence, 7.09(13) requires "documentation of a current physical examination at the time of each license renewal," and 7.09(7) caps your day at twelve hours of care in any twenty-four. The line between needing a licence and not needing one is drawn by policy, not by instinct. EEC's policy statement "Informal Cooperative Arrangement and Occasional Care" states the frame first: "Child care must be either licensed/licensable (license required) or exempt (no license required). Exempt care cannot be combined with licensed care." Then the trigger: "A family child care home is operating on a 'regular basis' if the care is available for more than one day per week and for more than eight weeks in a twelve-month period. If the care being provided does not meet both of these criteria, it is not subject to licensure." Occasional care "occurs when no child is present more than one day per week or more than a total of 8 hours in a week, or when no child is in care for more than 30 days from the initial date of placement." An informal cooperative arrangement exists where all children are related to the caretaker by blood, marriage or adoption; where parents care for each other's children on an equal informal basis with "no hired personnel and no-one receives monetary or non-monetary compensation"; or where "care is provided to only one child unrelated to the caretaker" in a friendship that "pre-dates the care taking situation." Taking money for a second unrelated child destroys the exemption immediately, and you cannot run an exempt side arrangement alongside a licensed programme in the same home. Do not confuse family child care with the small-programme licence that sounds similar. 606 CMR 7.02 defines "Small Group and School Age Child Care" as "Any program that receives on a regular basis ten or fewer children ... when such services are not provided in a private residence." Same ceiling of ten, opposite setting. If you are in your home you are family child care; if you rent space you are small group and school age, your licence runs two years instead of three, you need a state building-code certificate under 7.07(2), and under 7.10(8)(c) "there must always be a second adult trained in the program's health care and emergency procedures immediately available in case of an emergency." EEC publishes a separate "Dual Licensure: Group Child Care and Family Child Care" policy for people who want both, which is the only route to operating in two settings given the one-licence-per-licensee rule at 7.03(5)(f). Two home-only supervision rules catch people either way: 606 CMR 7.10(7)(a) says "children must always be on the same floor level as the educator," 7.10(7)(d) requires that "The educator must visually observe napping children at least every 15 minutes" with the door left ajar when they nap in a separate room, and 7.10(3)(b) counts volunteers and student interns in your ratio only if they are "at least 18 years of age (in Family Child Care)" and assigned for at least three months - eight years older than the centre threshold. Two home-specific rules with real consequences. Firearms: 606 CMR 7.11(17)(a) requires that "The licensee must keep firearms unloaded and either stored in a locked cabinet or equipped with a trigger lock and stored in a safe, secured place out of the reach of children," with ammunition stored separately, and 7.04(16)(c) requires that "The licensee must notify the Department whenever a firearm is brought into the family child care home." Emergency backup: 7.11(17)(b) requires your plan for potential emergencies to include "the name and telephone number of a potential emergency caregiver who will be available to arrive at the child care home within ten minutes of being summoned to provide temporary child care in case of a medical emergency," and 7.02 defines "Medical Emergency" broadly enough to include one affecting your spouse, parent or household member. A named ten-minute backup person is a licensing document, not a nice idea. If you offer regular overnight care, 7.11(17)(d)3 is unforgiving: "Whenever regular overnight care is provided for seven to ten child care children two educators must remain on the premises, one of whom must remain awake during the entire overnight shift." The notification list is where quiet violations accumulate. Under 606 CMR 7.04(15), family child care programs "must notify the Department at least ten days prior to any change in location" - ten days for a home, against thirty for a centre - and must notify EEC at least thirty days before any change in the space used by the program, whenever code non-compliance prevents renewal of a required inspection certificate, immediately by telephone where fire or another emergency forces evacuation, "within 24 hours" of any incident on the premises resulting in a report to law enforcement that could affect children's health, safety or wellbeing "or in the event of the arrest of an educator or person regularly on the child care premises," "within 24 hours" of any fire department response other than a false alarm, in writing of any action brought by the Internal Revenue Service, immediately of any transportation accident, and in writing to EEC and every parent "no less than 30 days prior to the anticipated closing." 7.04(16) adds the family-child-care-only items: notify EEC if you join or leave a family child care system, and notify EEC "within seven days of approval as a foster or adoptive placement resource, or of any change in the household composition." A new adult moving into your house is a seven-day licensing event that also starts a background record check. What the application transaction actually consists of. 606 CMR 7.03(1)(c) requires "a completed application on a form provided by the Department, the required license application fee" plus evidence of compliance with 102 CMR 1.05(1), documentation of all inspections required by 7.07(2) through (5), a copy of the written information for parents required by 7.08(6), the forms used to record children's records under 7.04(7), "evidence of compliance with St. 1983, c. 233, Revenue Enforcement and Protection Program (REAP) on a tax certification form provided by the Department," and, if you use volunteers, a plan covering their orientation, supervision, hours and background checks including "a provision that volunteers must be under the direct visual supervision of an EEC qualified educator at all times." 606 CMR 7.03(5)(a) adds three family-child-care-only documents: "copies of the lead paint disclosure statement required by 606 CMR 7.07(15)(a)2; certification of current training in CPR and first aid, per 606 CMR 7.09(15)(e); health records, as evidence of compliance with 606 CMR 7.09(11)." All of it goes into LEAD, EEC's Licensing Education Analytic Database, and EEC's instruction is that "You have 90 days to complete the process" once the transaction opens. After you submit, EEC emails a tax certification statement and, separately, a background record check consent form, with a separate consent form issued to every household member and frequent visitor aged fifteen or older. The last gate is the pre-licensing visit. EEC's guidance is that "Before your pre-licensing visit, your home should look exactly as it will on your first day of operation," that the visit "usually takes 1-2 hours," and that the licensor will confirm you have "printed, reviewed, and understand" the EEC Family Child Care Enrollment Packet, the EEC Family Child Care Parent Handbook, the EEC Family Child Care Sample Forms, the Safe Sleep Pledge Form and your progress report format. Then: "Check your LEAD account 1-2 days after your visit for your licensor's notes. You must complete any follow-up items within 2 weeks of your visit. Corrective action plans must include notes and images of corrections. Some follow-up items may require a second licensor visit." Two weeks, with photographs. Budget for a second visit rather than being surprised by one. Finally, the obligation that is newest and that no pre-2026 guide contains. Chapter 163 of the Acts of 2026, approved 5 August 2026, added M.G.L. c. 15D, Section 23, which requires that "Each licensed or department-funded child care center, family child care home, school aged child care program and group care facility shall adopt and implement a policy regarding interactions with law enforcement agents engaged in civil law enforcement," naming a contact person, procedures for documenting every such interaction, and procedures for informing "the provider and staff of a family child care home" how to respond. Section 19 of the act requires that policy "to be in effect not later than September 1, 2026 or the first day of the 2026-2027 school year, whichever is earlier," and subsection (e) of the new statute applies the substantive protections "regardless of whether" you have adopted the policy. EEC implemented it through policy FO-26-01, "Emergency Preparedness in Child Care Programs," released 21 August 2026 and effective 1 September 2026, which supplies a model policy and an attestation route, opens LEAD Document Library uploads under a "Protect Act" category on 4 September 2026, and folds the requirement into Section 11 of the LEAD emergency-preparedness submission by 1 November 2026. Every family child care applicant licensed on or after that date walks into a first monitoring visit where a licensor may ask to see this document. It is not in 606 CMR 7.00, it is not in the codified chapter 15D that the Legislature's own website served on 26 August 2026, and it is due now.
Maximum group size
Massachusetts does not put a group-size number in a single sentence you can quote, and that is the first thing to understand before you plan a room, hire an assistant or sign a family. The cap that binds you is built from four instruments that have to be read together: the licensed capacity EEC prints on your license under 606 CMR 7.03(2), the multi-age grouping table at 606 CMR 7.10(4), the assistant regime at 606 CMR 7.09(15)(c), and the capacity-counting rule at 606 CMR 7.03(5)(c) that pulls your own children into the count. Miss any one of the four and your arithmetic will be wrong in the direction that costs you money. Start with the instrument that overrides all the others. 606 CMR 7.03(2), "Licensed Capacity," provides: "Programs will be licensed for the maximum number of children who may be in the care of educators at any one time, taking into consideration the size and layout of the physical facility, the number and qualifications of educators, the equipment and resources available to the children, the individual needs and characteristics of the children served, and the building certificate capacity, if applicable. At no time shall a program admit, supervise or provide care for more than the maximum number of children indicated on the license." Two words in that rule do most of the work. "At any one time" means the cap is instantaneous, not daily: if you run a morning cohort and an afternoon cohort, the overlap at handoff is the moment you are measured, and two half-day families whose pickup and drop-off touch will put you over. "At no time shall a program admit, supervise or provide care for more than the maximum number of children indicated on the license" means the licensed number is a hard ceiling that no ratio calculation can lift. Even where the group-size table would permit a larger group, you may not exceed the number on your license without EEC first amending it. The definition at 606 CMR 7.02 says the same thing from the other side: "Licensed Capacity - Determination by the Department of the number of children that a program can care for at any one time under 606 CMR 7.00." For family child care that number is 6, 8 or 10, and nothing else. EEC's Family Child Care Licensing technical assistance sheet on determining capacity states it flatly: "There are no longer separate categories of Family Child Care, i.e. FCCP and LFCC. However, the requirements of experience and additional pre-service training for increased capacity still exist. Family Child Care Educators now will have a license capacity of 6 or 8 or 10. (This is the maximum number of children allowed for that type of care.)" The ceiling of ten also appears in the regulation's own definition at 606 CMR 7.02: "Family Child Care - Temporary custody and care provided in a private residence during part or all of the day for no more than ten children younger than 14 years old or children younger than 16 years old if such children have special needs." Understand that the ten is now purely regulatory. The statutory cap that used to sit in M.G.L. c. 15D, s. 1A, the words ", but the number of children under the age of 16 in a large family child care home shall not exceed 10, including participating children living in the residence," was struck out by SECTION 25 of the fiscal year 2025 General Appropriations Act, St. 2024, c. 140, an outside section captioned "Large Family Child Care Cap." Since then the Legislature imposes no numeric ceiling on a home program at all; EEC does. That is exactly why EEC was able to announce, on June 22, 2026, a Family Child Care Capacity Expansion Pilot to test raising licensed home enrollment from ten to twelve, seating roughly 25 to 30 programs out of about 1,379 identified eligible providers, limited to licensees in good standing already enrolled at ten and licensed at a capacity of ten continuously for at least three years, applications closing June 30, 2026. Unless you were invited and selected into that pilot, your ceiling is ten. And if a commercial licensing directory tells you Massachusetts large family child care homes may serve "up to 12 to 14 children," it is inventing a number that has never existed in Massachusetts law. Now the group-size table itself, which is where the real limits live. 606 CMR 7.10 opens: "The following requirements apply to all programs, including family child care, small group and school age and large group and school age child care. Additional requirements for family child care are found at 606 CMR 7.10(6) and (7). Additional requirements for small group and school age child care are found at 606 CMR 7.10(7) and (8). Additional requirements for large group and school age child care are found at 606 CMR 7.10(8) and (9)." There is no separate family child care ratio table. A family child care home is governed by the Multi-age Grouping provisions at 606 CMR 7.10(4), which begin: "A group of children ranging in age from birth through 13 years (or 16 years, if such children have special needs), may be assigned on an ongoing basis to a single group, provided all provisions of 606 CMR 7.10(4) are met. The Multi-age Grouping ratios and group sizes specified at 606 CMR 7.10(4)(d) through (h) may be used by: (a) family child care and small group and school age child care programs; (b) large group and school age child care programs during the initial two hours and final two hours of the program day, if: 1. the program operates more than seven hours per day, and 2. educators meet the qualifications required of educators in large group and school age child care programs; (c) large group and school age child care programs during the entire program day when approved by the Department." The supporting definition at 606 CMR 7.02 fixes the absolute ceiling of any such group: "Multi-age Grouping - Ten or fewer children from birth through 13 years (or 16 years, if such children have special needs) assigned to a single group." Ten is the maximum size of a multi-age group, and in a family child care home the whole program is one multi-age group, because 606 CMR 7.02 defines "Group - Two or more children who participate in the same activities at the same time and are assigned to the same educator for supervision, at the same time." The five rows of the table at 606 CMR 7.10(4)(d) through (h) are the operative caps and are worth memorising exactly. 606 CMR 7.10(4)(d): group size "six or fewer children," minimum number of educators present "one educator," limits on ages of children "No more than three children younger than two years old, including at least one toddler who is walking independently. Additional children must be older than 24 months." 606 CMR 7.10(4)(e): group size "seven or eight children," "one educator," "No more than three children younger than two years old, including at least one toddler who is walking independently. Additional children must be older than 24 months. All children over capacity of six must be school age." 606 CMR 7.10(4)(f): group size "six or fewer children," "two educators," "No more than six children younger than two years old." 606 CMR 7.10(4)(g): group size "seven - ten children," "two educators," "No more than six children younger than two years old, including no more than three infants." 606 CMR 7.10(4)(h): group size "seven-ten children," "three educators," "No more than six infants. Additional children must be 15 months of age or older." Read those five rows as a decision tree rather than as a list, because that is how a licensor reads them. If you have one educator on the floor, your group may be six, or it may be seven or eight, and the difference is entirely made of school-age children: at seven or eight, "All children over capacity of six must be school age." Massachusetts defines that term narrowly at 606 CMR 7.02: "School Age Child - A kindergarten child, or a child who is attending a public or approved private elementary school," where "Approved Private Elementary School - A program that has documentation of approval by the local education authority pursuant to M.G.L. c. 76, s. 1." A four-year-old is not a school-age child no matter how mature. A five-year-old in half-day kindergarten is, and EEC's technical assistance sheet confirms the useful corollary that "The 5 year old child who may be attending 1/2 day kindergarten can be counted as a school aged child for a FCC provider with a capacity of '8', but is still a participating child." A six-year-old attending a private school that has no local approval under M.G.L. c. 76, s. 1 is not, and that is a genuine and expensive edge case in communities with unaccredited religious schools. The infant and toddler limits inside those rows are stricter than most applicants expect, and the wording is precise enough that it traps people twice. First, "No more than three children younger than two years old" is a headcount of children under 24 months, not of infants; 606 CMR 7.02 defines "Infant - A child who is younger than 15 months old" and "Toddler - A child who is at least 15 months of age, but younger than 33 months old," so a nineteen-month-old is not an infant but is certainly "younger than two years old" and consumes one of your three slots. Second, the qualifying clause "including at least one toddler who is walking independently" means the three cannot all be non-ambulatory. EEC's determining-capacity sheet explains what the words mean operationally: "A FCC Educator with a capacity of '6' can care alone for 3 children under the age of 2 years so long as at least one of the three is 15 months and walking unassisted. (If there are more infants, or more than 3 under 2 years, a second Educator must be present.) 'Walking unassisted' means that the child is capable of walking without holding hands or needing assistance in exiting the home." The reason for the rule is evacuation, which is also why 606 CMR 7.07(15)(b) requires that "Family child care homes must have at least two separate exits to the outside, approved by the Department." Third, and this is the row that quietly costs an enrollment, 606 CMR 7.10(4)(d) and (e) both end with "Additional children must be older than 24 months." Older than 24 months, not "at least" 24 months. A child on their second birthday is 24 months, not older than 24 months, and if you already have three under two you cannot lawfully seat that child in a solo group until the following day. Fourth, at 606 CMR 7.10(4)(h) the phrase is different again: with three educators, "Additional children must be 15 months of age or older," which is an at-least formulation. Do not carry one row's wording into another. Now the assistant regime, which is what actually converts a capacity of ten into ten children on the floor, and where the Massachusetts trap lives. EEC's determining-capacity sheet states the operating rule: "FCC Providers with a capacity of '10' children must work with a second Educator at any time there are more than 6 pre-school aged children. A FCC Educator with a capacity of 10 can care for up to 8 children by her/himself if two of the children are school-aged. The second Educator can be another Provider, a Certified Assistant, or a Regular Assistant." Mass.gov's applicant-facing "Learn about Family Child Care" page says the same: "Up to 8 children: A licensed Family Child Care provider may enroll up to 8 children in their program without an assistant if at least 2 of the children are school age ... Up to 10 children: A licensed Family Child Care provider may enroll up to 10 children in their program if there is an approved assistant working with them." Set that against the statute. M.G.L. c. 15D, s. 1A defines "Large family child care home" and provides, in a sentence the 2024 budget did not touch, that "A large family child care home shall have at least 1 approved assistant when the total number of children participating in child care exceeds 6." The statute says an approved assistant is required above six. The regulation and EEC's own guidance say you may run seven or eight alone if the children above six are school age. Both instruments are in force. EEC licenses and inspects to 606 CMR 7.10(4)(e), and solo capacity-of-eight licenses are ordinary, but the statutory sentence has never been repealed. If your business plan depends on running eight children without paying an assistant, get your licensor's position in writing before you hire, lease or enroll, because the difference between eight solo and eight with an assistant is the whole margin of a home program. The two assistant types are defined at 606 CMR 7.02 and governed at 606 CMR 7.09(15)(c), and they are not interchangeable. "Certified Assistant - A person who holds a certified assistant certificate issued by the Department; who, at minimum, meets the qualifications of a provider licensed to care for six children; and who works with or substitutes for the licensee in a family child care home, depending on his/her level of qualification." "Regular Assistant - A person who holds a regular assistant certificate issued by the Department; does not meet the qualifications of the licensee for whom they are working; and who may replace a licensee or certified assistant on a limited basis in a family child care home as allowed under 606 CMR 7.09(15)(c)2.a." The operative text is 606 CMR 7.09(15)(c): "Assistants. All assistants must demonstrate the ability to implement the provider's curriculum, activities and routines. 1. Certified Assistant. a. An educator who meets the qualifications of the licensee may replace the licensee at any time, provided notice is given to parents in advance, in accordance with 606 CMR 7.08(8)(c). b. An educator who meets the qualifications of a family child care educator licensed to serve six or fewer children may substitute for a provider licensed to care for up to ten children for up to 25 hours in a 12 month period. 2. Regular Assistant. An educator whose qualifications are neither equal to nor greater than the licensee's qualifications may provide care under the general supervision of the licensee. a. A regular assistant may be alone on the premises with up to six children for up to 25 hours in a 12 month period, or up to eight hours in a seven day period, provided s/he is currently certified in first aid and CPR. b. In programs licensed to care for seven or more children, a regular assistant may provide care only under the supervision of a licensee or certified assistant." That block contains three separate ceilings that people routinely conflate. A certified assistant who matches your qualification level may replace you for any length of time, with advance parent notice. A certified assistant qualified only at the six-child level may substitute for a ten-capacity licensee, but only "for up to 25 hours in a 12 month period," which is roughly three working days a year, not a staffing plan. A regular assistant may be alone with up to six children, capped simultaneously at "25 hours in a 12 month period" and "eight hours in a seven day period," and only if currently first aid and CPR certified. Mass.gov restates the same limits on its "Learn about Family Child Care Assistant requirements" page: a regular assistant may "Care for up to 6 children alone in a licensed Family Child Care provider's home for a limited time period (25 hours in 12 months, or 8 hours in 7 days)," while a certified assistant "may provide substitute care for up to 25 hours in a twelve month period" unless certified at the same level as the provider, in which case they "may care for children in that provider's absence for any length of time." The trap that costs money is the annual number. Twenty-five hours in twelve months is your entire budget of solo assistant coverage for the year. A provider who plans vacation, a medical procedure or jury duty around a regular assistant will exhaust that budget in one week and will be operating unlawfully for the rest. The only durable answer is a certified assistant qualified at your own capacity level, which means that person must climb the same 606 CMR 7.09(15)(b) experience ladder you did: for six or fewer children, one year of experience as a parent or the equivalent in child care experience and approved training; for seven or eight children, a Department-approved pre-service training completed within one year prior to application plus "two years of experience as a family child care licensee or certified assistant" or one year plus an additional year in a group setting; for nine or ten children, "a five hour pre-service training approved by the Department" plus "three years of experience as a family child care licensee or certified assistant" or one year plus two additional years in a group setting. M.G.L. c. 15D, s. 8(c) is the statutory source of that ladder, directing that regulations for large family child care homes include "a prerequisite that a provider have at least 3 years of experience in licensed family child care and have completed at least 5 hours of specialized training before licensure as a large family child care provider and at least 10 hours of training each subsequent year." Who may be counted as the second educator is itself restricted. 606 CMR 7.10(3) provides: "(a) For purposes of calculating staff: child ratios, staff shall include only those EEC-qualified persons who are assigned to care for children for specific hours of the day. (b) Volunteers and student interns shall not be included in staff: child ratios unless they are at least 16 years of age (in Small and Large Group and School Age Child Care) or at least 18 years of age (in Family Child Care) and are assigned to the program for at least three months." Your teenage son helping in the afternoon does not lift your group size. 606 CMR 7.09(15)(a) states the floor without exception: "All educators must be at least 18 years of age." And 606 CMR 7.09(15)(e) requires that "All licensees, certified assistants, and any educator who may be alone with children must maintain current certification of training in basic first aid and CPR, in accordance with EEC policy." The count that fills the group is not the count of your enrolled families. 606 CMR 7.03(5)(c) determines which children occupy a slot: "The following children will be considered to be in the care of educators: 1. every child who lives in the family child care home who is younger than a school age child; 2. every child who lives in the family child care home who is home schooled, regardless of age; 3. every child younger than ten years old who lives in the residence and is present for more than three consecutive hours on each of five consecutive days, excluding weekends and holidays; 4. every person younger than 14 years old who does not live in the residence and is present during the time that child care is being provided; 5. during overnight care, every person younger than 18 years old who is present in the home." Your own preschooler occupies a slot whenever they are in the house. Your home-schooled twelve-year-old occupies a slot regardless of age. Your school-age child under ten occupies a slot only when both halves of clause 3 are true, more than three consecutive hours and on each of five consecutive days, which is why EEC's guidance says "A provider's own school aged child/ren who are under the age of 10 years old and home during the summer months do count in a provider's capacity. Provider must adjust enrollment accordingly." Clause 4 is the one that catches people mid-inspection: a visiting thirteen-year-old who lives elsewhere counts for every minute they are present during care hours, even though nobody pays you for them. If you are licensed for eight and your niece drops in after school, you have seven paid slots that day, not eight. Overnight care changes the staffing answer entirely. 606 CMR 7.02 defines "Regular Overnight Care - Care provided to any child care child between the hours of 11:30 P.M. and 6:00 A.M. more than one day per week for more than eight weeks in a 12-month period," "Occasional Overnight Care - Child care provided between the hours of 11:30 P.M. and 6:00 A.M. that is not provided on a regular basis," and "Evening Care - Child care provided between the hours of 8:00 P.M. and 11:30 P.M." 606 CMR 7.11(17)(d)3 then requires that "Whenever regular overnight care is provided for seven to ten child care children two educators must remain on the premises, one of whom must remain awake during the entire overnight shift," and 7.11(17)(d)2 that "The educator must have adequate sleep to ensure alertness while caring for children. As provided at 606 CMR 7.09(7), no educator may regularly care for child care children more than 12 hours in any 24-hour period." Combine that with the counting rule that during overnight care every person under eighteen in the home counts, and a ten-capacity overnight program is a two-adult operation with a smaller usable group than the license number suggests. Supervision rules narrow effective group size further at both ends of the age range. 606 CMR 7.10(5)(a): "Children younger than six months of age at the time of enrollment must be under direct visual supervision at all times, including while napping, during the first six weeks they are in care." 606 CMR 7.10(7)(d), which applies to family child care and small group and school age: "The educator must visually observe napping children at least every 15 minutes. When children are placed in a separate room for naps, the door must remain ajar." 606 CMR 7.10(7)(a): "Except as provided at 606 CMR 7.10(5)(j), children must always be on the same floor level as the educator." That last rule is the quiet killer of two-floor home layouts: your approved activity space may sit on two adjacent floors under 606 CMR 7.07(15)(c)2, but the children may not be on a different floor from you, so a two-floor program with one educator is really a one-floor program at any given moment. The relief at 7.10(5)(j) is age-gated and paperwork-gated: "Children age seven or older may, with written parental consent, participate in activities within the approved indoor space without constant visual supervision by the educator," subject to the educator being aware of location, monitoring at regular intervals, being readily available and being "able to respond immediately to an emergency situation." Outdoors, 606 CMR 7.10(6)(a) permits children five or older to play unaccompanied only if "the outdoor play space is located on the family child care premises of a single family or first floor residence, and is enclosed by a fence at least four feet high," the children "are observed by the caregiver every 15 minutes," "the time unaccompanied by the provider does not exceed one hour," and "the parents have given written permission." Square footage is a group-size constraint applicants discover too late. 606 CMR 7.07(15)(c) requires "a minimum of 150 square feet of approved activity space for one or two children; a minimum of 225 square feet of approved activity space for three to six children; 35 square feet of approved activity space for each child when serving seven to ten children." At ten children that is 350 square feet, and 606 CMR 7.02 defines "Approved Activity Space" as space that "shall include only usable floor space exclusive of hallways, bathrooms, and portions of rooms or areas that contain furniture or equipment suitable only for adult use." Measure before you apply for a capacity increase; the licensor will. If your program is not in a private residence the group-size rules change shape. 606 CMR 7.02 defines "Small Group and School Age Child Care" as "Any program that receives on a regular basis ten or fewer children who are unrelated to their caregivers and are younger than 14 years old, or 16 years, if such children have special needs, during all or part of the day for non-residential care and education outside their own homes, when such services are not provided in a private residence." A small group program uses the same 606 CMR 7.10(4) multi-age table as a home, so its group ceiling is likewise ten, but it carries two additional obligations a home does not. 606 CMR 7.10(8)(c) provides that "Notwithstanding the staff: child ratios provided at 606 CMR 7.10(4), there must always be a second adult trained in the program's health care and emergency procedures immediately available in case of an emergency," and 7.10(8)(b) requires a written, posted staff schedule showing "compliance with at least the minimum educator ratios at all times, including during breaks and planning time." The qualification ladder mirrors family child care at 606 CMR 7.09(16)(a): "At least one educator in each small group and school age child care program must meet the qualifications for a family child care provider for the number of children in care; or 1. be teacher or site coordinator qualified by EEC, if caring for six or fewer children; 2. be lead teacher qualified, or have two years of experience as a teacher or site coordinator if caring of seven or eight children; or 3. have three years of experience as a teacher or site coordinator, or be lead teacher or program administrator qualified, if caring for nine or ten children." Note that 606 CMR 7.09(16)(b) drops the age floor for additional staff to "at least 16 years of age and in high school, or at least 18 years of age," which is lower than the eighteen required in a home. Above ten children outside a residence you are a large group and school age child care program, and the multi-age table stops being your default. 606 CMR 7.10(9)(b) sets the fixed age group maxima: infants up to 15 months old, full or half day, maximum group size 7, ratio "1: 3, one additional educator for four - seven infants," with "At least one Infant/Toddler Teacher, per 606 CMR 7.09(18)(c)2."; toddlers 15 to 33 months, group size 9, ratio "1:4, one additional educator for five - nine toddlers"; preschoolers 33 months to school age, full day, group size 20, ratio 1:10; preschoolers 33 months to school age, half day, group size 24, ratio 1:12; kindergarten, meaning children "attending first grade the following year," group size 30, ratio 1:15; school age, group size 26, ratio 1:13, with "At least one Group Leader, per 606 CMR 7.09(19)(a)2." The mixed age group table at 606 CMR 7.10(9)(c) is the one that answers "how do mixed ages change it": infant/toddler group, maximum size "9; no more than three infants," ratio "1:3; one additional educator for four - nine children"; toddler/preschool group, maximum size 9, ratio "1:5; one additional educator for six - nine children"; preschool/school age group, maximum size "20; maximum age is eight," ratio 1:10; kindergarten/school age group, maximum size 26, ratio 1:13. Mixed is not a free-for-all: 606 CMR 7.02 defines "Mixed Age Group - A group of children within two consecutive age groups, such as Infant/ Toddler, Toddler/Preschool, Preschool/School Age or Kindergarten/School Age," so you may bridge two adjacent bands and no more, and the preschool/school age band is additionally capped at "maximum age is eight," which quietly forbids putting ten-year-olds with four-year-olds in a twenty-child group. A large group program may use the ten-child multi-age table only in the circumstances 606 CMR 7.10(4)(b) and (c) allow: "during the initial two hours and final two hours of the program day, if 1. the program operates more than seven hours per day, and 2. educators meet the qualifications required of educators in large group and school age child care programs," or "during the entire program day when approved by the Department," where the Department may approve "a single full day Multi-age Group when it can demonstrate that a. the developmental needs of every child in the Multi-age Group can be met in that setting; b. the program's physical environment is sufficiently self-contained to allow the benefits of a 'family setting' within a larger, center based program," and may approve additional such groups only after the first "has operated successfully for at least one year." Opening and closing multi-age grouping is what makes an early-morning and late-afternoon staffing plan affordable in a center, and it is limited to programs open more than seven hours. Two provisions bound how far you can bend an age group. 606 CMR 7.10(9)(a)4 permits assigning a child "to fixed age groups outside their chronologically defined age group," but only with parental approval, documented reasons, placement in "the next younger or next older chronologically defined age group," and documented monthly review. 606 CMR 7.10(9)(a)6 then caps it absolutely: "No more than two children outside the chronologically defined age range may be assigned to a fixed age group." That is the rule that stops a preschool room from becoming a de facto toddler room one child at a time. Finally, remember what does not change any of this. Ratios and group sizes are minimums layered under a general duty, stated at 606 CMR 7.10(1): "The licensee must maintain sufficient numbers of qualified staff to promote the health, safety, growth and development of each child. Assignment of staff must take into account the physical environment, requirements of the activities children are engaged in, and the developmental levels and behavioral traits of children in care," and under 7.10(2) the program "must have the number of educators necessary to (a) ensure adequate supervision of the group at all times." A licensor who finds a group at the table maximum but visibly unsupervised will cite 7.10(1), not the table. Variances exist under 606 CMR 7.03(4)(b), but only "upon written request," on "clear and convincing evidence," and "for a specified period of time not to exceed the term of the license." Plan to the table, staff above it, and never let the number of bodies in the house exceed the number printed on your license.
CPR & first aid
Yes — required before licensure
Last verified
2026-08-26

Who needs a license — home types in Massachusetts

In Massachusetts you are applying to the Department of Early Education and Care (EEC), the agency created by St. 2004, c. 205 and operational since July 1, 2005, which sits inside the Executive Office of Education and issues every child care license in the Commonwealth under 606 CMR 7.00, "Standards for the Licensure or Approval of Family Child Care; Small Group and School Age and Large Group and School Age Child Care Programs," whose sole regulatory authority line reads "606 CMR 7.00: M.G.L. c. 15D." Mass.gov states the scope plainly on its Child Care Program Licensing page: "EEC licenses or approves group, school age, and family child care programs; family child care assistants; residential programs for children; and adoption/foster care placement agencies." The licensing requirement itself is statutory, not regulatory, and it is criminal: M.G.L. c. 15D, s. 6(a) provides that "No person shall operate a school-aged child care program, a child care center, family child care home, large family child care home, placement agency, group care facility, or temporary shelter facility unless that person is licensed by the department," and M.G.L. c. 15D, s. 15(a) provides that "Any person who violates section 6 shall be punished for each violation by a fine of up to $5,000 or by imprisonment in the house of correction for not more than 21/2 years, or by both." A department, agency or institution of the Commonwealth or a political subdivision "shall obtain an approval rather than a license," which is why you will see the phrase "licensure or approval" in the title of 606 CMR 7.00; if you are a private individual opening a home program, the word that applies to you is license, not approval.

The single most important structural fact about Massachusetts, and the one that most out-of-state guidance gets wrong, is that the statute and the regulation no longer describe the same landscape. M.G.L. c. 15D, s. 1A still carries two separate residential definitions. "Family child care home" is defined as "a private residence which, on a regular basis, receives for temporary custody and care during part or all of the day, children under 7 years of age, or children under 16 years of age if those children have special needs, and receives for temporary custody and care for a limited number of hours children of school age under regulations adopted by the board. The total number of children under 16 in a family child care home shall not exceed 6, including participating children living in the residence. Family child care home shall not mean a private residence used for an informal cooperative arrangement among neighbors or relatives, or the occasional care of children with or without compensation." "Large family child care home" is defined as "a private residence which, on a regular basis, receives for temporary custody and care during part, or all of the day, children under 7 years of age, or children under 16 years of age if such children have special needs, and receives for temporary custody and care for a limited number of hours children of school age under regulations promulgated by the board. A large family child care home shall have at least 1 approved assistant when the total number of children participating in child care exceeds 6. Large family child care home shall not mean a private residence used for an informal cooperative arrangement among neighbors or relatives, or the occasional care of children with or without compensation."

Read that second definition again and notice what is missing. Until 2024 it ended with the words ", but the number of children under the age of 16 in a large family child care home shall not exceed 10, including participating children living in the residence." Those words are gone. They were struck by SECTION 25 of the fiscal year 2025 General Appropriations Act, St. 2024, c. 140, an outside section captioned "Large Family Child Care Cap," which reads in full: "Section 1A of chapter 15D of the General Laws, as appearing in the 2022 Official Edition, is hereby amended by striking out, in lines 98 to 100, inclusive, the words ', but the number of children under the age of 16 in a large family child care home shall not exceed 10, including participating children living in the residence'." Since that budget took effect there has been no statutory ceiling at all on a large family child care home in Massachusetts. The ten-child number that every third-party guide, every AI summary and most agency handouts still recite is now a licensing and regulatory number, held in place by 606 CMR 7.00 and EEC practice, not a number the Legislature imposes.

If you read a page that tells you "Massachusetts law caps large family child care at 10," that page is quoting a repealed clause. It matters practically, because it is the legal hook EEC used on June 22, 2026 to open a Family Child Care Capacity Expansion Pilot that lets a selected set of providers enroll up to 12 children; EEC could not have done that while the statute said ten. The second structural fact is that EEC has collapsed the statute's two residential categories into one license type with three capacities. EEC's own Family Child Care Licensing technical assistance sheet on determining capacity states it in terms that leave no room: "There are no longer separate categories of Family Child Care, i.e. FCCP and LFCC. However, the requirements of experience and additional pre-service training for increased capacity still exist. Family Child Care Educators now will have a license capacity of 6 or 8 or 10. (This is the maximum number of children allowed for that type of care.)" The regulation matches. 606 CMR 7.02 does not define "family child care home" or "large family child care home" at all; it defines a single activity, "Family Child Care - Temporary custody and care provided in a private residence during part or all of the day for no more than ten children younger than 14 years old or children younger than 16 years old if such children have special needs.

Family child care shall not mean an informal cooperative arrangement among neighbors or relatives, or the occasional care of children with or without compensation." One definition, one license, ten children on its face, and a capacity number of 6, 8 or 10 written on the license EEC hands you. Mass.gov's applicant-facing page "Learn about Family Child Care" says the same thing in the language you will actually be spoken to in: "There are three types of licensed Family Child Care programs: Up to 6 children ... Up to 8 children: A licensed Family Child Care provider may enroll up to 8 children in their program without an assistant if at least 2 of the children are school age ... Up to 10 children: A licensed Family Child Care provider may enroll up to 10 children in their program if there is an approved assistant working with them." That sentence about eight children without an assistant is the trap that costs Massachusetts applicants money, and you should understand exactly where the conflict lies before you build a business plan on it. The statute says a large family child care home "shall have at least 1 approved assistant when the total number of children participating in child care exceeds 6." EEC's regulation and EEC's own guidance say you may run a capacity-of-eight program alone, provided at least two of the eight are school age. 606 CMR 7.10(4)(e) authorizes "seven or eight children" with "one educator," with the limit "All children over capacity of six must be school age."

EEC's determining-capacity sheet is blunter: "A FCC Educator with a capacity of 10 can care for up to 8 children by her/himself if two of the children are school-aged." You are being told two different things by two instruments that are both in force. In practice EEC licenses and inspects to the regulation, and a capacity-of-eight license issued to a solo educator is routine. But the statutory sentence was not repealed when the ten-child cap was, and if you plan to run eight alone you should get your licensor's position in writing before you sign a lease, hire, or turn away the school-age enrollments that make the eighth slot legal. Losing a school-age child in September and keeping eight bodies in the house puts you over capacity the same day, and over-capacity is the finding that produces a corrective action plan, a probationary license or a capacity reduction, all of which cost you revenue you have already promised to families. Now the definitional question that brings most people to this page: does the home have to be your own residence? The answer in Massachusetts is no, and the exception is far wider than applicants expect. 606 CMR 7.03(5)(e), "Location of Care," provides: "For the purposes of 606 CMR 7.00, family child care may only be provided in a dwelling that provides complete independent living facilities for one or more persons including permanent provisions for living, sleeping, eating, cooking, and sanitation.

In addition, the dwelling must: 1. be occupied for living purposes on a full time basis by either the licensee, or an individual personally known to the licensee, as the occupant's legal residence; or 2. be unoccupied and be: a. located physically on the same property as the licensee's permanent residence and such residence is a single family home; or b. located in a duplex structure containing two independent side-by-side dwelling units and the licensee permanently resides in the other dwelling unit located in the duplex; or c. located in a structure with a maximum of three stories, with no more than one dwelling unit located on each floor level, and the licensee permanently resides in one of the other dwelling units located in the three story structure." Read the first branch carefully: the dwelling may be the full-time legal residence of "an individual personally known to the licensee." You may, lawfully, run your program out of your mother's apartment or a friend's house if that person actually lives there full time as their legal residence. Read the second branch just as carefully: an unoccupied dwelling qualifies only in three shapes, and every one of them requires that you, the licensee, permanently reside on the same property, in the other half of the duplex, or on another floor of a three-story, one-unit-per-floor building. A vacant condominium across town does not qualify. A finished basement apartment in a six-unit building does not qualify. A commercial storefront never qualifies, because it is not a dwelling with "permanent provisions for living, sleeping, eating, cooking, and sanitation."

The supporting definition at 606 CMR 7.02 is "Private Residence - A dwelling that is occupied for living purposes so long as the dwelling is the occupant's full-time legal residence, and contains the facilities necessary for sleeping, eating, cooking, and family living." The corollary matters as much: 606 CMR 7.03(5)(f) provides that "A family child care licensee may not hold more than one family child care license." You cannot license two homes and run them as a two-site business under your own name. If your growth plan is more than one location, your second location is not family child care at all; it is a small group and school age child care program, licensed under the same 606 CMR 7.00 but under a different definition and a different qualification ladder. That brings you to the boundary that separates family child care from everything else, and the boundary is the private residence, not the number of children. 606 CMR 7.02 defines "Small Group and School Age Child Care" as "Any program that receives on a regular basis ten or fewer children who are unrelated to their caregivers and are younger than 14 years old, or 16 years, if such children have special needs, during all or part of the day for non-residential care and education outside their own homes, when such services are not provided in a private residence."

Ten or fewer children, but not in a private residence. And "Large Group and School Age Child Care" is "Any program that receives on a regular basis more than ten children who are unrelated to their caregivers and are younger than 14 years old, or 16 years, if such children have special needs, during all or part of the day for non-residential care and education outside their own homes." So the three-way test is mechanical: in a private residence with up to ten children you are family child care; outside a private residence with up to ten children you are small group and school age; more than ten children anywhere you are large group and school age. Applicants who plan a "home daycare" in a church basement, a converted garage that is not a dwelling, or a rented office suite are applying for the wrong license, and EEC will tell them so after the fee is paid. Note also the age reach: 606 CMR 7.02 defines "Child - Any person younger than 14 years old, or 16 years old with special needs," and EEC's technical assistance sheet spells out the consequence, "Family Child Care is now defined as the regular care of children younger than 14 years of age or 16 years old if they have special needs.

This means that all children up to the age of 14 years old (16 if they have special needs) count and are regulated in FCC homes." An eleven-year-old is not "too old to count" in Massachusetts. The exemptions are narrow, and the one applicants most want to exist does not. Massachusetts has no numeric floor. There is no "you may care for up to three unrelated children without a license" rule in c. 15D or in 606 CMR 7.00. The only carve-outs written into both the statutory and the regulatory definitions of family child care are two, and they are identical in each: a private residence used for "an informal cooperative arrangement among neighbors or relatives," and "the occasional care of children with or without compensation." Note that compensation is irrelevant to the second exemption and irrelevant to the licensing requirement generally, so the widespread belief that unpaid care is unregulated is backwards. What the exemptions turn on is regularity. Both definitions apply only to a residence that "on a regular basis" receives children; occasional care and informal reciprocal arrangements among neighbors are outside the definition.

Care for one unrelated child, five days a week, all year, for money, is regular care in a private residence and requires a license. EEC maintains an "Unlicensed Child Care Complaint Form" at childcare.mass.gov/reportunlicensedcare, and complaints from neighbors and from competitors are the ordinary way unlicensed programs come to EEC's attention. The relative exemption is real but the definition of relative is closed and short. 606 CMR 7.02: "Relative - A person who is a parent, grandparent, great grandparent, aunt, uncle, great aunt, great uncle or sibling by blood, marriage or adoption." Cousins are not on that list. Godparents are not on that list. Close family friends are not on that list. If the children you care for are your grandchildren, nieces and nephews, you are outside licensure; add one child of a family friend on a regular basis and you are inside it. The religious and school exemptions exist in Massachusetts but they exempt centers and school-age programs, not homes, and you should not plan a home program around them. The 606 CMR 7.02 definition of "Child Care Center" excludes "any part of a public school system; any part of a private organized educational system, unless the services of such a system are primarily limited to kindergarten, nursery or related pre-school services; a Sunday school conducted by a religious institution; a facility operated by a religious organization where children are cared for during short periods of time while persons responsible for such children are attending religious services; a family child care home; an informal cooperative arrangement among neighbors or relatives; or the occasional care of children with or without compensation."

The definitions of "Small Group and School Age Child Care" and "Large Group and School Age Child Care" carry the same list, the latter adding "any part of a program operated by an organized educational system for the children enrolled in that particular system, unless the services of such system are primarily limited to a school age child care program" and substituting "Sunday schools or classes for religious instruction conducted by a religious institution." The religious carve-out is deliberately narrow: it covers care "during short periods of time while persons responsible for such children are attending religious services," which is nursery-during-worship, not a parish preschool. A church that runs a five-day-a-week program is licensed like anyone else. And crucially, none of these religious or educational exclusions appear in the definition of family child care at all; a home program is not made exempt by the provider's faith, by affiliation with a congregation, or by calling itself a ministry.

The counting of your own children is the question this site is asked more than any other, and Massachusetts answers it in regulation, not in guidance. 606 CMR 7.03(5)(c), "Determining Capacity," provides that "The following children will be considered to be in the care of educators: 1. every child who lives in the family child care home who is younger than a school age child; 2. every child who lives in the family child care home who is home schooled, regardless of age; 3. every child younger than ten years old who lives in the residence and is present for more than three consecutive hours on each of five consecutive days, excluding weekends and holidays; 4. every person younger than 14 years old who does not live in the residence and is present during the time that child care is being provided; 5. during overnight care, every person younger than 18 years old who is present in the home." Take those five clauses one at a time, because each one has cost somebody a slot. Clause 1 uses "school age child," which 606 CMR 7.02 defines as "A kindergarten child, or a child who is attending a public or approved private elementary school," and "Kindergarten Child - A child who is five years old or who will attend first grade the following year in a public or private school."

So your own preschooler counts every hour they are in the house, full stop. Clause 2 means home schooling destroys the age break entirely: a home-schooled twelve-year-old of yours occupies a licensed slot. Clause 3 is the one people misread. It does not say a child of five to nine "counts if home during the day"; it says a child under ten who lives in the residence counts only if present "for more than three consecutive hours on each of five consecutive days, excluding weekends and holidays." Both halves are conjunctive. A seven-year-old who gets off the bus at 3:00 and whose program closes at 5:30 is present two and a half hours, not more than three, and does not count. A seven-year-old home sick Tuesday and Wednesday is not present on five consecutive days and does not count. The same seven-year-old across July and August, home all day every weekday, does count, and EEC's technical assistance sheet says so directly: "A provider's own school aged child/ren who are under the age of 10 years old and home during the summer months do count in a provider's capacity. Provider must adjust enrollment accordingly."

Plan your summer enrollment in March, not in June. Clause 4 is the sleeper: "every person younger than 14 years old who does not live in the residence and is present during the time that child care is being provided." That captures your visiting niece, your assistant's own child, and the neighbor's eleven-year-old doing homework at your kitchen table. They are not enrolled, they are not paid for, and they still occupy a licensed slot for as long as they are in the house during care hours. Clause 5 doubles the reach at night: during overnight care every person under eighteen present in the home counts, including your own teenagers. EEC's determining-capacity sheet restates the same rules in plainer words and adds the labels licensors use: "What is a 'Participating Child'? A provider's own child who is counted in FCC License capacity. A provider's own child who is 10 years old or older does not count unless they are homeschooled. A provider's own child who is under the age of 5 years old counts whenever they are on the premises. A provider's own child who is 5 years old, but younger than 10 years old and is enrolled in school full-time, and in the home less than 3 consecutive hours during the child care day does not count during the school year. (The 5 year old child who may be attending 1/2 day kindergarten can be counted as a school aged child for a FCC provider with a capacity of '8', but is still a participating child.) Provider's own children who are home schooled count in the capacity regardless of their age."

Two cautions about relying on that sheet. First, it is old; the file name printed on it is FCCDeterminingCapacityTA20110516, which dates it to 2011, and it still narrates a world in which the FCCP and LFCC categories have only just been merged. Second, its paraphrase of the three-hour rule drops the "on each of five consecutive days" element that the regulation actually requires. Where the sheet and 606 CMR 7.03(5)(c) diverge, the regulation is the law and the sheet is guidance. The parenthetical about the half-day kindergartener is genuinely useful, though, and worth internalising: your own five-year-old in half-day kindergarten is simultaneously a participating child who fills a slot and a school-age child who can satisfy the "at least 2 of the children are school age" condition that a capacity-of-eight license depends on. What a licensed capacity is, formally, is set by 606 CMR 7.03(2): "Programs will be licensed for the maximum number of children who may be in the care of educators at any one time, taking into consideration the size and layout of the physical facility, the number and qualifications of educators, the equipment and resources available to the children, the individual needs and characteristics of the children served, and the building certificate capacity, if applicable.

At no time shall a program admit, supervise or provide care for more than the maximum number of children indicated on the license." The number on the license is the operative cap and it is a moment-by-moment cap, not a daily headcount, so staggered part-time schedules do not let you exceed it at overlap. The physical constraints that shape that number for a home are at 606 CMR 7.07(15)(c): "a minimum of 150 square feet of approved activity space for one or two children; a minimum of 225 square feet of approved activity space for three to six children; 35 square feet of approved activity space for each child when serving seven to ten children," with the space "located on no more than two adjacent floors" and "No more than one area that is used exclusively for napping purposes can be counted toward meeting the square footage requirements." "Approved Activity Space" is defined at 606 CMR 7.02 as space that "shall include only usable floor space exclusive of hallways, bathrooms, and portions of rooms or areas that contain furniture or equipment suitable only for adult use," so measure the rooms you will actually use, subtract the adult furniture, and do the arithmetic before you promise ten slots: ten children requires 350 square feet of qualifying space.

Egress is the other hard gate, at 606 CMR 7.07(15)(b): "Family child care homes must have at least two separate exits to the outside, approved by the Department," and if a basement is approved for child care "the basement must have at least two separate means of egress directly to the outside," with a grandfather clause only for homes "initially licensed prior to October 10, 2003, and which remains continuously licensed," and even that lapses "in the event of substantial renovations to the basement." Two administrative facts frame the license itself. Duration: 606 CMR 7.03(5)(b) provides that for family child care "A regular license or approval is valid for three years from the date of issuance unless revoked, suspended, or made probationary," which is longer than the two years a group program gets under 606 CMR 7.03(6)(b)2. And the household, not just the program, is regulated. 606 CMR 7.02 defines "Household Member - Any person other than the educator who resides in the family child care home for 30 consecutive days or more," and M.G.L. c. 15D, s. 8(d) requires that "household members, age 15 or older, or persons regularly on the premises, age 15 or older, of family child care and large family child care homes shall be subject to a background record check not less than every 3 years." 606 CMR 7.04(16)(b) adds that "A family child care licensee must notify the Department within seven days of approval as a foster or adoptive placement resource, or of any change in the household composition," and 7.04(16)(c) that "The licensee must notify the Department whenever a firearm is brought into the family child care home."

An adult child moving home, a new partner, a roommate past the thirtieth day: each is a seven-day notification and a background record check, and each is a common source of a licensing violation that nobody saw coming. One piece of Massachusetts law works decisively in your favour, and you should know it before your first conversation with your city or town. M.G.L. c. 40A, s. 3, as rewritten by SECTION 76 of the same fiscal year 2025 budget, St. 2024, c. 140, provides: "Family child care home and large family child care home as defined in section 1A of chapter 15D shall be an allowable use and no city or town shall prohibit or regulate such use in its zoning ordinances or by-laws." That is an absolute preemption for home programs. A municipality may not require you to obtain a special permit, may not zone you out of a residential district, and may not impose a use restriction on your family child care home. Note the asymmetry: the immediately preceding paragraph of the same section gives centers and school-age programs a weaker protection, providing that no zoning ordinance shall "prohibit, or require a special permit for" a child care facility while expressly allowing "reasonable regulations concerning the bulk and height of structures and determining yard sizes, lot area, setbacks, open space, parking and building coverage requirements," and defining "child care facility" as "a child care center or a school-aged child care program, as defined in section 1A of chapter 15D."

Homes get the stronger rule. What zoning preemption does not do is touch your landlord, your condominium association's rules, your deed restrictions or your homeowner's insurance, and it does not touch the building, fire and sanitary code inspections that 606 CMR 7.03(1)(c)3 requires you to document as part of the application. Finally, two forward-looking facts you should factor into a business plan written in 2026. First, on June 22, 2026 the Department of Early Education and Care announced a Family Child Care Capacity Expansion Pilot to test raising licensed family child care enrollment from ten children to twelve. EEC identified roughly 1,379 eligible providers and expects to seat about 25 to 30 programs; eligibility required a license in good standing, current enrollment of ten children, and continuous operation at a licensed capacity of ten for at least three years, with applications due June 30, 2026. This is a pilot, not a rule change, and nothing in it raises your capacity unless you were invited and selected. Second, if you read a commercial licensing directory that tells you Massachusetts large family child care homes serve "up to 12 to 14 children," close the tab.

No Massachusetts instrument has ever authorised fourteen children in a home, the current regulatory ceiling is ten outside the pilot, and the number that was repealed in 2024 was ten, not fourteen. The instruments that actually decide your case are three: M.G.L. c. 15D as it stands today on the Legislature's own site, 606 CMR 7.00 as the Secretary of the Commonwealth serves it today, and the capacity number EEC prints on your license.

How many children you can care for in Massachusetts

Ten is the answer, but ten is a regulatory number that survives a statute which no longer says it, and the reason that matters to you is that the statute was amended in 2024 while the regulation was not. Start with what is in force. The Department of Early Education and Care defines your business at 606 CMR 7.02 as "Family Child Care - Temporary custody and care provided in a private residence during part or all of the day for no more than ten children younger than 14 years old or children younger than 16 years old if such children have special needs. Family child care shall not mean an informal cooperative arrangement among neighbors or relatives, or the occasional care of children with or without compensation therefore." Ten. The same section defines the group instrument that gets you there: "Multi-age Grouping - Ten or fewer children from birth through 13 years (or 16 years, if such children have special needs) assigned to a single group." Ten again.

And it defines what a licence number actually is: "Licensed Capacity - Determination by the Department of the number of children that a program can care for at any one time under 606 CMR 7.00." That definition is worth reading twice, because the ceiling on your licence is not ten; it is whatever number the Department writes on your licence, and ten is only the maximum it may write. 606 CMR 7.03(2) tells you how that number is set: "Programs will be licensed for the maximum number of children who may be in the care of educators at any one time, taking into consideration the size and layout of the physical facility, the number and qualifications of educators, the equipment and resources available to the children, the individual needs and characteristics of the children served, and the building certificate capacity, if applicable. At no time shall a program admit, supervise or provide care for more than the maximum number of children indicated on the license." Five inputs, and any one of them can hold you below ten: your square footage, your staffing, your equipment, the children you actually serve, and your building certificate.

The last sentence is the enforcement hook, and it is written in the absolute — admit, supervise, or provide care. A child you are merely supervising for an hour as a favour is over capacity if the number on the licence is full. The three licensable tiers are not created by the capacity rule at all; they are created by your own credentials in the educator-qualification section, and applicants routinely discover this after signing a lease on a bigger house. 606 CMR 7.09(15)(b)1. sets the entry tier: "an applicant for a license to care for six or fewer children must have at least the following: a. one year of experience as a parent; or b. one year of full-time experience, or the equivalent, in caring for children younger than 12 years of age; or c. nine months of full-time experience in caring for children younger than 14 years of age and completion of 15 hours of training, approved by the Department, not including the EEC educator orientation; or d. six months of full-time experience in caring for children younger than 12 years of age and completion of 30 hours of training, approved by the Department, not including the EEC orientation; or e. qualification as a teacher or site coordinator by EEC." 606 CMR 7.09(15)(b)2. sets the middle tier: "An applicant for a license to care for seven or eight children, at least two of whom must be school age, must have evidence of having completed within one year prior to application a pre-service training approved by the Department; and either a. two years of experience as a family child care licensee or certified assistant; or b. one year of experience as a family child care licensee or certified assistant and i. one additional year caring for unrelated children in a group setting; or ii.

EEC certification as a teacher or site coordinator", with "An additional three credits in education or early childhood education may substitute for six months of the required additional experience" and six credits for nine months. 606 CMR 7.09(15)(b)3. sets the top tier: "An applicant for a license to care for nine or ten children must have evidence of having completed within one year prior to application a five hour pre-service training approved by the Department and either a. three years of experience as a family child care licensee or certified assistant, or b. one year of experience as a family child care licensee or certified assistant; and one of the following: i. two additional years caring for unrelated children in a group setting, which may include experience as a family child care licensee or certified assistant; ii. EEC certification as a teacher or site coordinator and one additional year of experience caring for unrelated children in a group setting", with the same credit substitutions. Read the tiers as a clock. A first-time applicant whose only qualifying experience is "one year of experience as a parent" is licensable for six.

The eight-child tier requires prior experience as a family child care licensee or certified assistant — a credential you cannot hold on day one — so nobody in Massachusetts is licensed for eight at first licensure without having first worked in someone else's licensed home or held their own licence. The ten-child tier requires three years of it. The single most expensive planning error here is buying or renting for ten while qualifying for six. Note the structure inside 7.09(15)(b)2.: the licence itself is described as a licence "to care for seven or eight children, at least two of whom must be school age". The school-age composition is welded into the licence, not merely into the daily group. That matches the ratio table at 606 CMR 7.10(4)(e), where "seven or eight children" with "one educator" carries the condition "All children over capacity of six must be school age", and "School Age Child" is defined at 606 CMR 7.02 as "A kindergarten child, or a child who is attending a public or approved private elementary school", with "Kindergarten Child" defined as "A child who is five years old or who will attend first grade the following year in a public or private school".

If your two school age children age out of your programme in June and you replace them with preschoolers in September, you have not merely broken a ratio row, you are operating outside the licence you hold. Now the counting rule, which is where Massachusetts takes seats away from you before you enrol anyone. 606 CMR 7.03(5)(c), headed "Determining Capacity", provides that "The following children will be considered to be in the care of educators: 1. every child who lives in the family child care home who is younger than a school age child; 2. every child who lives in the family child care home who is home schooled, regardless of age; 3. every child younger than ten years old who lives in the residence and is present for more than three consecutive hours on each of five consecutive days, excluding weekends and holidays; 4. every person younger than 14 years old who does not live in the residence and is present during the time that child care is being provided; 5. during overnight care, every person younger than 18 years old who is present in the home." Five separate counters, and applicants read only the first.

Your own preschooler occupies a paid seat. Your home-schooled twelve-year-old occupies a seat regardless of age, and this is the clause that catches families who switch to home schooling mid-licence and never tell the Department. Your nine-year-old who is home for three hours a day for a week of school vacation occupies a seat under clause 3. Your teenage nephew who drops in during care hours occupies a seat under clause 4, because clause 4 says "every person younger than 14 years old who does not live in the residence and is present during the time that child care is being provided" — presence, not participation. And if you are approved for overnight care, clause 5 pulls everyone under eighteen in the house into the count for those hours. Build your enrolment model by subtracting your own household from ten first. The physical plant is the second hard ceiling, and it is arithmetic you can do before you apply. 606 CMR 7.07(15)(c) provides: "The licensee must provide: a. a minimum of 150 square feet of approved activity space for one or two children; b. a minimum of 225 square feet of approved activity space for three to six children; c. 35 square feet of approved activity space for each child when serving seven to ten children."

Ten children therefore require 350 square feet of approved activity space, and "Approved Activity Space" is defined at 606 CMR 7.02 as "The indoor and outdoor areas determined by the Department to be safe and appropriate for children in an early education and care program. This space shall include only usable floor space exclusive of hallways, bathrooms, and portions of rooms or areas that contain furniture or equipment suitable only for adult use." Hallways, bathrooms and the corner occupied by your dining set do not count. Two further limits at 606 CMR 7.07(15)(c) narrow it again: "The approved activity space counted toward the square footage requirement can be located on no more than two adjacent floors" and "No more than one area that is used exclusively for napping purposes can be counted toward meeting the square footage requirements." Outdoors, 606 CMR 7.07(7) requires the licensee to "maintain, or have access to, an outdoor play area of at least 75 square feet per child who is outside at any one time" — note "at any one time", so a staggered outdoor schedule can lawfully shrink the area you must provide, and note also that the rule accepts access to space you do not own.

Egress is a capacity gate too: 606 CMR 7.07(15)(b) requires that "Family child care homes must have at least two separate exits to the outside, approved by the Department", and that a basement approved for child care "must have at least two separate means of egress directly to the outside", with a grandfather clause for homes "initially licensed prior to October 10, 2003, and which remains continuously licensed" that dies "in the event of substantial renovations to the basement". There is one building-code threshold that a family child care home should never cross, and knowing where it sits protects your budget. 606 CMR 7.07(2) provides: "Every program that is not located in a residence and every program that has a licensed capacity of more than ten children must provide a certificate of inspection from the Department of Public Safety or the local building inspector certifying that the facility complies with the applicable 780 CMR: The Sate Building Code." Ten is precisely the number at which the state building-code certificate is not yet required. That is not a coincidence; it is the design of the family child care tier.

Any plan that puts an eleventh child in your house converts your home into a facility that must satisfy 780 CMR, and in most Massachusetts housing stock that is a renovation, not a form. Now the statute, and the amendment the coordinator's brief and most of the press coverage get slightly wrong. M.G.L. c. 15D, § 1A defines "Family child care home" as "a private residence which, on a regular basis, receives for temporary custody and care during part or all of the day, children under 7 years of age, or children under 16 years of age if those children have special needs, and receives for temporary custody and care for a limited number of hours children of school age under regulations adopted by the board. The total number of children under 16 in a family child care home shall not exceed 6, including participating children living in the residence." Six, with your own children counted, and that six is still in the statute today. It defines separately "Large family child care home" as "a private residence which, on a regular basis, receives for temporary custody and care during part, or all of the day, children under 7 years of age, or children under 16 years of age if such children have special needs, and receives for temporary custody and care for a limited number of hours children of school age under regulations promulgated by the board. A large family child care home shall have at least 1 approved assistant when the total number of children participating in child care exceeds 6." Read that definition to the end: it carries no number.

It used to. Section 25 of Chapter 140 of the Acts of 2024, the fiscal year 2025 general appropriation act approved in part by the Governor on 29 July 2024, provides in terms: "Section 1A of chapter 15D of the General Laws, as appearing in the 2022 Official Edition, is hereby amended by striking out, in lines 98 to 100, inclusive, the words ', but the number of children under the age of 16 in a large family child care home shall not exceed 10, including participating children living in the residence'." The legislature deleted the ten from the statute and left the assistant requirement standing. It did not delete the six from the family child care home definition, and it did not raise anything: after that amendment the only place a Massachusetts ceiling of ten still lives is 606 CMR 7.02 and the Multi-age Grouping table at 606 CMR 7.10(4). Press coverage that says the fiscal 2025 budget "removed the statutory cap of 10 children in family childcare programs" is describing the right act and the wrong definition — the cap struck was the large-family-home cap, and the six-child cap on the plain family child care home is still on the books, contradicted daily by a regulation that licenses to eight and ten.

Treat the statutory six as a dead letter that has not been repealed, and rely on your licence. The practical effect of the deletion is that EEC can now move the ceiling by regulation instead of by legislation, and it has started to. In June 2026 the Department announced a family child care capacity pilot to test enrolment of twelve children in a small number of homes; as reported by State House News Service, the pilot "will evaluate whether the cap can be raised to 12 'while maintaining high standards for quality, safety, and regulatory compliance,' EEC said", will include roughly twenty-five to thirty programmes, and is open only to providers who "hold a license in 'good standing,' be currently licensed and have 10 children enrolled, and have operated continuously with a licensed capacity of 10 children for at least three years". The legal vehicle for such a thing already exists in your regulation: 606 CMR 7.03(4)(a) provides that "Proposals for pilot or demonstration projects for the innovative delivery of services related to a program will be considered by the Department upon written request.

However, no project shall be implemented without prior written approval of the Department" and that "Projects shall be implemented only on an experimental basis for a specified period not to exceed the term of the license." Two things follow for an applicant. Twelve is not available to you: you cannot reach the pilot's eligibility floor without three continuous years at a licensed capacity of ten. And nothing about the pilot is codified — as of today the Department's own proposed-rulemaking page states that "Department of Early Education & Care does not have any proposed amendments to its regulations at this time", so the number you will be licensed for in 2026 is six, eight or ten. The other route past a written rule is the variance, and it is narrower than people hope. 606 CMR 7.03(4)(b) allows the Department "upon written request" to "grant a variance of any provision contained in 606 CMR 7.04 through 7.13 and allow an alternative method for compliance with such regulation if the applicant for the variance provides clear and convincing evidence, including, at the request of the Department, expert opinion which demonstrates to the satisfaction of the Department that the applicant's alternative method will comply with the intent of the regulation".

Note the range: 7.04 through 7.13. The definition of family child care at 606 CMR 7.02 and the licensure provisions at 606 CMR 7.03 are outside the variance power, so the ten in the definition cannot be varied even though the square-footage rule at 7.07 and the ratio table at 7.10 can be. Variances are also time-limited — "for a specified period of time not to exceed the term of the license" — and revocable: "If the Department receives or finds evidence that the conditions of the variance have been violated, the variance will be rescinded." Capacity moves downward more easily than upward, and the mechanism is worth knowing before you are on the receiving end of it. EEC's licensing policy statement "Freezing or Reducing Enrollment" (document code EECFreezeReduceEnrollment20110714) states that "When EEC finds that a program or facility is not in compliance with regulations governing the licensure of such program or facility, in order to ensure that the program is soundly administered, EEC may impose a variety of remedial requirements, including prohibiting the enrollment of new children and reducing the number of children a program is licensed to serve", and lists the triggers, which include "insufficient numbers of staff, unqualified staff", "enrollment in excess of the licensed capacity", and "the facility or program has enrolled more children than allowed by the program's building certificate".

The same policy warns that "The enrollment freeze or capacity reduction will be noted in the EEC licensing database and will become part of the program's licensing history" and "will also be reflected in the current EEC licensed program listing on the EEC website", and that "During any enrollment freeze, no new children unless otherwise approved by EEC may be enrolled; no previously terminated children may be re-enrolled; and no vacancies resulting from a child who is graduating, terminating or otherwise leaving the program may be filled." It also states that "EEC may issue a license with a reduced capacity if there is evidence that the program will be unable to continue to serve the number of children for which it had been previously licensed." One over-enrolment visit can therefore cost you the tier you spent three years qualifying for, publicly, in the state's own consumer-facing directory. Three structural limits round out the ceiling. First, one licence per person: 606 CMR 7.03(5)(f) says flatly "A family child care licensee may not hold more than one family child care license."

You cannot double your capacity by licensing a second home in your own name. Second, where the care may happen: 606 CMR 7.03(5)(e) provides that "family child care may only be provided in a dwelling that provides complete independent living facilities for one or more persons including permanent provisions for living, sleeping, eating, cooking, and sanitation", and that the dwelling must either "be occupied for living purposes on a full time basis by either the licensee, or an individual personally known to the licensee, as the occupant's legal residence" or be unoccupied and sit on the same property as the licensee's single-family home, or in the other half of a duplex the licensee lives in, or in a structure "with a maximum of three stories, with no more than one dwelling unit located on each floor level" where the licensee lives in another unit. Third, duration: 606 CMR 7.03(5)(b) gives family child care "A regular license or approval is valid for three years from the date of issuance unless revoked, suspended, or made probationary" — three years, not the two that centres get under 606 CMR 7.03(6)(b)2. One capacity is set outside the daytime table entirely.

If you intend to offer regular overnight care — defined at 606 CMR 7.02 as "Care provided to any child care child between the hours of 11:30 P.M. and 6:00 A.M. more than one day per week for more than eight weeks in a 12-month period" — then 606 CMR 7.11(15)(b)2. requires that "The educator must submit a written plan for approval to EEC and must receive EEC written approval prior to providing any regular overnight care", and that plan must state "the maximum overnight capacity being requested and the age range of children expected to be in care", must include "a floor plan, with designated exit routes, for the entire building where children are located, and the rooms used by children for sleeping", and must give "a specific description of how an evacuation would occur when the maximum capacity of children and educators is present". Your overnight capacity is a separately approved number, and it is bounded further by the counting rule at 606 CMR 7.03(5)(c)5., which during overnight care counts "every person younger than 18 years old who is present in the home". Finally, the good news that most applicants never hear, and that has saved Massachusetts home programmes from the zoning fights that kill them elsewhere.

Section 76 of the same Chapter 140 of the Acts of 2024 rewrote the fifth paragraph of M.G.L. c. 40A, § 3 to read: "Family child care home and large family child care home as defined in section 1A of chapter 15D shall be an allowable use and no city or town shall prohibit or regulate such use in its zoning ordinances or by-laws." No city or town may cap you, zone you out, require a special permit, or attach conditions through its by-law. If a building department tells you a home programme needs a special permit or a change of use, that paragraph is your answer. What still binds is the state building code above ten children under 606 CMR 7.07(2), the fire-code evidence required by 606 CMR 7.07(3) — "The licensee shall submit evidence of compliance with applicable fire codes" — the well-water approval at 606 CMR 7.07(4), and the lead-paint disclosure that 606 CMR 7.03(5)(a)1. requires you to file with your application. Two closing precautions on sourcing, because the wrong document is easy to find here. The Secretary of the Commonwealth's State Bookstore catalogue still sells "102 CMR 1.00 - 12.00", described as including "Standards for the Licensure of Family Child Care and Large Family Care Homes" — that is the pre-2010 Office of Child Care Services regime, superseded when 606 CMR 7.00 took effect, as its own transition clause at 606 CMR 7.14(3) records: "Any license or approval issued under the provisions of 102 CMR 7.00 or 8.00 is in effect immediately prior to January 22, 2010 shall, notwithstanding its expiration date, remain in effect, unless suspended or revoked, until a new license or approval is issued".

Anything citing 102 CMR 8.00 for a large family child care home is describing a dead licence type; 606 CMR 7.00 does not use the phrase "large family child care home" anywhere in its text, only the statute does. And the number on your licence is the only number that is enforceable against you: 606 CMR 7.04(14)(d) requires you to post "the current license or approval" in an area easily visible to parents, educators and visitors, which means the ceiling you are inspected against is the one hanging on your own wall.

Adult-to-child ratios

Massachusetts does not give family child care a staff-to-child ratio in the form you are expecting, and the first money an applicant loses here is lost by looking for one. There is no line in 606 CMR 7.00 that reads one adult to four toddlers or one adult to seven preschoolers for a home program. The operative instrument is a five-row table inside 606 CMR 7.10(4), headed Multi-age Grouping, whose columns are "Regulation Number", "Group Size", "Minimum Number of Educators Present" and "Limits on Ages of Children". Each row is a permitted shape of a group: a total headcount, the number of educators that shape requires, and an age composition that shape must satisfy. You do not compute a ratio and then fill seats; you pick a row and you stay inside it. 606 CMR 7.10(4) opens by telling you who may use those rows: "The Multi-age Grouping ratios and group sizes specified at 606 CMR 7.10(4)(d) through (h) may be used by: (a) family child care and small group and school age child care programs", and only then, in (b) and (c), by large centres under conditions. The definition at 606 CMR 7.02 fixes the outer edge of the instrument: "Multi-age Grouping - Ten or fewer children from birth through 13 years (or 16 years, if such children have special needs) assigned to a single group." A family child care home in Massachusetts is one multi-age group.

That single sentence is why ten is the number everyone repeats, and it is a regulatory number, not a statutory one — see the capacity field, because the statute that used to carry ten no longer does. Read the five rows exactly as the Department serves them today. 606 CMR 7.10(4)(d): "six or fewer children", "one educator", "No more than three children younger than two years old, including at least one toddler who is walking independently. Additional children must be older than 24 months." 606 CMR 7.10(4)(e): "seven or eight children", "one educator", "No more than three children younger than two years old, including at least one toddler who is walking independently. Additional children must be older than 24 months. All children over capacity of six must be school age." 606 CMR 7.10(4)(f): "six or fewer children", "two educators", "No more than six children younger than two years old." 606 CMR 7.10(4)(g): "seven – ten children", "two educators", "No more than six children younger than two years old, including no more than three infants." 606 CMR 7.10(4)(h): "seven-ten children", "three educators", "No more than six infants.

Additional children must be 15 months of age or older." Four consequences follow, and each one is a place applicants lose money. First, eight children with a single educator is lawful in Massachusetts, at 606 CMR 7.10(4)(e), provided every child above six is a school age child. That is the row that surprises people who arrive from a ratio state. Second, the seventh child is not free: under (e) the seventh and eighth must both be school age, so a seven-child group holding six preschoolers and one four-year-old is not a lawful (e) group, it is an unlawful (d) group. Third, going past eight, or past six with anyone who is not school age, requires a second educator physically present under (g) — not on call, not upstairs, not the spouse who is home. Fourth, the infant sub-limits are the hard edges of every row: three children younger than two years old in the one-educator rows (d) and (e), six children younger than two with no more than three infants in the two-educator row (g), and six infants only in the three-educator row (h). The word infant is defined at 606 CMR 7.02 as "A child who is younger than 15 months old", and toddler as "A child who is at least 15 months of age, but younger than 33 months old".

So "younger than two years old" and "infant" are two different counters running at the same time in row (g), and an inspector counts both. The "at least one toddler who is walking independently" clause in rows (d) and (e) is the single most misread sentence in the Massachusetts table. It is not permission; it is a condition on the composition. If you are carrying three children younger than two in a one-educator group, at least one of those three must be walking independently, and every other child in the group beyond that trio "must be older than 24 months". Two non-ambulatory infants plus one walking toddler is the maximum under-two load a lone educator may carry, and the rest of the group has to be over 24 months — which quietly rules out the twenty-month-old you were planning to add. Who counts as an educator for these rows is a separate question with its own trap. 606 CMR 7.10(3)(a) reads: "For purposes of calculating staff: child ratios, staff shall include only those EEC-qualified persons who are assigned to care for children for specific hours of the day." The words "EEC-qualified" and "assigned" both do work. A person who has not been approved or certified by the Department in one of the family child care roles is not a second educator no matter how competent, how related to you, or how many hours they put in. 606 CMR 7.10(3)(b) closes the volunteer route: "Volunteers and student interns shall not be included in staff: child ratios unless they are at least 16 years of age (in Small and Large Group and School Age Child Care) or at least 18 years of age (in Family Child Care) and are assigned to the program for at least three months."

EEC's own family child care licensing policy statement "Volunteers, Student Interns and Ratios" (document code FCCVolunteer2012.04.26) goes further than the regulation and tells you the practical rule: "Volunteers and Student Interns who wish to be included in staff to child ratios in a family child care setting, must additionally apply and be approved/certified as a Family Child Care Approved Assistant. Once the approval/certification is granted the individual may be counted in the staff to child ratios." Treat that as the operating rule: in a home, the only bodies that count toward the two-educator rows are the licensee, a Certified Assistant, or a Regular Assistant holding a current EEC certificate. And 606 CMR 7.09(15)(a) states the floor plainly: "All educators must be at least 18 years of age." The assistant regime is the historic Massachusetts trap, and it is worth setting out in full because the regulation and the agency's public wording do not read the same. 606 CMR 7.02 defines "Certified Assistant - A person who holds a certified assistant certificate issued by the Department; who, at minimum, meets the qualifications of a provider licensed to care for six children; and who works with or substitutes for the licensee in a family child care home, depending on his/her level of qualification."

It defines "Regular Assistant - A person who holds a regular assistant certificate issued by the Department; does not meet the qualifications of the licensee for whom they are working; and who may replace a licensee or certified assistant on a limited basis in a family child care home as allowed under 606 CMR 7.09(15)(c)2.a." The operative rules sit at 606 CMR 7.09(15)(c). For the certified tier: "An educator who meets the qualifications of the licensee may replace the licensee at any time, provided notice is given to parents in advance, in accordance with 606 CMR 7.08(8)(c)", and "An educator who meets the qualifications of a family child care educator licensed to serve six or fewer children may substitute for a provider licensed to care for up to ten children for up to 25 hours in a 12 month period." For the regular tier: "An educator whose qualifications are neither equal to nor greater than the licensee's qualifications may provide care under the general supervision of the licensee. a. A regular assistant may be alone on the premises with up to six children for up to 25 hours in a 12 month period, or up to eight hours in a seven day period, provided s/he is currently certified in first aid and CPR. b.

In programs licensed to care for seven or more children, a regular assistant may provide care only under the supervision of a licensee or certified assistant." Parse 7.09(15)(c)2.b carefully, because it is where applicants over-read their own capacity. A Regular Assistant is a lawful second educator for the two-educator rows (g) and (h) — nothing forbids it, and the assistant holds a Department certificate, so 7.10(3)(a) is satisfied — but only while you or a Certified Assistant are supervising on the premises. The moment you step out, the group must collapse to six children, the clock at 7.09(15)(c)2.a starts, and that clock is brutal: twenty-five hours in twelve months, and never more than eight hours in any seven day period. EEC's licensing policy statement "Use of Regular Assistants in Family Child Care Homes" (document code FCCRegularAssistants20120626) removes the workaround people try: "no provider may leave their child care children with an uncertified assistant for more than a total of 8 hours per week or a total of 25 hours per year, no matter how many assistants he/she uses.

The maximum amount of time child care children may be left alone with any number of regular assistants is 25 hours in one year, and no more than 8 hours in any seven day period." Hiring a second Regular Assistant does not buy you a second allowance. The same policy also tells you the limit runs per home rather than per person: "the aggregate number of hours that a regular assistant may be left alone with child care children in a variety of homes may be greater than the 8 hours per week or 25 hours per year, but those limits apply to each family child care home separately." And it closes with the sentence that governs your daily staffing: "Regular assistants may work with a provider or Certified Assistant for any length of time when the provider or Certified Assistant is on the child care premises." Now the contradiction you must know about before you build a business plan, because it decides whether you need an assistant at seven children or at nine. M.G.L. c. 15D, § 1A defines "Large family child care home" as "a private residence which, on a regular basis, receives for temporary custody and care during part, or all of the day, children under 7 years of age, or children under 16 years of age if such children have special needs, and receives for temporary custody and care for a limited number of hours children of school age under regulations promulgated by the board. A large family child care home shall have at least 1 approved assistant when the total number of children participating in child care exceeds 6." Read literally, the statute requires an approved assistant above six children.

The regulation the Department actually inspects against does not: 606 CMR 7.10(4)(e) authorises "seven or eight children" with "one educator" so long as "All children over capacity of six must be school age", and 606 CMR 7.09(15)(b)2. licenses a provider "to care for seven or eight children, at least two of whom must be school age" on the strength of the provider's own experience and pre-service training, saying nothing about an assistant. EEC's own consumer page "Learn about Family Child Care" states the regulation's position in plain words — "Up to 8 children: A licensed Family Child Care provider may enroll up to 8 children in their program without an assistant if at least 2 of the children are school age" — and reserves the assistant for the top tier: "Up to 10 children: A licensed Family Child Care provider may enroll up to 10 children in their program if there is an approved assistant working with them." The practical answer for an applicant is that the licence you hold and the row you are standing in govern: at seven or eight, all school age above six, you may be alone; at nine or ten, or at seven and eight with a non-school-age child in the extra seats, you need a second educator present.

But do not let anyone quoting § 1A at you tell you your 7-8 licence is invalid, and equally do not build a nine- or ten-child model on the theory that § 1A's silence about numbers means the ceiling is open — the ceiling is at 606 CMR 7.02 and 7.10(4), and it is ten. The tier you may be licensed for is decided by your own credentials before any child walks in, and that is a capacity question with a ratio consequence. 606 CMR 7.09(15)(b)2. requires, for seven or eight children, "evidence of having completed within one year prior to application a pre-service training approved by the Department" plus "two years of experience as a family child care licensee or certified assistant" or one year of that experience plus a further year with unrelated children in a group setting or EEC teacher/site-coordinator certification. 606 CMR 7.09(15)(b)3. requires, for nine or ten children, "a five hour pre-service training approved by the Department" plus "three years of experience as a family child care licensee or certified assistant" or one year plus two additional years in a group setting, or one year plus EEC teacher or site coordinator certification and one additional year.

In both tiers "An additional three credits in education or early childhood education may substitute for six months of the required additional experience" and six credits for nine months. A first-time applicant with a year of parenting experience qualifies under 606 CMR 7.09(15)(b)1. for six or fewer children and cannot buy the eight-child row with an assistant. The assistant does not upgrade your licence. Your résumé does. Supervision is a separate obligation that survives every ratio row, and Massachusetts writes it as duties, not numbers. 606 CMR 7.10(5) requires that "all licensees and educators must exercise appropriate supervision of the children in their care in order to ensure their health and safety at all times. Such supervision must include, but not be limited to, indoor and outdoor activities, mealtimes, naptime, transportation, field trips, and transitions between activities." The one hard number is at 606 CMR 7.10(5)(a): "Children younger than six months of age at the time of enrollment must be under direct visual supervision at all times, including while napping, during the first six weeks they are in care."

Six weeks of eyes-on a newborn, including through nap, is what an infant enrolment actually costs you in a one-educator group. The judgment factors at 606 CMR 7.10(5)(b) are the five an inspector will walk you through: "the chronological age and developmental needs of each child", "the behavioral characteristics of each child", "the number of educators supervising each group and their qualifications", "the environment and its impact upon the educator's ability to see and/or hear children", and "the nature of the activity and the materials and equipment used". Then 606 CMR 7.10(5)(c) through (f): "Educators must be in sufficient proximity to children at all times in order to be able to intervene quickly when necessary"; "Educators must be positioned to maximize their ability to see and/or hear children in their care"; "Educators must be aware of children's activities at all times"; "Educators must not engage in any other activities or tasks that could unnecessarily divert their attention from supervising the children." That last one is the citation you get for cooking, cleaning or taking a call while alone with eight children.

Two age-based releases loosen the visual tether, and both need paper. 606 CMR 7.10(5)(j): "Children age seven or older may, with written parental consent, participate in activities within the approved indoor space without constant visual supervision by the educator. The educator must be aware of the child's location, monitor the child's activity at regular intervals based on the factors in 606 CMR 7.10(5)(b), be readily available to assist children, as needed, and be able to respond immediately to an emergency situation." 606 CMR 7.10(5)(k): "Children age nine or older may leave the premises with written parent and educator consent, provided that the consent specifies the day and time the child will leave, the time the child will return, if applicable, the method of transportation the child will use, and the parent's responsibility for the child once he or she leaves the premises." Without the written consent on file, the release does not exist and the child counts as unsupervised. The provisions written specifically for homes are at 606 CMR 7.10(6) and (7), and you are expected to know they override the general outdoor rule. 606 CMR 7.10(6) begins "Notwithstanding 606 CMR 7.10(5)(h)" and permits at (a) that "children five years of age or older may be allowed to engage in outdoor activities unaccompanied by the educator if: 1. the outdoor play space is located on the family child care premises of a single family or first floor residence, and is enclosed by a fence at least four feet high; and 2. the children are observed by the caregiver every 15 minutes; 3. the time unaccompanied by the provider does not exceed one hour; and 4. the parents have given written permission."

All four conditions, not three: a four-foot fence, a fifteen-minute observation cycle, a one-hour ceiling, and written parental permission. 606 CMR 7.10(6)(b) extends the seven-and-older release to the approved outdoor space on the same four conditions of awareness, interval monitoring, readiness to assist and immediate emergency response. 606 CMR 7.10(7) then adds the four rules that make a home a home: "(a) Except as provided at 606 CMR 7.10(5)(j), children must always be on the same floor level as the educator. (b) Except when attending to their personal hygiene needs, educators must be actively engaged in child care and education activities during all times when children are in care. (c) Educators must ensure that infants and toddlers are placed in a safe location when educators are unable to maintain direct eye contact with them for any reason. (d) The educator must visually observe napping children at least every 15 minutes. When children are placed in a separate room for naps, the door must remain ajar." The same-floor rule at (7)(a) is the one that quietly kills the basement-playroom-while-I-cook-upstairs plan, and the ajar door at (7)(d) is a recurring monitoring citation.

Know also what does not apply to you, because applicants copy centre rules into home policies and then get audited against them. 606 CMR 7.10(8) is headed "Additional Provisions for Small Group and School Age and Large Group and School Age Child Care" — not family child care. So the written staffing schedule at 606 CMR 7.10(8)(b), which requires that "the Licensee must establish a written schedule listing all persons on duty, including volunteers" and that it "must show compliance with at least the minimum educator ratios at all times, including during breaks and planning time", is a centre obligation. So too is the second-adult rule at 606 CMR 7.10(8)(c): "Notwithstanding the staff: child ratios provided at 606 CMR 7.10(4), there must always be a second adult trained in the program's health care and emergency procedures immediately available in case of an emergency." Massachusetts imposes no second-adult backstop on a family child care home operating a lawful one-educator row. Likewise 606 CMR 7.10(9), the fixed-age and mixed-age tables — infants at 1:3 with a maximum group of 7, toddlers at 1:4 with a maximum of 9, preschoolers at 1:10 full day with a maximum of 20 and 1:12 half day with a maximum of 24, kindergarten at 1:15 with a maximum of 30, school age at 1:13 with a maximum of 26, and the mixed-age rows at 1:3 for an infant/toddler group of 9 with no more than three infants, 1:5 for a toddler/preschool group of 9, 1:10 for a preschool/school age group of 20 with a maximum age of eight, and 1:13 for a kindergarten/school age group of 26 — belong to large group and school age programs.

Those are the numbers a search engine will hand you when you type "Massachusetts daycare ratios". They are not your numbers. Quoting them in your own parent handbook is a self-inflicted finding. Ratios follow the children out of the house. 606 CMR 7.07(9) provides that for programs offering "swimming, boating or other water activities, the licensee must ensure that the area is safe and children are directly supervised at all times during activities involving water, including tubs, pools, showers, or standing water.

Educator/child ratios must be sufficient to maintain the safety of children in or near water" — an open-ended standard, which in practice means the ratio your inspector thinks was sufficient after the fact. 606 CMR 7.13 applies "to all programs, including family child care" and requires at 7.13(1) "a written plan for the safety and supervision of all children during transport" that "must describe how children are transported to and from the program, in an emergency, and on field trips" and "must also address the safety and supervision of children who walk and who arrive by public transportation", and at 7.13(2) "written parental consent for each child's individual transportation plan". 606 CMR 7.13(4)(f) requires that "at least one person on each vehicle is currently certified in first aid and CPR", and 7.13(4)(a) drops a capacity cliff into your transport plan: any vehicle "used for transportation of more than eight passengers at any one time and the driver thereof" must "conform to Massachusetts school bus requirements as contained in the pertinent sections of M.G.L. c. 90 and 540 CMR 7.00: Minimum Standards for Construction and Equipment of School Buses". A ten-child licence plus one educator is eleven occupants, so the day you decide to drive your whole group anywhere, you have crossed into school bus territory. 606 CMR 7.13(3)(i) adds that "Children must not be regularly transported for periods longer than 45 minutes one way", and 606 CMR 7.10(5)(i), cross-referencing 7.13(3)(j), states that "a child must never be left unattended in a vehicle."

Two more ratio-adjacent duties. 606 CMR 7.04(13)(a) requires that when you serve a child with a disability you identify in writing, with the parent's input, the accommodations needed, including "the size of the group to which the child may be assigned and the appropriate staff/child ratio" — meaning your lawful table row can be tightened for a specific child by your own written accommodation, and you will then be held to your own document. And 606 CMR 7.11(14) provides that "Educators providing evening care must comply with all applicable regulations regarding daytime care, including, but not limited to, staffing ratios, supervision of children, curriculum, nutrition, ventilation and lighting, and naptime regulations", with evening care defined at 606 CMR 7.02 as "Child care provided between the hours of 8:00 P.M. and 11:30 P.M." Overnight care adds a wakefulness rule rather than a ratio: 606 CMR 7.11(15)(a) requires that "The educator must remain on the same floor level as child care children during the overnight shift" and that "The educator must remain awake until all the children, including all household members and/or visitors below the age of 12 years old, are asleep."

The authority under which all of this is issued is short and worth memorising, because it is what you cite when someone tells you a different agency licenses you: the regulation's own closing line is "REGULATORY AUTHORITY 606 CMR 7.00: M.G.L. c. 15D", and M.G.L. c. 15D, § 2 provides that "There shall be in the executive office of education a department of early education and care" whose duties include, at § 2(c), to "license or approve child care centers, school-aged child care programs, family child care homes and large family child care homes". EEC has sat inside the Executive Office of Education since it was created; nothing has moved the licensing function out of it. Finally, note what is not in force: as of today the Department's own page listing proposed rulemaking states that "Department of Early Education & Care does not have any proposed amendments to its regulations at this time", so the five rows at 606 CMR 7.10(4) are the rows you will be inspected against, and any number you have read about twelve children belongs to a pilot, not to the table.

Training you must complete before licensure

START WITH THE DATE, BECAUSE THE MASSACHUSETTS PRE-SERVICE GATE MOVED AND THE DOCUMENT MOST OF THE INTERNET STILL QUOTES IS A 2012 POLICY WHOSE EVERY TRAINING LINK IS DEAD. Verified 26 August 2026 against the operative text and against the live servers, not against a pinned copy. The regulation that licenses you is 606 CMR 7.00, Standards for the Licensure or Approval of Family Child Care; Small Group and School Age and Large Group and School Age Child Care Programs, promulgated by the Department of Early Education and Care under the authority line that closes the chapter: "606 CMR 7.00: M.G.L. c. 15D." The chapter as it stands today was last amended by Massachusetts Register Issue 1452 and Massachusetts Register Issue 1459, both effective 1 September 2021; there is no later amendment to 7.03 or 7.09. The Secretary of the Commonwealth serves that text at reg_pub/pdf/600/606007.pdf, a file whose server stamps it last modified 24 December 2021, and the 2021 emergency-revision content (including the workforce-shortage clause at 606 CMR 7.09(20)) is present in it, which is how you know the file the Secretary serves and the text the codifiers report are the same text.

What has changed since 2021 is not the regulation. It is the policy layer underneath the regulation, and that is where the pre-service requirement actually lives. THE ONE SENTENCE THAT DECIDES WHETHER A LICENCE CAN ISSUE AT ALL IS 606 CMR 7.03(1)(b). The Department may issue a child care license provided that, in the words of the rule, "within one year prior to licensure the licensee (or his or her designee) has attended an orientation to early education and care approved by the Department". That is a condition on the issuance of the licence, not a condition you can cure afterwards. It is reinforced from the educator side at 606 CMR 7.09(9): "All educators must attend an orientation to early education and care approved by the Department." Note the timing trap embedded in the wording. The orientation must sit within the twelve months BEFORE licensure. If you attend orientation, then spend fourteen months finding a dwelling, passing a background record check, chasing a lead paint disclosure and scheduling inspections, your orientation has aged out of the window and you attend again. Applicants front-load the training because it feels like the first step, then discover at the end of a long application that the certificate is stale.

Sequence it late, not early. WHAT "APPROVED BY THE DEPARTMENT" MEANS IS SET BY POLICY, AND THE POLICY THAT DEFINED IT FOR A DECADE IS NOW A GHOST. EEC's policy statement "Orientation to Early Education and Care", document control number EECOrientation20121004, states in its own words: "EEC regulations require the licensee to provide an orientation to its program for all educators it employs. [See 606 CMR 7.09(15)(d) for family child care educators, and 606 CMR 7.09(17)(a) for small or large group and school age child care programs]. In addition to the orientation to the individual program, EEC regulations require that: 'All educators must attend an orientation to early education and care approved by the Department' [See 606 CMR 7.09(9)]. This policy specifies the activities required to comply with 606 CMR 7.09(9)." For family child care it then says: "Applicants for licensure in family child care or for certification as an assistant must attend a five-hour, in-person orientation to family child care delivered by an EEC-approved trainer within one year prior to application for licensure or certification. (This training is approved for 5 EEC Professional Development hours or .5 CEUs.)" It adds a second module: "Family child care licensees and certified assistants first licensed or certified after August, 2010, must complete Module Two of the Family Child Care Orientation within their first six months of licensure or certification."

It adds a capacity-specific module: "Applicants for a license to serve 7 - 10 children in family child care or for certification as an assistant to serve 7 - 10 children must complete the on-line training 'Maintaining Quality While Expanding Your Capacity' ... before receiving a capacity increase. (This training is approved for 2 EEC Professional Development hours.)" It adds an assistant module, a SIDS module required "prior to licensure, certification or approval as an assistant", a transportation module "Look Before You Lock" within sixty days, and "Medication Administration: The Five Rights" before administering any medication. EVERY SINGLE TRAINING URL IN THAT POLICY IS DEAD TODAY, AND THE POLICY ITSELF HAS BEEN DELISTED. Measured 26 August 2026: the SIDS self-study at eec.state.ma.us/docs1/Workforce_Dev/SIDS revised self-study.pps returns HTTP 503; the Look Before You Lock deck at eec.state.ma.us/docs1/Workforce_Dev/20120502-look-before-lock.pps returns 503; the Five Rights medication module at eec.state.ma.us/docs1/regs_policies/FiveRightsMedAdmin/ returns 503; the family child care assistant orientation at eec.state.ma.us/docs1/regs_policies/FCCAssistOrient/ returns 503; the capacity-expansion PowerPoint at mass.gov/edu/docs/eec/20101015-fcc-expansion-training.ppt returns 403; and the professional development calendar the companion policy points to, eec.state.ma.us/ProfessionalDevelopment/WebFindTraining.aspx, returns 503. And EEC's own current index page, Licensing Policies for Family Child Care Providers, does not contain the word "orientation" anywhere: the 2012 policy has been dropped from the list EEC publishes for family child care, even though the file still resolves.

If a consultant hands you a checklist saying "complete the five-hour in-person orientation and the SIDS PowerPoint", they are reading a delisted 2012 document and pointing you at six dead servers. WHAT ACTUALLY GATES YOUR LICENCE IN 2026 IS EEC ESSENTIALS 2.0, AND THE OPERATIVE INSTRUMENT IS A POLICY ADVISORY, NOT A REGULATION. EEC Policy Advisory Field Operations 2024-9, "Policy: EEC Essentials 2.0", carries "Effective Date: May 8, 2024 (staff have until June 30, 2025 to complete EEC Essentials 2.0)" and is signed under Commissioner Amy Kershaw. It states: "The revisions to this policy and the related EEC Essentials training package are in response to requirements from the US Department of Health and Human Services, Office of Child Care within the Administration for Children and Families", and "Completing EEC Essentials 2.0 is mandatory for all new staff entering the field." On applicability it is explicit about you: "All educators and administrators working in EEC-licensed or funded programs will be required to complete the EEC Essentials 2.0 training package. In Family Child Care (FCC) programs, the FCC licensee, certified assistants, and regular assistants, must complete the training package."

And on timing: "Staff that are new to working in EEC-licensed or funded programs Must complete a background check and the EEC Essentials 2.0 before working with children." The companion EEC Essentials 2.0 FAQs, dated April 2024, remove the ambiguity for family child care specifically: "For Family Child Care providers and assistants, the EEC Essential 2.0 training package needs to be completed prior to licensure. Additionally, certification of current training in CPR and first aid is also required prior to licensure." THE PACKAGE IS THIRTEEN COURSES AND ABOUT TWELVE HOURS, AND YOU CANNOT CHERRY-PICK IT. The advisory says: "All applicable staff in early childhood programs (center-based and family child care) will enroll in and complete the 13-course package labeled 'EEC Essentials for Early Childhood 2.0'. This package should take approximately 12 hours." The FAQ lists the modules by name: "Protecting Children from Abuse and Neglect (Mandated Reporter Training), Emergency Response, Introduction to First Aid and CPR, Food Safety, Hazardous Materials, Prevention and Control of Infectious Diseases, Introduction to Child Growth and Development, Medication Administration, Missing Child Prevention, Transporting Children Safely, Physical Premises Safety, Safe Sleeping Practices, and Shaken Baby Syndrome."

There is one certificate for the whole package, not thirteen: "Does each module have its own certificate? No. You must complete all the course modules in the EEC Essentials 2.0 training package." And prior equivalent training does not excuse you: "What if I took an EEC-approved course on any of these topics already or I took the original EEC Essentials? All Staff working directly with children need to complete the EEC Essentials 2.0 course by June 30, 2025. This includes staff that may have taken training on one or more of these topics in the past. These are requirements from the Federal Government." If you took the original twelve-course EEC Essentials, the FAQ answers "Yes" to whether you must take 2.0 anyway. THIS IS WHERE THE MANDATED-TOPIC LIST ACTUALLY LIVES, AND IT IS NOT IN 606 CMR 7.00. Read 606 CMR 7.00 cover to cover and you will not find a rule ordering a course in Sudden Infant Death Syndrome, a course in shaken baby syndrome, or a course in mandated reporting. The regulation imposes the underlying DUTIES without imposing the courses. On safe sleep it commands the practice: "Programs serving infants must: 1. place infants on their backs for sleeping, unless the child's health care professional orders otherwise in writing".

On mandated reporting it commands the status: "Every educator is a mandated reporter under M.G.L. c. 119, s. 51A and must make a report to the Department of Children and Families whenever he/she has reasonable cause to believe a child in the program is suffering from serious physical or emotional injury resulting from abuse inflicted upon the child, including but not limited to sexual abuse, or from neglect, including but not limited to malnutrition, no matter where the abuse or neglect may have occurred and by whom it was inflicted." The training obligations attach through the policy layer. EEC's Safe Sleep for Infants policy, effective 1 October 2023, states: "All staff working with infants under 12 months of age must be trained on safe sleep practices prior to caring for infants. In accordance with the EEC Essentials Policy, Infant Safe Sleep Practices and Shaken Baby Syndrome trainings must be completed prior to working with infants and toddlers in an unsupervised capacity. An educator trained in safe sleep practices must be present at all times where there is a sleeping infant."

And the FAQ closes the mandated-reporter question with three words: "Does this replace the mandatory 51A training? Yes." So the topic list exists, it is federal in origin, it is delivered as one package, and it is enforced through a policy advisory that no version of the Code of Massachusetts Regulations will ever show you. Anyone auditing your readiness by reading only 606 CMR 7.00 will tell you Massachusetts has no SIDS or shaken-baby training requirement. That is a reading of the code, and it is wrong about the world. THE ONLY TRAINING THE REGULATION ITSELF DEMANDS BEFORE A FAMILY CHILD CARE LICENCE ISSUES IS FIRST AID AND CPR, AND IT IS THE ONE MOST APPLICANTS BUY WRONG. 606 CMR 7.09(15)(b) opens: "Prior to being licensed for the first time to provide family child care the applicant must submit evidence of current certification in basic first aid and CPR that is age appropriate for all of the children in care." 606 CMR 7.03(5)(a) repeats it in the documents list: the licensee must submit "certification of current training in CPR and first aid, per 606 CMR 7.09(15)(e)". EEC's policy "CPR and First Aid Training and Certification", effective 1 October 2020 and updated 17 December 2021, sets the acceptance rules.

On CPR: "Online CPR training may be taken as long as the participant is required as part of the online training to demonstrate and successfully complete age-appropriate CPR techniques to a certified instructor. EEC will not accept CPR certification training that does not include hands-on skill demonstration." Appropriate courses must "Address choking and rescue breathing, Include the use of mannequins, Maintain an appropriate mannequin to student ratio, Be appropriate for the ages of the children in care, and Include a requirement that the participant demonstrates age-appropriate CPR technique." On first aid the instructor must be currently certified by one of exactly seven bodies: "1. American Heart Association; 2. American Red Cross; 3. National Safety Council; 4. American Safety and Health Institute; 5. Massachusetts Firefighting Academy; 6. Emergency Medical Instructor/Coordinator Training Course of Department of Public Health; or 7. EMS Safety Services, Inc." The policy then adds the line that costs money: "NOTE: EEC does not maintain an approved list of individual First Aid and CPR trainers."

There is no roster to check against. A twenty-dollar wholly online certificate with no skills demonstration is worthless to EEC, and you will not learn that until a licensor looks at it. Buy the blended course with an in-person or live-proctored skills check, and buy the age-appropriate version covering infants if you intend to enrol infants. THE CAPACITY YOU APPLY FOR CHANGES THE PRE-SERVICE REQUIREMENT, AND THE RULE IS ASYMMETRIC IN A WAY THAT CATCHES PEOPLE. For the base licence, 606 CMR 7.09(15)(b)1 requires "an applicant for a license to care for six or fewer children must have at least the following: a. one year of experience as a parent; or b. one year of full-time experience, or the equivalent, in caring for children younger than 12 years of age; or c. nine months of full-time experience in caring for children younger than 14 years of age and completion of 15 hours of training, approved by the Department, not including the EEC educator orientation; or d. six months of full-time experience in caring for children younger than 12 years of age and completion of 30 hours of training, approved by the Department, not including the EEC orientation; or e. qualification as a teacher or site coordinator by EEC."

Read the exclusions in c and d: the fifteen and thirty hours are "not including the EEC educator orientation". You cannot count the orientation twice. For seven or eight children, 606 CMR 7.09(15)(b)2 requires an applicant "must have evidence of having completed within one year prior to application a pre-service training approved by the Department" plus "two years of experience as a family child care licensee or certified assistant" or one year plus an additional year in a group setting or EEC teacher/site coordinator certification. For nine or ten children, 606 CMR 7.09(15)(b)3 requires "evidence of having completed within one year prior to application a five hour pre-service training approved by the Department" plus three years as a licensee or certified assistant, or one year plus two additional years in a group setting, or EEC certification plus one additional year. Notice what the text does and does not say. The nine-to-ten tier names an hour figure, "a five hour pre-service training". The seven-to-eight tier names no hour figure at all: it says "a pre-service training approved by the Department" and stops.

The number does not exist in the regulation, only in whatever EEC has approved at the moment you apply. Do not budget from a blog post that asserts five hours for both tiers. THE BRIEF HANDED TO THIS RESEARCH SAID MASSACHUSETTS DISTINGUISHES "FAMILY CHILD CARE" FROM A "LARGE FAMILY" LICENCE AT TEN CHILDREN. THE TEXT SAYS OTHERWISE AND YOU SHOULD NOT SHOP FOR A LICENCE THAT DOES NOT EXIST. 606 CMR 7.02 defines family child care as "Temporary custody and care provided in a private residence during part or all of the day for no more than ten children younger than 14 years old or children younger than 16 years old if such children have special needs." There is one family child care licence. What varies is the licensed capacity written on it, and the qualification tier that unlocks each capacity: six or fewer, seven or eight, nine or ten. Massachusetts has no separate "large family child care home" licence category in 606 CMR 7.00. The "six plus two school age" figure people repeat comes from the ratio table, not from a licence type: 606 CMR 7.10(4)(e) permits seven or eight children with one educator on condition that "All children over capacity of six must be school age", while 606 CMR 7.10(4)(g) requires TWO educators for seven to ten children in the general case.

That is the assistant trap the Massachusetts file is famous for. You can be licensed for nine or ten and be unable to lawfully open the door alone, because the ratio row that permits nine or ten requires a second qualified adult in the home. THE ASSISTANT REGIME IS PART OF YOUR PRE-SERVICE PLANNING, NOT AN AFTERTHOUGHT. 606 CMR 7.09(15)(c) splits assistants in two. A certified assistant is "An educator who meets the qualifications of the licensee" and "may replace the licensee at any time, provided notice is given to parents in advance"; separately, "An educator who meets the qualifications of a family child care educator licensed to serve six or fewer children may substitute for a provider licensed to care for up to ten children for up to 25 hours in a 12 month period." A regular assistant is "An educator whose qualifications are neither equal to nor greater than the licensee's qualifications" and "may be alone on the premises with up to six children for up to 25 hours in a 12 month period, or up to eight hours in a seven day period, provided s/he is currently certified in first aid and CPR."

In programmes licensed for seven or more, "a regular assistant may provide care only under the supervision of a licensee or certified assistant." EEC's policy statement on regular assistants, control number FCCRegularAssistants20120626, tightens the arithmetic against aggregation: "no provider may leave their child care children with an uncertified assistant for more than a total of 8 hours per week or a total of 25 hours per year, no matter how many assistants he/she uses." Twenty-five hours is a per-home budget, not a per-assistant budget. And under Policy Advisory 2024-9, your regular assistant must have completed the full thirteen-course EEC Essentials 2.0 package and hold current first aid and CPR before ever being alone with children. REGISTRATION IS A SEPARATE OBLIGATION FROM TRAINING AND IT HAS ITS OWN LIVE SYSTEM. 606 CMR 7.09(4): "All educators must register annually with the Department of Early Education and Care in accordance with EEC policies and procedures." The instrument is the Professional Qualifications Registry, live today at eec.state.ma.us/PQRegistry/, which describes itself as gathering "important information on the size, composition, education, and experience of our current workforce" and states that "Educators, including assistants, who work with infants, toddlers, preschoolers, or school age children in EEC-licensed settings are required to register."

The EEC Essentials FAQ is blunt about keeping it live: "Do I still need to keep my PQR active? Yes. All Staff working directly with children must register in the PQR and continue to keep their PQR in an 'active' status." Your PQR number is also your enrolment key for the training system. Where this bites in 2026 is that EEC is mid-migration. EEC's new Professional Portal at childcare.mass.gov/educators, live today, says: "The Department of Early Education and Care (EEC) is working on a new way to manage your professional trainings and growth. Use the portal to access the new StrongStart and apply for EEC professional certifications." And then, critically: "PQR isn't available in the portal yet. At this time, you need to continue using PQR for annual registration and other tasks you currently complete there." It also warns about older certificates: "If you applied and were approved for a certification before November 2025, a copy of your certificate will be available in the portal in the future. At this time, continue to check wherever you saved your copy." You will hold accounts in two systems, MyMassGov plus the new portal for training and the old single sign-on for PQR, and nobody will merge them for you.

THE TRAINING SYSTEM ITSELF MOVED TWICE AND EVERY PUBLISHED LINK TO IT IS NOW A REDIRECT. The EEC Essentials FAQ instructs: "Go to the URL: https://strongstart.eoe.mass.gov". Fetched 26 August 2026, strongstart.eoe.mass.gov returns HTTP 301 to childcare.mass.gov/educators, and so does every deep link into the old StrongStart course store, including the item pages for "Potential Provider Training for FCC" and "Potential Educator Meeting" that search engines still surface as the canonical way to book your orientation. The eoe.mass.gov host is the fingerprint of the reorganisation: EEC's professional development estate now sits under the Executive Office of Education. That transfer did not change who issues the licence. 606 CMR 7.00 still names the Department of Early Education and Care as the licensing authority throughout, 606 CMR 7.02 still provides that "Department - When used alone shall mean the Department of Early Education and Care", the regulatory authority line is still M.G.L. c. 15D, and EEC's own portal page is headed "DEPARTMENT OF EARLY EDUCATION AND CARE" and footed "© 2026 Commonwealth of Massachusetts".

The web addresses where you do the work have changed twice in about two years, and the policies that instruct you still cite the addresses from before both moves. THERE IS A THIRD PRE-SERVICE OBLIGATION MOST CHECKLISTS OMIT: THE BACKGROUND RECORD CHECK, AND IT REACHES YOUR HOUSEHOLD. 606 CMR 7.03(1)(c)1 conditions issuance on "evidence of the applicant's compliance with the requirements of 102 CMR 1.05(1)". That cross-reference is itself a piece of archaeology worth knowing about, because 102 CMR is titled "OFFICE OF CHILD CARE SERVICES", an agency the General Court folded into EEC in 2005, and the Secretary of the Commonwealth's copy of 102 CMR 1.00 carries a server timestamp of 9 July 2004. The substance still governs: 102 CMR 1.05(1) provides that "An applicant shall not qualify to receive, retain, or have renewed a license if the background of the applicant, household member, or person who is regularly on the premises is not free from conduct which adversely bears on the provider's ability to care for children." The mechanics are in 606 CMR 14.00, Criminal Offender and Other Background Record Checks, which runs candidate categories, submission frequency, disqualifications, provisional hiring, the review process and a Table of Disqualifying Offenses.

Every adult who lives in your home or is regularly present during care is in scope. Start the checks early; they are the step most often outside your control. THE HEALTH FILE IS ALSO PRE-SERVICE. 606 CMR 7.09(11) requires that "Prior to licensure or employment of any educator the licensee must obtain from a licensed health care practitioner: (a) evidence that the educator has had a physical examination within one year prior to employment; (b) evidence that the educator has been immunized in accordance with the recommendations of the Department of Public Health; (c) a statement of any limitations on the educator in working with children", and 606 CMR 7.03(5)(a)3 lists those health records among the documents you must submit. 606 CMR 7.09(15)(g) extends the reach into your household: "Upon request by the Department the licensee must provide a current statement signed by a physician or other professional acceptable to the Department certifying that any household member or person regularly on the premises of the family child care home is in good physical and mental health." Like the orientation certificate, the physical examination carries a one-year shelf life relative to licensure, so book it in the same late window.

DO NOT CONFUSE THE DEPARTMENT ORIENTATION WITH YOUR OWN PROGRAMME ORIENTATION; THEY ARE DIFFERENT OBLIGATIONS AND ONLY ONE OF THEM EARNS HOURS. 606 CMR 7.09(15)(d), headed "Program Orientation", requires that "The licensee must inform all educators of the location of the children's records and the first aid kit and all procedures pertaining to the operation of the program, including, but not limited to, emergency procedures, variances, first aid procedures, supervision, child guidance, children's individual health plans, including infant sleeping positions, and the curriculum plan." That is a duty you owe to anyone working in your home, including a regular assistant. EEC's Professional Development policy, control number EECLicensingProfDev20120904, then rules it out as credit: professional development hours "will not be awarded for ... Program Orientation or staff training in a program's basic policies and procedures." The same policy also excludes "First Aid and CPR training" from professional development hours, which is the single most common accounting mistake made by newly licensed Massachusetts providers.

WHAT TO DO WITH THE PAPER, BECAUSE MASSACHUSETTS ENFORCES ON DOCUMENTS HELD ON SITE, NOT ON FILINGS. 606 CMR 7.04(5) requires a personnel record for each staff member containing "documentation that the employee has the qualifications required under 606 CMR 7.09 including, but not limited to, health records", "copies of licenses, certifications and registrations held", and "documentation of orientation, training and professional development, as required by 606 CMR 7.09(15)(d) through (f), 7.09(16)(c), 7.09(17)(a), 7.11(1), 7.09(18)(d), and 7.09(19)(b)". Policy Advisory 2024-9 adds: "Printed certificates should be available in staff records located within the program", and the FAQ adds the enforcement date: "Starting July 1, 2025, EEC licensing staff will begin monitoring to determine if the EEC Essentials 2.0 training requirements have been completed." The orientation policy sets the standard of completion for online modules in terms you should take literally: "the educator must view and listen to the entire narrated power point presentation, complete all examination questions, and print and maintain the appropriate training certificate on file for review by EEC."

Print everything. The training system has changed platform twice; your learning history is not a substitute for a certificate you hold. THE ORDER THAT ACTUALLY WORKS, GIVEN ALL OF THE ABOVE. Confirm your dwelling qualifies under 606 CMR 7.03(5)(e), which permits family child care only in a dwelling "that provides complete independent living facilities for one or more persons including permanent provisions for living, sleeping, eating, cooking, and sanitation". Start background record checks for yourself and every adult in the household under 606 CMR 14.00 and 102 CMR 1.05(1). Book the physical examination and immunisation evidence under 606 CMR 7.09(11). Register in the Professional Qualifications Registry at eec.state.ma.us/PQRegistry/ and get your PQR number, because you need it to enrol in training. Create a MyMassGov account and a profile in EEC's Professional Portal at childcare.mass.gov/educators, which is the only live door to the new StrongStart Learning Management System. Complete the full thirteen-course EEC Essentials 2.0 package for Early Childhood, about twelve hours, and print the single package certificate.

Take a blended first aid and CPR course with a hands-on skills demonstration, age-appropriate to the children you intend to enrol, from an instructor certified by one of the seven organisations EEC names. Attend the Department-approved orientation, and attend it INSIDE the twelve months before the licence will issue. If you are applying for seven or more children, add the additional Department-approved pre-service training required by 606 CMR 7.09(15)(b)2 or the five-hour training required by 7.09(15)(b)3, and confirm with the licensor in writing which currently approved course satisfies it, because the rule names no course and the 2012 policy that did name one points at a dead server. Then file, with the lead paint disclosure required by 606 CMR 7.07(15)(a)2, the CPR and first aid certification, and the health records, and pay the application fee. The training window and the background checks are the two things that cannot be compressed at the end. ONE LAST WARNING ABOUT WHO IS ALLOWED TO TELL YOU ANY OF THIS. The regulation itself contains an escape hatch at 606 CMR 7.09(20): "In the event the Commissioner of the Department determines there is a significant workforce shortage of early educators, and such shortages prevent programs from obtaining the appropriate staffing necessary to meet the health and safety needs of children, the Commissioner of the Department shall have the authority to revise and/or rescind any educator qualifications and professional development requirements under 606 CMR 7.04 and 7.09 to address this need."

That power is not hypothetical; it has been exercised. EEC's CPR policy records that "On August 31, 2021, the Board of Early Education and Care approved emergency revisions to its licensing regulations to address the workforce shortages caused by the pandemic. One of these revisions was to remove the annual CPR renewal requirement established by 606 CMR 7.11(1)(a)2 and, instead, to adhere to the expiration date listed on the CPR certificate." Which means that in Massachusetts the qualification and training rules can be changed by the Commissioner without a Register amendment you would notice, and the change reaches you through a policy advisory published on a page that has moved twice. Before you spend a dollar on any course, ask your regional EEC licensor by e-mail to confirm, in writing, which orientation and which pre-service training they will accept for the capacity you are applying for, and keep the reply. That e-mail is worth more than any checklist, including this one.

Ongoing (annual) training

THE DISTINCTION THAT COSTS MASSACHUSETTS PROVIDERS THE MOST MONEY IS THIS ONE: YOUR LICENCE RUNS THREE YEARS, YOUR TRAINING OBLIGATION RUNS EVERY YEAR, AND NOBODY COUNTS THE HOURS FOR YOU UNTIL A LICENSOR IS STANDING IN YOUR LIVING ROOM. Verified 26 August 2026 against 606 CMR 7.00 as amended by Massachusetts Register Issues 1452 and 1459, both effective 1 September 2021, the current text of the chapter, served by the Secretary of the Commonwealth at reg_pub/pdf/600/606007.pdf and confirmed against the codified version. 606 CMR 7.03(5)(b) provides that for family child care "A regular license or approval is valid for three years from the date of issuance unless revoked, suspended, or made probationary." 606 CMR 7.09(15)(f) states the training requirement PER YEAR. Massachusetts never restates the requirement as a per-renewal-cycle total, and that silence is the trap. A full-time family child care educator owes ten hours a year, which is thirty hours across one licensing period, and the regulation gives you no way to satisfy year two by doubling up in year three. If you are shopping for a training bundle that promises to cover you "for your licence period", you are buying against a rule that does not exist here.

HERE IS THE OPERATIVE TEXT, IN FULL, BECAUSE IT IS SHORT AND EVERY WORD IN IT DOES WORK. 606 CMR 7.09(15)(f), Professional Development, provides: "1. Educators in family child care working more than 25 hours per year but less than ten hours per week must complete at least five hours of professional development activities per year. 2. Educators in family child care working more than ten hours per week must complete at least ten hours of professional development per year. 3. At least one third of the required professional development must address diverse learners." Three thresholds sit inside those thirty-seven words. Below twenty-five hours of work in a year, the regulation states no professional development requirement at all. Between twenty-five hours per year and ten hours per week, five hours a year. Above ten hours per week, ten hours a year. The band you fall in is set by how much you actually work, not by your licensed capacity, and it changes if your enrolment changes. A licensee who dropped to part-time in the middle of a licensing period and back to full-time the next year owes five hours for one year and ten for the other, and must be able to show which is which.

THE ONE-THIRD DIVERSE LEARNERS RULE IS THE SINGLE MOST CITED ITEM ON THIS SUBJECT AND ALMOST NOBODY BUDGETS FOR IT. "Diverse Learners" is defined at 606 CMR 7.02 as "Children who have special physical, emotional, behavioral, cognitive or linguistic needs or whose primary learning modality is visual, auditory, tactile or kinesthetic, who may require an adaptation in the environment, interaction or curriculum in order to succeed in their program." If you owe ten hours, at least one third of them, three and one third hours, must address that. If you owe five hours, at least one and two thirds hours must. Nothing in 606 CMR 7.00 and nothing in EEC's professional development policy authorises rounding that fraction down, so the safe practice is four hours out of ten and two hours out of five. EEC repeats the rule in the policy with the definition attached, under the heading "A Note about Diverse Learners", which is a strong signal about what licensors look for. It is not enough to have ten hours of certificates. Ten hours of certificates with nothing on inclusion, adaptation, dual language learners or sensory and behavioural needs is a citation waiting to be written.

AND HERE IS THE TRAP THAT DID NOT EXIST BEFORE 2024 AND THAT MOST MASSACHUSETTS GUIDANCE HAS NOT CAUGHT UP WITH. EEC Essentials 2.0, the thirteen-course federally driven package that runs about twelve hours and that you must complete before licensure, looks on its face like a full year of professional development and then some. EEC's own EEC Essentials 2.0 FAQs, dated April 2024, confirm half of that: "Does the training count towards EEC licensing training hour requirements? Yes, completion of the EEC Essentials 2.0 training package via EEC's LMS will count toward the required yearly professional development training hours the first time it is taken." Read the qualifier. THE FIRST TIME IT IS TAKEN. And then read the very next question and answer in the same document: "Can any of the trainings count towards EEC licensing training requirements in diverse learners? No, none of these trainings count towards EEC licensing training requirements in diverse learners." So the twelve hours that felt like a comfortable surplus contribute exactly zero toward the three and one third hours of diverse-learner content you owe in the same year. A newly licensed full-time family child care educator who does EEC Essentials 2.0 and nothing else is compliant on the raw hour count and non-compliant on the composition, in year one, on the strength of the very training the Commonwealth required her to take.

THE ANNUAL REFRESHER IS A SEPARATE, ADDITIONAL, PERMANENT OBLIGATION. EEC Policy Advisory Field Operations 2024-9, "Policy: EEC Essentials 2.0", with "Effective Date: May 8, 2024", provides: "After completing EEC Essentials 2.0, there will be an annual requirement to complete a 3-hour EEC Essentials refresher course", and again, "In addition, all applicable staff will be required to take the EEC Essentials Refresher package annually." The enforcement date is stated: "Starting July 1, 2025, EEC licensing staff will begin monitoring to ensure that the EEC Essentials 2.0 Training requirements and annual EEC Essentials Refresher training have been completed a year later (and yearly thereafter) and certificates are available in staff records on-site. A program's failure to ensure that each program staff member/assistant working directly with children and counting in the program's staff-child ratio has completed the training package may result in citations of non-compliance." Note who is caught: "All staff that are included in the count for the maintenance of licensing ratios and group size must complete the entire package, regardless of the frequency that they work.

In addition to educators and program administrators, this includes volunteers, interns, and substitutes that are counted in ratio." In family child care that means your certified assistant and your regular assistant, and the FAQ says so directly: "Do FCC Certified Assistants and Regular Assistants need to take the training? Yes." So your annual planning is not ten hours. It is three hours of refresher plus enough additional professional development that the year still totals ten with at least three and one third of them on diverse learners, for you and for every assistant who counts in your ratio. WHAT CANNOT BE COUNTED IS AS IMPORTANT AS WHAT CAN, AND THE EXCLUSION LIST IS EXPLICIT. 606 CMR 7.09(15)(e) provides, in its own words: "All licensees, certified assistants, and any educator who may be alone with children must maintain current certification of training in basic first aid and CPR, in accordance with EEC policy. Training in first aid and CPR may not be counted toward Professional Development hours." That sentence sits inside the regulation, not merely in policy, and it is the most expensive misunderstanding in the Massachusetts file, because first aid and CPR recertification is the one training every provider reliably does and the one that reliably earns zero credit.

EEC's policy statement on Professional Development, control number EECLicensingProfDev20120904 and still published on EEC's Licensing Policies index, extends the list: professional development hours "will not be awarded for: Committee meetings; Staff meetings (except for that portion of the meeting that has previously been identified as training and that meets the documentation requirements of this policy); First Aid and CPR training; Program Orientation or staff training in a program's basic policies and procedures. For successfully completing an identical professional development activity more than once." That last exclusion is the one that catches providers in year two and year three of a licence. Repeating the same online module you took last year earns you nothing. The policy also narrows how a course's hours are computed: "The calculation of professional development hours is limited to hours approved by the accrediting organization or anticipated by the course presenter. This does not include time for waiting, breaks, meals, discussion unrelated to the professional development topic, and other unrelated activities." A six-hour conference day is not six hours.

WHAT DOES COUNT IS DEFINED BY SUBJECT MATTER AND BY WHO TAUGHT IT. The regulation's own definition at 606 CMR 7.02 is broad: "Professional Development - Ongoing education or training designed to increase an educator's skills or knowledge or assist the educator in gaining new competencies in his or her profession or in a field closely related to his or her profession. Professional development may fulfil the annual number of hours required by regulation to maintain a license, registration or credential, and/or may result in college credit or CEUs that lead to career advancement." The policy narrows it: "All professional development activities intended to satisfy the professional development hours required by EEC's regulations must relate to EEC's Core Competencies", and it prints the eight Core Competency Areas: Understanding the Growth and Development of Children and Youth; Guiding and Interacting with Children and Youth; Partnering with Families and Communities; Health, Safety, and Nutrition; Learning Environments and Implementing Curriculum; Observation, assessment, and documentation; Program planning and development; Professionalism and leadership.

Delivery format is generous: "Acceptable professional development can be offered in person at child care programs, lectures, workshops or conferences or by distance-learning through self-guided study or instructor-led communities of practice." THE TRAINER QUALIFICATION RULE IS WHERE CHEAP CERTIFICATES DIE. The same policy provides: "To provide professional development to educators working in EEC licensed programs, trainers/instructors must meet one of the following: Have been approved to present coursework for college credit; Have been approved to offer training that results in CEUs, PDPs, or CECs; Have at least an associate's degree in early childhood education or a related field and at least one year of experience in early education, out of school time, or equivalent; Holding a recognized credential in a specific area of training will be accepted as being qualified within that area of expertise; or Meet EEC's qualifications for lead teacher, site coordinator or have at least three years of experience as a licensed family child care provider." And where no formal credit is awarded, the burden of proving the trainer shifts onto you: if college credits, CEUs, PDPs or CECs are not awarded, your documentation "must include: Qualifications of the instructor (see the following section); Evidence of completion of all required quizzes, tests, self-assessments and assignments". A twelve-dollar unaccredited online certificate with no named instructor and no assessment is a certificate you cannot defend.

Ask the vendor, before paying, which of those five bullets its instructor satisfies, and keep the answer with the certificate. THE CONVERSION TABLE, VERBATIM, BECAUSE PEOPLE GUESS AT IT AND GUESS WRONG. 606 CMR 7.02 defines the unit: "Continuing Education Unit (CEU) - A nationally recognized method for recognizing participation in professional development and training activities. One CEU is granted for each ten hours of instruction. CEUs must be approved by organizations designated by the Department." The policy names the designated organisations: "EEC accepts CEUs awarded by: Accredited colleges or universities; Training organizations with the International Association for Continued Education and Training (IACET) accreditation; Massachusetts Association for the Education of Young Children (MAEYC); National Association for the Education of Young Children (NAEYC); The National Coalition for Education and Cultural Programs (NCECP)." For the two neighbouring currencies: "One PDP equals one hour of professional development. PDPs are usually offered in blocks of 10 hours" — PDPs being Professional Development Points issued by the Department of Elementary and Secondary Education — and "One CEC equals 1.5 hours of professional development; 2 or more CECs correspond hour for professional development hours (2 CECs = 2 hours; 3 CECs = 3 hours, etc.)", CECs being Competency Education Credits issued by Early Intervention at the Department of Public Health.

College credit counts only if "offered by an institution that has been accredited by an accrediting agency or state approval agency recognized by the U.S. Secretary of Education." So half a CEU is five hours, one CEU is your entire annual obligation as a full-time family child care educator, and a training advertised as "1 CEU" from an outfit that is none of the five listed bodies is not one CEU as far as EEC is concerned. THERE IS A BANKING RULE, IT IS NARROW, AND IT IS THE ONLY LAWFUL WAY TO SMOOTH HOURS ACROSS YEARS. The policy provides: "If an educator successfully completes a college course (for credit) that results in more hours than needed for her annual professional development requirement, the additional hours may be credited towards the required professional development hours for the following calendar year ('banked'). Professional development hours for a single course may not be credited toward more than two consecutive year's requirements. At least one third of the course to be banked must address diverse learners." Read every limit in that. Only a COLLEGE COURSE FOR CREDIT can be banked, not a workshop and not an online module.

The surplus rolls forward one year only, and a single course can never cover more than two consecutive years. And the diverse-learner fraction follows the banked course, so a three-credit course with no inclusion content cannot be banked at all. Note also the word the policy uses for the year: CALENDAR year. Nothing in 606 CMR 7.00 or in the policy anchors your professional development year to the anniversary of your licence. If you are tracking your hours from licence date to licence date and your licensor is reading them by calendar year, the two of you will disagree about a compliant year, and the licensor's reading is the one that goes in the record. Keep your log by calendar year and date every certificate. ONE MORE CREDIT EXISTS THAT ALMOST NOBODY CLAIMS. "Trainer's Development Credit. An educator who researches, develops, and presents training that meets the professional development requirements of this policy may be credited for one professional development hour for each hour spent developing and presenting the training up to a maximum to 5 professional development hours per year."

If you present at a local family child care system meeting, a CCR&R workshop or a conference, half of a full-time educator's annual obligation can come from your own preparation time, provided the training you deliver would itself qualify and you document it like any other activity. THERE ARE REGULATORY TRAINING TOPICS OUTSIDE THE HOUR COUNT, AND THEY ARE ENFORCED SEPARATELY. 606 CMR 7.11(1) provides: "All educators must be trained in the program's emergency and evacuation procedures, in standard precautions and in medication administration procedures." On medication specifically, 606 CMR 7.11(1)(b) requires that "Each person who administers prescription or non-prescription medication to a child must be trained to verify and to document that the right child receives the proper dosage of the correct medication designated for that particular child and given at the correct time(s), and by the proper method. Each person who administers medication (other than topical medication) must demonstrate competency in the administration of medication before being authorized by the licensee to administer any medication", that "The licensee must ensure that at least one educator with training in medication administration is present at any and all times when children are in care", and that any person administering medications other than oral or topical medications and epinephrine auto-injectors "must be trained by a licensed health care practitioner and must demonstrate annually to the satisfaction of the trainer, competency in the administration of such medications."

That is an ANNUAL competency demonstration, separate from your hour count, for anyone giving anything beyond the oral, topical and epi-pen categories. EEC's Essentials package includes a Medication Administration module and the FAQ confirms it "replaced EEC's legacy training offering in that area" alongside "Nutrition and Choking; Safe Sleep Practices; Look before You Lock; Drivers Transportation Training". It does not replace the annual practitioner-verified competency demonstration that 7.11(1)(b)2 requires for the harder routes. NUTRITION AND CHOKING IS A STANDING REQUIREMENT WITH NO STANDING COURSE. 606 CMR 7.12(2) requires that "All educators must receive basic training in the following: (a) in USDA recognized nutrition requirements for the healthy growth and development of children; and (b) in food choking hazards." EEC's family child care policy on the point, control number FCCChokingHazardTraining20121128, concedes the gap in its own words: "While CPR training does touch upon choking, it does not deal specifically with food hazards, and therefore does not meet the regulatory requirement of 7.12(b) by itself.

There is currently no formalized training solely on this topic, so Family Child Care educators may meet the requirements of this regulation in different ways", and it then allows food-programme training, documented review of USDA Team Nutrition materials, a free online course, or an attended nutrition training. It closes with "NOTE: This training can be counted for 1 hour of professional development", which makes it one of the few obligations that is simultaneously a regulatory topic and an hour you can bank against the ten. The USDA and NFSMI links printed in that policy are more than a decade old; use current USDA Team Nutrition child care materials and document the date you reviewed them. SAFE SLEEP CARRIES ITS OWN TRAINING TRIGGER AND ITS OWN PUNISHMENT. EEC's Safe Sleep for Infants policy, effective 1 October 2023, states: "All staff working with infants under 12 months of age must be trained on safe sleep practices prior to caring for infants. In accordance with the EEC Essentials Policy, Infant Safe Sleep Practices and Shaken Baby Syndrome trainings must be completed prior to working with infants and toddlers in an unsupervised capacity.

An educator trained in safe sleep practices must be present at all times where there is a sleeping infant." And the consequence of a first citation is retraining on a clock: "Within 10 business days of the citation, all educators and staff involved in the care of infants must complete training on Safe Sleep, including SIDS, through the StrongStart Professional Development System. Providers/Program Administrators must request training access from their Licensor via email", followed by an in-person unannounced Safe Sleep Follow-Up Monitoring Visit. So in Massachusetts a safe-sleep finding does not just generate paperwork; it generates a compulsory training assignment with a ten-business-day deadline and a return visit. THE FIRST AID AND CPR CLIFF IS THE HARSHEST ENFORCEMENT PROVISION IN THE WHOLE TRAINING FILE, AND IT IS NOT IN THE REGULATION. EEC's policy "CPR and First Aid Training and Certification", effective 1 October 2020 and updated 17 December 2021, records that the annual CPR renewal that 606 CMR 7.11(1)(a)2 once required was removed by the emergency revisions the Board approved on 31 August 2021, so the rule today is simply "CPR training must be renewed prior to the expiration date listed on the CPR certificate."

Then comes the sanction: "If EEC finds that there is no individual on premises at a family child care home or child care center with current (not expired) certification in age-appropriate CPR and first aid, the program must temporarily cease care at the end of the day when families have left the program. The program may not reopen until evidence of current and valid age-appropriate CPR and first aid certifications can be made available to the EEC licensor." An expired card closes your business the same day. And remember 606 CMR 7.09(15)(e): the hours you spend renewing it earn you nothing toward the ten. Diarise the expiry ninety days out. WHERE THE HOURS ARE ACTUALLY CHECKED, AND WHY RENEWAL IS NOT THE ANSWER YOU EXPECT. Renewal under 606 CMR 7.03(3) requires you to "file a written application for renewal on forms provided by the Department and pay any required application fee not less than 30 days before the date of expiration of the current license", to "participate in a license renewal meeting approved by the Department", and to "review all of the written plans and documents required by 606 CMR 7.00 and submit copies of: 1. any of the required written plans or documents that have been revised during the licensing period; 2. current inspection certificates required by 606 CMR 7.00; and 3. any document required by 606 CMR 7.00 if requested by the Department."

Read that list again. It does not require you to file three years of training certificates with the renewal application. The certificates live in the record you keep. 606 CMR 7.04(5) requires a personnel record for each staff member including "documentation of orientation, training and professional development, as required by 606 CMR 7.09(15)(d) through (f)", and EEC's professional development policy states the standard plainly: "Licensees must maintain and make available documentation to EEC upon request that their staff have met the requirements for professional development." Policy Advisory 2024-9 says the same of the Essentials certificates: "Printed certificates should be available in staff records located within the program." So the audit happens at monitoring visits, unannounced, at any point in the three years. The provider who plans to "catch up before renewal" is planning against a system that does not wait for renewal, and a licensor visiting in month fourteen can cite a deficient year one that renewal would never have reached. DOCUMENT EACH ACTIVITY TO THE POLICY'S SIX-ITEM SPECIFICATION OR IT DOES NOT EXIST.

The professional development policy requires that "Each educator must maintain documentation of successful completion of the professional development activity that includes: Name of the professional development activity; Topic(s) covered and the core competency area addressed; Number of contact hours completed; Date the course or training was completed; Instructional method (lecture, classroom discussion, distance learning, self-guided study or community of practice, etc.); Name of the sponsoring organization (if applicable)." Most vendor certificates give you the name, the date and the hours and stop. The two fields they omit are the two that prove compliance: the core competency area addressed, which is how you demonstrate the diverse-learner third, and the instructional method. Write them onto your own log at the time. The policy also states that "Professional development should be recorded in the educator's profile in the EEC Professional Qualifications Registry", but note that the Essentials package is handled differently: "This training does not need to be listed in the Professional Qualification Registry (PQR).

The training will be captured on each person's SSPDS transcript (available in their learning history)." THE SYSTEMS THAT HOLD YOUR RECORD HAVE MOVED TWICE, WHICH IS AN ARGUMENT FOR PAPER. The Essentials FAQ tells you to "Go to the URL: https://strongstart.eoe.mass.gov". Fetched 26 August 2026, that host returns HTTP 301 to childcare.mass.gov/educators, and so does every deep link into the old StrongStart course store. EEC's new Professional Portal, live at childcare.mass.gov/educators, describes itself thus: "The Department of Early Education and Care (EEC) is working on a new way to manage your professional trainings and growth. Use the portal to access the new StrongStart and apply for EEC professional certifications", offers "The new StrongStart Learning Management System (LMS) — Complete and track your professional development courses or trainings", and warns that "PQR isn't available in the portal yet. At this time, you need to continue using PQR for annual registration and other tasks you currently complete there", and that for approvals "before November 2025", "continue to check wherever you saved your copy".

Meanwhile 606 CMR 7.09(4) still requires that "All educators must register annually with the Department of Early Education and Care in accordance with EEC policies and procedures", the Professional Qualifications Registry at eec.state.ma.us/PQRegistry/ is still the live instrument for that annual registration, and the Essentials FAQ still insists: "All Staff working directly with children must register in the PQR and continue to keep their PQR in an 'active' status." Two annual obligations, two systems, one of which is being replaced under you. Print every certificate the day you earn it and keep a dated paper log by calendar year. Your learning history in a system that has already been migrated once is not evidence you control. A NOTE ON WHAT MASSACHUSETTS DOES NOT REQUIRE, BECAUSE THE ABSENCE IS ALSO WORTH MONEY. Search 606 CMR 7.00 for an annual mandated-reporter course, an annual SIDS course, an annual shaken-baby course, or a mandated topic list of the kind Texas, Florida or Illinois publish, and you will not find one. The regulation imposes the duties without imposing recurring courses: 606 CMR 7.11(4)(d) makes "Every educator ... a mandated reporter under M.G.L. c. 119, s. 51A", 606 CMR 7.11(13)(e) requires programmes serving infants to "place infants on their backs for sleeping, unless the child's health care professional orders otherwise in writing", and that is the extent of it in the code.

The recurring topic obligation arrives entirely through the policy layer, through EEC Essentials 2.0 and its annual three-hour Refresher, and the FAQ confirms the substitution in three words when asked whether Essentials replaces the mandatory 51A training: "Yes." Which means that any compliance product sold to you on the basis of a Massachusetts "mandated annual topic list" pulled from the Code of Massachusetts Regulations is selling you a list that is not there, and any adviser who tells you Massachusetts has no SIDS or shaken-baby training requirement has read only the code and missed the policy advisory that actually binds you. FINALLY, THE HOUR COUNT ITSELF IS REVOCABLE BY ONE OFFICIAL WITHOUT A REGISTER AMENDMENT. 606 CMR 7.09(20) provides: "In the event the Commissioner of the Department determines there is a significant workforce shortage of early educators, and such shortages prevent programs from obtaining the appropriate staffing necessary to meet the health and safety needs of children, the Commissioner of the Department shall have the authority to revise and/or rescind any educator qualifications and professional development requirements under 606 CMR 7.04 and 7.09 to address this need."

That clause entered the chapter in the September 2021 amendments and it has already been used once in the adjacent area, when the Board's emergency revisions of 31 August 2021 struck the annual CPR renewal out of 606 CMR 7.11(1)(a)2. So the hour count you owe in a given year is the hour count in 606 CMR 7.09(15)(f) as of that year, unless the Commissioner has revised it, and the revision will reach you as a policy advisory on a web estate that has changed address twice since 2024. Once a year, before you buy training, open EEC's Licensing Policies for Family Child Care Providers index and its Professional Development Policy and read what is actually listed there, rather than trusting a bundle sold as covering "Massachusetts annual requirements". The requirements are ten hours a year, at least a third on diverse learners, plus a three-hour Essentials Refresher, plus first aid and CPR that never counts, thirty hours of it across a three-year licence, checked without warning.

Background checks

In Massachusetts the background check is not a step in your family child care application. It is the gate, and the most common reason a file that looks complete sits unissued for months. The licensing authority is the Department of Early Education and Care (EEC), which mass.gov today places under the Executive Office of Education but which still issues the license itself: M.G.L. c. 15D, § 7(a) provides that "The department shall issue and may renew a license to any person ... who meets applicable standards and requirements to establish and maintain ... a family child care home." No transfer of that issuing authority has occurred; EEC sitting inside an executive office describes reporting lines, not the signature on your license. The operative regulation is 606 CMR 14.00, Criminal Offender and Other Background Record Checks. As of 26 August 2026 the EEC index at mass.gov/lists/eec-laws-and-regulations serves exactly one file for it, "EEC BRC Regulations (606 CMR 14)," a 37-page document whose credits line records the last substantive amendment as "1433 Mass. Reg. 81, amended eff. Dec. 25, 2020" and whose currency line reads "current through Register No. 1467, dated April 15, 2022." EEC's proposed-amendments page states on the same date that the "Department of Early Education & Care does not have any proposed amendments to its regulations at this time."

The rules that will be applied to you were fixed in December 2020, and nothing pending will change them before your license issues. Start from the statutory command, because it is broader than most applicants expect and it is where the money is lost. M.G.L. c. 15D, § 7(a)(i) requires that, prior to issuing any license, EEC shall "(1) obtain from the sex offender registry board all available sex offender registry information ... associated with the address of the program, center, facility or home; and (2) conduct fingerprint-based checks of the state and national criminal history databases, as authorized by Public Law 92-544." Note the first clause. The sex offender registry search runs against the ADDRESS of your home, not only against the names you list. If a registered sex offender lives at or near the address you propose to license, EEC finds that without anyone naming him, and 606 CMR 14.11(10) says what follows: "If EEC determines through an address match with SORB that an individual who is registered or required to be registered as a sex offender lives or works on or nearby the premises of a Program, EEC will immediately investigate and take appropriate action related to the Program."

Applicants who chose a unit before running that address search have lost the lease, the deposit and the renovation money. The same statute states who must be fingerprinted, and it reaches into your household. M.G.L. c. 15D, § 7(a)(i) continues: "The fingerprint-based checks shall be conducted on any current holder of or applicant for a family child care assistant certificate or any current holder of or applicant seeking a license for: family child care ... The fingerprint-based checks shall also be required for any household member, age 15 or older, or any person, age 15 or older, regularly on the premises of applicants for family child care licensure, as well as in-home non-relative caregivers." That is the statute, not a policy, and it is why a family child care application is never about one adult. 606 CMR 14.04 then defines the class with precision, and the definition of Family Child Care Candidate is the sentence to memorise: "The family child care licensee; family child care assistants; and all household members and persons regularly on the premises of the family child care home 15 years of age or older, regardless of whether the individuals are present during child care hours."

The closing clause does the damage. Your adult son who sleeps through your entire program day is a candidate; so is your mother-in-law in the finished basement, and your stepdaughter on her fifteenth birthday. None of them has to be near a child, or awake, or home. The threshold for "household member" is set in the licensing regulation, not the BRC regulation: 606 CMR 7.02 defines "Household Member" as "Any person other than the educator who resides in the family child care home for 30 consecutive days or more." Thirty consecutive days is the whole test, and 606 CMR 14.05(2)(b) imports it, requiring checks on "Household members, as defined by EEC licensing regulations at 606 CMR 7.02 ... 15 years of age or older, regardless of whether such individuals are present while child care children are present; and persons regularly on the premises (including volunteers and other regular visitors) 15 years of age or older." A nephew who moves in for a summer internship crosses thirty days at the end of the first month and becomes a person EEC must clear before your license issues or renews. "Regularly on the premises" is defined only in 606 CMR 14.04, and it is defined by exclusion: "Individuals who are present at a family child care home on a recurring basis, but do not reside at the home and are not employed by the program."

Recurring presence is the entire trigger: no hour count, no schedule, no minimum. EEC's applicant guidance at mass.gov/info-details/1-check-if-you-meet-fcc-licensing-requirements requires a BRC of anyone who "Lives in your home. It doesn't matter if they help with child care or are present during child care hours," anyone who "Frequently and predictably visits your home. This can include a family member, house cleaner, or friend," and anyone who "Helps run your program. It doesn't matter if they're paid, unpaid, or occasionally helping." The cleaner who comes every other Tuesday is a candidate; so is the boyfriend who comes to dinner every Thursday. Applicants routinely omit these people because they are not staff, and the omission does not merely delay the file: under 606 CMR 14.10(1)(e) knowingly making "a materially false statement in connection with a BRC" is itself a mandatory disqualification, and 606 CMR 14.04 defines that term to include information that "could have caused EEC to perform an invalid BRC, or lead to the omission of relevant BRC information." "Background check" in Massachusetts is five checks wearing one name. 606 CMR 14.05(2) closes the family child care paragraph: "The above candidates will be required to complete a CORI, DCF, SORI, NSOR, fingerprint-based check and all out of state checks mandated by CCDBG."

EEC at mass.gov/eec-background-record-checks names the same five layers and states the reach of the out-of-state layer: NSOR or "out of state records for any known criminal history, child welfare, and sex offender information where applicants have lived in the past five years." The CORI layer is not the sanitised employer CORI you may have seen before; 606 CMR 14.04 records that "EEC is legally authorized to receive information pursuant to M.G.L. c. 6, §§ 172 and 172F, including information in addition to CORI," and EEC's step 4 applicant page specifies that Massachusetts CORI here "Includes juvenile records, sealed records, non-delinquent findings, delinquent findings, convictions, and non-convictions." Sealed does not mean invisible. The DCF layer is the one applicants never see coming. 606 CMR 14.04 defines the DCF Check as a check of "its Central Registry and Registry of Alleged Perpetrators to determine if a candidate has been identified as the person responsible for abuse or neglect of a child in a supported M.G.L. c. 119, § 51B Report or is the alleged perpetrator of a pending investigation ... under M.G.L. c. 119, § 51A." A 51A filed years ago and supported at the 51B stage is on your record even though no court ever heard it and no conviction exists. A currently PENDING 51A stops everything: 606 CMR 14.11(8) provides that a candidate with "an outstanding warrant for any criminal offense or a pending DCF 51B investigation or out of state equivalent ... is ineligible for any position in an EEC Program" unless the warrant is removed, the investigation closes not supported, or EEC approves in writing.

And if the support lands on someone other than you, 606 CMR 14.11(9)(a) is unforgiving: "If the support or equivalent determination is against a household member or a person regularly on the premises of a family child care home, then the family child care licensee must stop caring for children, unless there is a written agreement with EEC for the program to continue operating." Your business closes on a finding about someone who does not work for you. The process runs through the BRC Navigator Program Portal in a fixed order. 606 CMR 14.08(1) states that "A signed consent form initiates the BRC process. Upon receipt of a BRC consent form, EEC will determine whether there is a final suitability determination on file for the candidate within the prior three years." 606 CMR 14.07(2) puts the paperwork burden on you, not on the household member: "Family child care licensees must submit EEC BRC consent forms for all family child care candidates (including household members and persons regularly on the premises 15 years of age or older)." Fingerprinting comes first, not last; EEC's FAQ states that "Fingerprinting is the first part of the process via the Navigator BRC Program Portal ...

After a candidate completes a fingerprinting scan, the other checks will be triggered." Nothing else moves until every household member has been printed. Appointments are made through IdentoGO and, in EEC's words, "walk-in service is not available"; you cannot book at all without the fingerprint notification letter, which carries the ID number the booking system demands. EEC's warning is set in bold on the state's own site: "If your name does not exactly match what you provide as an identification document, then you may be turned away from your appointment." A hyphenated married name entered one way in the portal and another way on a licence turns a household member away at the counter, and the queue restarts. The federal clock is 45 days and it does not start when you apply. EEC's policy statement of 30 August 2018, "45 Day Turnaround Time for Background Record Check Process," implements 45 CFR 98.43(e) and states that "the timeline begins on the date when the candidate is fingerprinted for EEC ... This 45 day turnaround policy excludes the time necessitated for the review of any relevant findings." 606 CMR 14.08(3) states the same rule as regulation, "within a maximum of 45 days from the date the candidate is fingerprinted by EEC approved means, excluding any time required for the review process."

Read the exclusion. If anything at all appears on any of your five checks, the 45 days stops counting, and an applicant who planned a September opening on the strength of "45 days" with a twenty-year-old dismissed charge on a CORI has mis-planned by a season. Family child care is the program type with the least procedural mercy, and this is the trap that separates it from centre-based care. In a group and school age programme a new hire can begin work provisionally, under supervision, while the checks finish. You cannot. 606 CMR 14.13(2)(e) is explicit: "Licensees, family child care candidates, relative caregivers, in-home non-relative caregivers, transportation personnel, temporary agency staff, and contracted/service providers may not be placed in provisional status." EEC's policy of 22 August 2023, "EEC Background Record Check Process by Program Type," repeats it: "FCC candidates cannot work in a provisional status; instead, they must complete the entire BRC process and obtain a suitable finding before they can receive a license or approval." 606 CMR 14.13(4)(a) states it as regulation: "Family child care licensees may not obtain or renew a license until the licensee and any household members and those regularly on the premises have a final suitability determination of 'suitable.'" There is no partial opening and no conditional day one.

Your slowest household member sets your opening date. Assistants are checked before they are approved, not after they start. 606 CMR 14.05(2)(c) covers "All current and prospective family child care assistants and volunteers, regardless of whether such individuals are present in an unsupervised capacity," and 606 CMR 14.09(2)(c) requires "a BRC ... complete with a final suitability determination issued ... before EEC will issue a certificate or approval." Volunteers in a family child care home are a special case. EEC policy BRC-26-01, "BRC Requirements for the Roles of Intern, Volunteer, and Affiliated Person for All Program Types," released 4 March 2026 and effective 1 April 2026, states that "In family child care programs, all volunteers are required to complete EEC's BRC process," while in every other programme type a volunteer needs a check only if unsupervised or counted in ratio; the 2023 process policy adds that "Volunteers in FCC homes must be run under the role of a person regularly on the premises." BRC-26-01 also states interns and affiliated persons "must complete a full BRC through the program, regardless of whether such individuals work in a supervised or unsupervised capacity" — since 1 April 2026 supervision is no longer an escape for an intern.

If you use a family child care system, the system's home visitor must be cleared: the 2023 policy's table lists "FCC System Staff — Always assumed to be regularly on the premises and unsupervised — Yes." The disqualification structure has three tiers and only one is survivable without work. Mandatory disqualification is defined at 606 CMR 14.10(1): a child care candidate is mandatorily disqualified if they "Are registered, or required to be registered, in any state or national sex offender registry, repository or database"; if they have "a felony conviction after a state or national criminal check" for first or second degree murder, "Crimes involving child abuse or neglect," "Crimes against children, including child pornography," spousal abuse, "Crimes involving rape or sexual assault," kidnapping, arson, or "Physical assault or battery"; if they have "a conviction as an adult ... for a violent misdemeanor committed against a child"; if they "Refuse to consent to an EEC BRC"; or if they "Knowingly make a materially false statement in connection with a BRC." Under 606 CMR 14.10(2) the registry and conviction categories "are for life as long as the disqualification appears on a record," while refusal to consent and false statement "last for up to three years subject to EEC's discretion."

That felony assault and battery line surprises adults with a decades-old bar fight on their record; it is a mandatory bar for life and, per 606 CMR 14.12(1), "A candidate with a mandatory disqualification may not have their disqualification reviewed, unless they successfully dispute the accuracy or completeness of the record." Presumptive disqualification is the tier where a case is winnable but expensive. 606 CMR 14.10(5) makes a candidate presumptively disqualified where the BRC discloses "Any pending charges, adjudications as a juvenile delinquent, Youthful Offender, non-conviction or not delinquent findings for an adult or juvenile, including sealed offenses and the equivalent, mandatory disqualification as defined in 606 CMR 14.10(1)"; "A supported DCF finding or out of state equivalent determination for sexual abuse"; or "A conviction for a felony drug offense within the three years prior to the date of the EEC BRC." Discretionary disqualification, at 606 CMR 14.10(6), captures non-convictions on the presumptive table, anything on the discretionary table, and, critically, where candidates "have been found to be the person responsible for the abuse or neglect of a child ... as appearing on any check of any state or national child welfare or child abuse and neglect registry or database." 606 CMR 14.18 tells you the tables live outside the regulation, "available as an EEC policy on the EEC website found on www.mass.gov," and the three tables EEC currently publishes are each labelled effective 10/1/18. There is a catch-all at 606 CMR 14.10(7): "Any criminal or child welfare offenses that are not specifically listed will be categorized and may warrant review as determined by EEC's General Counsel."

Nothing falls through. If you land in the presumptive tier, budget for a psychiatric evaluation and budget early. 606 CMR 14.12(2)(b)1 requires "A written assessment by a qualified mental health professional who is not the candidate's treating mental health professional or direct employer," concluding "whether the candidate poses an unacceptable risk of harm to the persons served." 606 CMR 14.04 defines Qualified Mental Health Professional narrowly — a psychiatrist under M.G.L. c. 112, § 2, a psychologist under §§ 118-121, a psychiatric nurse under §§ 74 and 80E, or an LICSW under §§ 130-132 — and adds two conditions that shrink the pool to a handful of practitioners: "at least 1,000 hours of experience over a minimum of two years involving assessment, treatment, and consultation concerning individuals with behavior that presents a risk of harm to others," and "Such individual may not have personally provided treatment to the candidate." Your own therapist is barred by rule from writing the letter that saves your licence. The only alternative is at 606 CMR 14.12(2)(b)2, "a letter from the candidate's criminal justice official, including a probation or parole officer that the candidate does not pose a risk of harm"; 606 CMR 14.04 limits that official to "The candidate's probation officer, parole officer or correctional facility superintendent (or designee)."

If you were never supervised, only the paid evaluation remains, and 606 CMR 14.12(2)(b)3 warns that failure to supply it in time "may result in the candidate being issued a 'not suitable' final suitability determination." The standard of proof in the review is high. 606 CMR 14.12(2)(e) provides: "Standard of Review: EEC shall require from the candidate clear and convincing evidence demonstrating the candidate's suitability for licensure, employment or affiliation in light of the concern for children's safety." The documents you may be asked for at 606 CMR 14.12(2)(c) are police reports, docket sheets, a candidate statement, child welfare documentation, reference letters, probation or parole documentation, imprisonment papers and evidence of rehabilitation; certified docket sheets for a 1990s case take weeks, so start on the day EEC's letter arrives. There is no lookback window that saves you: EEC's published answer to whether the age of an offence matters is "No, all offenses and supports are taken into consideration, regardless of how much time has passed since the offense or support.

This includes juvenile and sealed records." Renewal cadence is where the regulation and the statute part company, and you should follow the statute. There is no three-year interval anywhere in 606 CMR 14.09, titled "Submission and Frequency of Background Record Checks," which addresses only the exceptions that force an EARLY re-run. The three-year rule is statutory. M.G.L. c. 15D, § 8(d) provides that a person with unsupervised access to children in a licensed programme "and household members, age 15 or older, or persons regularly on the premises, age 15 or older, of family child care and large family child care homes shall be subject to a background record check not less than every 3 years," and that a person found suitable "shall not be subject to more than 1 fingerprint-based check every 3 years to maintain employment with the same employer." EEC's published guidance confirms the operational rule: "Both BRCs and fingerprints need to be renewed every 3 years," and, in the sentence applicants most often miss, "The BRC renewal cycle is independent of a license renewal cycle." Your family child care licence runs three years under 606 CMR 7.03(5)(b) — "A regular license or approval is valid for three years from the date of issuance" — but the two clocks drift, because the BRC clock starts at fingerprinting and the licence clock at issuance.

Watch the "fingerprint renewal" date in the Navigator portal, which EEC describes as "the date when the fingerprint expires." Seven circumstances force a re-run before the three years are up, and 606 CMR 14.09(3) lists them: candidates "who have moved outside of Massachusetts since the last EEC BRC was completed and who have had a break in employment or affiliation of 30 days or longer"; new charges, a child welfare investigation, or sex offender registration "in Massachusetts or any other state or territory"; candidates "who have a break of more than 180 days from being affiliated with an EEC Program"; discovery of "false, misleading or incomplete information on file"; candidates "who may be involved in any investigation"; resolution of a pending charge or child welfare matter; and candidates "who are changing their role or program type." That last one has a family child care example in EEC's suitability transfer policy BRC-2025-02, released and effective 15 October 2025: asked what a daughter who lives in the home and also wants to work as an assistant should do, EEC answers "Your daughter will need to apply for two Background Record Checks: one as an FCC Household Member and one as an FCC Assistant.

EEC recommends that she apply as an FCC Assistant first ... because the Suitability Determination is more likely to transfer from FCC Assistant to FCC Household Member than vice-versa." Two BRCs for one person under one roof, and the order decides whether you pay for one set of prints or two. That policy also fixes what a break in employment is not: "EEC does not consider a candidate taking leave to be a 'break in employment.'" Consent is annual even though the check is triennial, and this is where quiet licences fall out of compliance. 606 CMR 14.07(7) provides that each candidate "must recertify their consent for EEC on a yearly basis ... Failure to complete the consent form as required is independent grounds for finding a candidate 'not suitable'." 606 CMR 14.07(8) applies it to your household: "Family child care licensees must ensure that all family child care candidates (including household members and persons regularly on premises 15 years of age or older and family child care assistants) sign EEC's BRC consent form each year that they are present in the family child care program." A not suitable household member, under 606 CMR 14.13(4)(c), "may prevent the family child care licensee from obtaining, renewing or retaining their license."

That is a licence lost over a form. You also carry a continuing duty to report changes, and the licensing regulation gives you five days. 606 CMR 14.09(2)(b) requires that "Family child care licensees must disclose to EEC any changes to the composition to the family child care home, including the addition or removal of household members, or those regularly on the premises ... to ensure that a background record check is timely completed." 606 CMR 7.04(15)(d)2 sets the deadline: "In family child care, the licensee must notify the Department in writing within five days of the initiation of the legal proceedings ... which are brought against any educator, household member of the licensee or person regularly on the premises of the family child care home: a. any criminal or delinquency complaint listed in the Department's Background Record Check regulations; b. any civil action in which mistreatment or neglect of a child is alleged; and c. any petition alleging that a child ... is in need of care and protection." Five days from initiation, in writing, about someone who is not you. Separately, 606 CMR 7.11(4)(f) requires that "The licensee must notify the Department immediately upon learning that a report has been filed naming an educator or person regularly on the child care premises (including household members in family child care) an alleged perpetrator of abuse or neglect of any child."

Not the finding — the filing. And 606 CMR 7.08(9)(b) requires that you notify parents "of any changes in the regular composition of the household" and "of anyone regularly on the premises." Three notification duties, three audiences, one household event. When findings appear, EEC's letters carry short deadlines. EEC's published BRC results guidance states that a candidate with a mandatory disqualifying conviction "will be mailed a 'Mandatory Disqualification' letter that requires action within 7 calendar days," and that if confirmed the program must "remove the candidate from the program within 14 calendar days." 606 CMR 14.11(3) adds that "If a candidate with any disqualification fails to complete EEC's BRC Process within 45 days, EEC may issue a final suitability determination of 'not suitable'." Seven days from a mailed letter is how good applicants lose the file for reasons unrelated to the underlying record. What EEC owes you is set out at 606 CMR 14.11(4): before an adverse decision or as part of the licensing appeals process EEC will inform the candidate that they have "a disqualifying background," give them "a copy of their criminal record," and state "the candidate's right to dispute the accuracy of the BRC findings" and the process for doing so, with a copy of the CORI Policy.

Disputing accuracy is a separate route: EEC's guidance notes that a candidate disputes accuracy "with the relevant reporting agency (e.g., the Sex Offender Registry Board)," not with EEC. Appeals split by role, and family child care licensees get the better forum. 606 CMR 14.14(2) provides that "Licensees who have been found 'not suitable' after completing EEC's review process may file for an adjudicatory hearing at the Division of Administrative Law Appeals (DALA) within 21 days of receipt of the 'not suitable' final suitability determination," under 801 CMR 1.01 Formal Rules. Assistants get an internal forum: 606 CMR 14.14(4) sends "Certified and regular family child care assistants who have been found 'not suitable'" to "an adjudicatory hearing at EEC within 21 days" under 801 CMR 1.02 informal rules. The provision that most surprises households is 606 CMR 14.14(3): "A 'not suitable' determination for a family child care licensee due to the BRC of a household member or person regularly on the premises will entitle the family child care licensee to file an appeal ... The right to appeal is held by the licensee, not the family child care household member or person regularly on the premises."

Your housemate cannot appeal his own disqualification through this route; you appeal, in your own name, about his record. Mandatory disqualifications have no appeal at all: 606 CMR 14.14(1) provides that such candidates "do not have the right to undergo an appeals process with EEC. EEC's 'not suitable' determination is final and results in a lifetime ban under CCDBG, unless the candidate's disqualification is expunged, pardoned or otherwise permanently removed from their record." Reapplication windows are long. 606 CMR 14.14(7) lets candidates refused "for failing to respond or providing false information or related to a pending offense ... reapply at any time, but must repay all associated fees," with a three-year bar for repeat offenders. 606 CMR 14.14(8) is harsher: "Candidates whose 'not suitable' results from a comprehensive BRC review of all adverse findings may not reapply for a period of five years." Two traps in EEC's own web pages. The first: the "EEC BRC Requirements: Applicability, Frequency" page reads "For family child care, residential programs, and placement agencies: Only individuals present in an EEC-licensed program with the potential for unsupervised access to children (including household members and persons regularly on the premises in family child care homes) must complete a Background Record Check."

Read literally, that suggests a household member with no access to children escapes. The regulation says the opposite: 606 CMR 14.05(2)(b) requires household members 15 and over "regardless of whether such individuals are present while child care children are present." When an agency page and 606 CMR 14.00 disagree, the regulation is the law and your licensor applies the regulation. The second: the fingerprinting FAQ is headed "If I need to renew my program license with EEC every 2 years must I get fingerprinted every 2 years?" — but 606 CMR 7.03(5)(b) gives a regular family child care licence three years, not two. Do not calendar your renewals off a question heading. Cost and mechanics. There is no application fee for a family child care licence; EEC's applicant guide states that "There is no cost to apply for a license" and that "It can take 2-6 months to complete licensing steps." The fingerprinting is billed to the individual at the IdentoGO appointment, and the charge falls on every adult household member and every person regularly on the premises, not only on you — a four-adult household pays four times. 606 CMR 14.15(1) makes the licensee "responsible for ensuring all candidates submit consent and renew their consents annually," and 606 CMR 14.16 warns that "EEC shall periodically review BRC documentation maintained by Programs."

One last structural point: 606 CMR 14.02 provides that "Nothing in 606 CMR 14.00 shall be construed to create a private right of action," and 606 CMR 14.11(13) lets EEC, where results "may pose a risk of harm to children in the program," "require immediate removal of the candidate or require that the candidate cease caring pending a final suitability determination or sooner within the discretion of EEC." The Department can stop your programme mid-week on a suspicion, and the regulation gives you no cause of action for it. Plan the household, the consents and the fingerprint appointments, and do not sign a lease before you have run the address.

The application, step by step

Work through these in order — the prep packet turns them into a checklist you can tick off:

  1. START BY FIXING WHO LICENSES YOU AND UNDER WHICH TEXT. In Massachusetts family child care is licensed by the Department of Early Education and Care (EEC) under M.G.L. c. 15D, and the operative standard is 606 CMR 7.00: Standards for the Licensure or Approval of Family Child Care; Small Group and School Age and Large Group and School Age Child Care Programs, whose regulatory authority line reads simply "606 CMR 7.00: M.G.L. c. 15D." M.G.L. c. 15D, s. 6(a) makes the licence mandatory: "No person shall operate a school-aged child care program, a child care center, family child care home, large family child care home, placement agency, group care facility, or temporary shelter facility unless that person is licensed by the department." EEC now sits inside the Executive Office of Education for administrative purposes and its licensing pages are co-branded by both organisations, but the licence is still issued by EEC and the regulation has not been renumbered or reassigned; do not go looking for a new chapter. Two further texts bind you and applicants routinely miss both. The first is 102 CMR 1.00, "Enforcement standards and definitions for licensure or approval", which EEC still lists as a live licensing regulation even though it is written in the name of the abolished Office of Child Care Services, still says "family day care", and carries an effective date of May 1, 1997 at 102 CMR 1.04(1); 606 CMR 7.03(1)(c)1 cross-refers to it by requiring "evidence of the applicant's compliance with the requirements of 102 CMR 1.05(1)", which is the disqualifying-background provision. The second is 606 CMR 14.00, EEC's Criminal Offender and Other Background Record Checks regulation. Verified on 26 August 2026: EEC's own notice page states that the Department "does not have any proposed amendments to its regulations at this time", so there is no pending rewrite of 606 CMR 7.00 to wait for and no draft text that changes what follows. The trap at this first step is reading a secondary guide that describes a Massachusetts "registration" or "certification" tier below the licence: there is none. Care of even one unrelated child on a regular basis in your residence is licensable family child care, and operating without the licence is what s. 6(a) forbids outright.
  2. DECIDE YOUR CAPACITY TIER BEFORE YOU TOUCH THE APPLICATION, BECAUSE IT SETS YOUR QUALIFICATIONS. Massachusetts has three family child care tiers and the tier you choose determines the experience and training you must already hold on the day you apply. Under 606 CMR 7.09(15)(b)1, an applicant for a licence to care for six or fewer children needs at least one of: one year of experience as a parent; one year of full-time experience, or the equivalent, caring for children younger than 12; nine months of full-time experience with children younger than 14 plus 15 hours of EEC-approved training not counting the EEC educator orientation; six months of full-time experience with children younger than 12 plus 30 hours of approved training; or qualification as an EEC teacher or site coordinator. Under 606 CMR 7.09(15)(b)2, a licence for seven or eight children, "at least two of whom must be school age", additionally requires a Department-approved pre-service training completed within one year prior to application plus either two years of experience as a family child care licensee or certified assistant, or one year of such experience plus one more year with unrelated children in a group setting or EEC teacher/site-coordinator certification. Under 7.09(15)(b)3, a licence for nine or ten children requires a five-hour approved pre-service training within one year prior to application plus three years as a licensee or certified assistant, or one year plus two additional years with unrelated children in a group setting. The trap is that these are not requirements you can satisfy during the application: they are entry conditions, and an applicant who requests a capacity of eight on day one without having ever held a family child care licence or a certified assistant certificate is asking for something 7.09(15)(b)2 does not permit. Note also the statutory frame at M.G.L. c. 15D, s. 1A, which caps a "family child care home" at "6, including participating children living in the residence" and defines a "large family child care home" as one that "shall have at least 1 approved assistant when the total number of children participating in child care exceeds 6". EEC's own consumer page states you may enrol up to 8 without an assistant when at least two children are school age; that reading depends on the school-age carve-out written into the s. 1A definitions, and 606 CMR 7.10(4)(e) does allow seven or eight children with one educator. Plan for six, then upgrade.
  3. CONFIRM THE DWELLING ITSELF IS LICENSABLE, AND GET WRITTEN PERMISSION TO USE IT. 606 CMR 7.03(5)(e) is narrower than most applicants expect: "family child care may only be provided in a dwelling that provides complete independent living facilities for one or more persons including permanent provisions for living, sleeping, eating, cooking, and sanitation." That dwelling must either be occupied full time as a legal residence by the licensee or by an individual personally known to the licensee, or be unoccupied and fall into one of exactly three shapes: physically on the same property as the licensee's permanent residence where that residence is a single-family home; one half of a side-by-side duplex where the licensee permanently resides in the other unit; or a unit in a structure of at most three stories with no more than one dwelling unit per floor where the licensee permanently resides in one of the other units. A rented storefront, a finished garage that lacks cooking and sanitation, or a second apartment across town is not a family child care home. 606 CMR 7.03(5)(f) adds that "a family child care licensee may not hold more than one family child care license", which kills the plan of licensing two homes and staffing one with an assistant. EEC's own applicant checklist, "Opening a Family Child Care (FCC) Program: Initial Considerations" (published February 2026), makes the practical questions explicit and cites 606 CMR 7.03(5)(e): is the home currently occupied for living purposes; if the home is in an apartment, condominium or homeowners association, do you need permission to operate a business; if you rent, have you informed your landlord or management company of your intent to open a family child care business; does your city or town require a business permit; and is your residence located on the third floor or below. The expensive traps here are the two nobody puts in writing early. First, a landlord or condominium board can veto the whole project after you have paid for training, and EEC will not overrule a private lease or covenant. Second, municipal permitting is separate and additive: 606 CMR 7.14(1) states plainly that licensure "shall not relieve programs of their obligation to comply with any other applicable state or federal statutory or regulatory requirements", and your city or town may still want a home-occupation or business certificate. Settle both before you spend a dollar on training or equipment.
  4. MEASURE THE APPROVED ACTIVITY SPACE WITH A TAPE, AND DISTRUST THE THIRTY-FIVE-SQUARE-FOOT FIGURE. 606 CMR 7.07(15)(c)1 sets family child care indoor minimums that are not a per-child rate at small capacities: "a minimum of 150 square feet of approved activity space for one or two children; a minimum of 225 square feet of approved activity space for three to six children; 35 square feet of approved activity space for each child when serving seven to ten children." Two structural limits follow. 7.07(15)(c)2 says the counted square footage "can be located on no more than two adjacent floors", so a first-floor playroom plus a third-floor bedroom does not add up. 7.07(15)(c)3 says "no more than one area that is used exclusively for napping purposes can be counted toward meeting the square footage requirements." "Approved Activity Space" is itself defined in 606 CMR 7.02 as space the Department determines safe and appropriate and "shall include only usable floor space exclusive of hallways, bathrooms, and portions of rooms or areas" that are not usable, so the hallway you were counting is not counted. Outdoors, 606 CMR 7.07(7) requires an outdoor play area, maintained or accessible, of "at least 75 square feet per child who is outside at any one time", accessible to children with disabilities, providing both direct sunlight and shade, and free of hazards including a busy street, a parking lot, poisonous plants, water hazards, debris, broken glass and chipping paint. EEC's checklist "Opening a Family Child Care (FCC) Program: Before the Licensing Visit" restates this arithmetic as 6 children equals 450 square feet, 8 equals 600, and 10 equals 750 of outdoor space. Here is a contradiction inside EEC's own material that costs applicants a second visit: the mass.gov step-1 page "Check if you meet FCC licensing requirements" summarises the indoor rule as "Indoor space: 35 square feet per child", which understates the requirement for every capacity from one to six children. An applicant with a 200-square-foot playroom who reads only the web page believes she is licensable for five children; 7.07(15)(c)1 says she needs 225. The regulation controls. Measure to the regulation, not the summary, and if the outdoor space is short, EEC's Initial Considerations checklist accepts the question "is there a park or playground within walking distance" as the fallback route, which the licensor will want to see walked.
  5. PROVE TWO SEPARATE EXITS TO THE OUTSIDE, BECAUSE THIS IS THE SINGLE MOST COMMON MASSACHUSETTS DISQUALIFIER. 606 CMR 7.07(15)(b)1 states that "family child care homes must have at least two separate exits to the outside, approved by the Department", and 7.07(15)(b)2 adds that if a basement space is approved for child care, "the basement must have at least two separate means of egress directly to the outside", both approved by the Department. Homes initially licensed before October 10, 2003 and continuously licensed since are exempt from the basement rule under 7.07(15)(b)3 until substantial renovation. EEC's policy "Exits and Evacuations in Family Child Care Programs", effective January 29, 2013 and updated May 8, 2024, is the document your licensor will apply. It defines two exits as "two separate doorways leading from the home or apartment building to the outside ground level" and separate as doorways "located in different parts of the home", expressly excluding two doors in sequence along the same exit route. Every exit must be marked with a visible exit sign posted above it, kept clear, and openable from inside under all lighting conditions without a tool or key. Balcony doors with no stairs or ramp to ground level are not exits. Doors exiting to ladders are not exits. Elevators may never be used in an evacuation and any route requiring one is non-compliant. Bulkheads and garage doors qualify only if they open easily from the inside, open manually without electricity, and stay unlocked whenever children are in care. For apartments the policy is specific: the unit needs one exit into the building interior and the building must have two separate distinct exits to outside ground level; a converted attic or basement apartment with one exit is non-compliant unless a certificate of occupancy covering the converted space is provided to EEC. Note a real divergence you should not rely on: the same 2024 policy says exits "may be ground level doors, garage or bulkhead doors, or stairs leading from the basement to a first-floor exit", and EEC's Initial Considerations checklist says of a licensed basement that "one may be the stairs to the first floor", while 7.07(15)(b)2 as codified demands two means of egress "directly to the outside". The softer reading is the agency's; the regulation is the harder one, and a different licensor can hold you to it. Design the basement to the regulation or do not licence the basement.
  6. REGISTER FOR A PROFESSIONAL QUALIFICATIONS NUMBER AND A STRONGSTART ACCOUNT BEFORE YOU BOOK ANY TRAINING. EEC's step-2 page, "Complete FCC program trainings", is explicit that you must create two accounts before you can complete a single required course: first, "Register with the Department of Early Education and Care (EEC) to get a Professional Qualifications (PQ) number", done through EEC's Professional Qualifications Registry profile setup at eec.state.ma.us; second, create a StrongStart account, StrongStart being EEC's online professional development system at strongstart.eoe.mass.gov, through which every required online and in-person course is enrolled and recorded. The PQ number is not a formality. 606 CMR 7.09(4) provides that "all educators must register annually with the Department of Early Education and Care in accordance with EEC policies and procedures", and 7.09(10) requires the licensee to hold evidence that personnel are currently certified, licensed or registered where required, "including, but not limited to, driver's licenses and EEC registration". The PQ number is the key that ties your training transcript, your background record check and your licence record together across LEAD, StrongStart and the registry; without it, courses you complete may not post to a transcript the licensor can see. The trap is sequencing and it costs weeks rather than money. Applicants routinely take a first-aid class or an outside child-development workshop before creating the registry profile, then discover at the pre-licensing visit that EEC has no record of the hours and that a paper certificate from an unapproved trainer is not a Department-approved training under 606 CMR 7.09(15)(b)1.c or d. Create the PQ profile first, enrol every course through StrongStart so that completion posts automatically, and download your transcript before you open the licensing transaction so you can upload it as evidence. The registry profile is also where the annual re-registration required by 7.09(4) is done for as long as you hold the licence, so treat it as a permanent account rather than an application step.
  7. COMPLETE THE FULL ORIENTATION AND POTENTIAL-PROVIDER TRAINING SET, AND CHECK THE LIST AGAINST THE VISIT CHECKLIST. 606 CMR 7.03(1)(b) conditions the licence on the fact that "within one year prior to licensure the licensee (or his or her designee) has attended an orientation to early education and care approved by the Department", and 606 CMR 7.09(9) repeats that all educators must attend a Department-approved orientation. As EEC delivers this today, the applicant-facing package on mass.gov step 2 is: the Potential Provider Training, a two-part online StrongStart course of 1.5 hours known as PPT 1 and PPT 2, available in English, Spanish, Portuguese and Mandarin; and the Family Child Care Potential Educator Meeting, a three-hour in-person session at an EEC regional office known as the PEM, available in English, Spanish and Portuguese. EEC's guide page states you must complete "about 16 hours of online and in-person training before applying for your FCC license", a figure the step-2 page's own course list does not reconcile to, so budget for more than the 4.5 hours the two named courses total. More importantly, EEC's pre-visit checklist "Opening a Family Child Care (FCC) Program: Before the Licensing Visit" lists a fourth item the step-2 page omits entirely: documentation of "EEC Essentials 2.0 training", alongside the in-person PEM, FCC PPT1 and FCC PPT2. Take EEC Essentials 2.0 even though the application page does not mention it, because the checklist your licensor works from does. On top of orientation, capacity-specific pre-service training is a hard entry condition: 606 CMR 7.09(15)(b)2 requires a Department-approved pre-service training completed within one year prior to application for a seven-or-eight-child licence, and 7.09(15)(b)3 requires a five-hour approved pre-service training within one year prior to application for nine or ten. The trap is the one-year clock in both 7.03(1)(b) and 7.09(15)(b): training completed too early expires against the application just as surely as training not completed at all, and an applicant who takes orientation, then spends fourteen months finding a suitable apartment, retakes it. Take orientation only once the dwelling question of step three is settled.
  8. HOLD FIRST AID AND CPR CERTIFICATION AND A CURRENT MEDICAL FORM IN HAND ON THE DAY YOU APPLY. 606 CMR 7.09(15)(b) is unusually direct about timing: "Prior to being licensed for the first time to provide family child care the applicant must submit evidence of current certification in basic first aid and CPR that is age appropriate for all of the children in care." 606 CMR 7.03(5)(a)2 lists that certification among the documents required for a family child care licence, citing 7.09(15)(e), and EEC's pre-visit checklist specifies "Infant/Child First Aid and CPR (must include in-person skills practice)" for the licensee and for every adult working in the program. That in-person skills requirement is the money trap: an online-only certificate is cheaper, arrives instantly, and is refused, so book a class with a hands-on skills session. 606 CMR 7.09(15)(e) also warns that "training in first aid and CPR may not be counted toward Professional Development hours", so it does not offset the five or ten annual professional development hours that 7.09(15)(f) will require of you later. The health side is separate and equally pre-emptive. 606 CMR 7.09(11) requires, prior to licensure, evidence from a licensed health care practitioner that the educator has had a physical examination within one year prior to employment, evidence of immunisation in accordance with Department of Public Health recommendations, and a statement of any limitations on the educator in working with children; 7.09(12) preserves a written religious or medical exemption from immunisation. 606 CMR 7.03(5)(a)3 requires those health records to be submitted with the family child care application, and EEC supplies a specific "Family Child Care medical form" that the step-3 page tells you to upload to the LEAD Document Library. 606 CMR 7.09(13) then requires a current physical examination again at each licence renewal. Do not overlook 606 CMR 7.09(15)(g): on request, the licensee must provide a statement signed by a physician "certifying that any household member or person regularly on the premises of the family child care home is in good physical and mental health" — a demand that lands on relatives who never expected to be part of your application, and which is worth warning them about before the licensor asks.
  9. REQUEST A LEAD ACCOUNT, OPEN THE LICENSING TRANSACTION, AND WATCH THE NINETY-DAY CLOCK. All EEC licensing now runs through the Licensing Education Analytic Database, a cloud-based system EEC describes as handling "all licensing-related transactions", including applying for a new licence and applying to renew one. Family child care applicants and family child care assistants may request a new user account themselves through the LEAD Provider Portal request form at childcare.mass.gov, or by telephoning an EEC regional office; group, school age, residential and placement applicants must go through the regional office instead. Once approved you receive an email with instructions to log in and set a password, then start a "new transaction" in LEAD, which asks about you, your household members, and your indoor and outdoor spaces. EEC's step-3 page states the constraint that catches people: "You have 90 days to complete the process." You then upload documents to the LEAD Document Library, which EEC lists as first aid and child and infant CPR certifications, a completed EEC medical form, proof of completed online and in-person training, and other forms about indoor and outdoor safety and program operations as required. After submission EEC emails two more items that are not part of the LEAD transaction itself and are missed constantly because they arrive separately. The first is the tax certification statement, linked from your LEAD confirmation email, by which you attest that you have filed and paid all required Massachusetts taxes; this is the document 606 CMR 7.03(1)(c)6 demands as "evidence of compliance with St. 1983, c. 233, Revenue Enforcement and Protection Program (REAP) on a tax certification form provided by the Department", and an unresolved state tax delinquency will stop a licence regardless of how good your home is. The second is the background record check consent form, which arrives in its own email and which every household member and frequent visitor aged 15 or older receives individually. The trap is treating submission as completion: the ninety-day window runs against a transaction that is not finished until the uploads, the REAP certification and the consent forms are all in, and a spouse who ignores a consent email for a month burns a third of your clock.
  10. DO NOT MAIL A CHECK UNTIL EEC ASKS, BECAUSE THE FEE QUESTION IS GENUINELY CONTRADICTED ON MASS.GOV TODAY. Three official texts disagree and you should know all three before you spend anything. The regulation still contemplates a fee: 606 CMR 7.03(1)(c) conditions issuance on the applicant submitting "a completed application on a form provided by the Department, the required license application fee and the following documents", and 606 CMR 7.03(3) requires a renewal applicant to "pay any required application fee not less than 30 days before the date of expiration". 102 CMR 1.03(5), still listed by EEC as a live licensing regulation, adds that "the application, where applicable, shall be accompanied by a check made payable to the Commonwealth of Massachusetts. A fee schedule may be obtained from the Office." The fee schedule EEC still publishes, an internally dated document headed EECLicensingApplicationFeeSchedule20100217, states "A non-refundable application fee in the form of a check or money order, payable to the Commonwealth of Massachusetts, must accompany all applications" and prices family child care as: Provider (new and renewal) 100.00 dollars; Certified Family Child Care Assistant 75.00 dollars; Upgrade within Licence or Certificate Period 25.00 dollars; Change of Address 100.00 dollars. Against all of that, EEC's current applicant guide "Become a Family Child Care Provider" states flatly, in the same paragraph that gives the two-to-six-month timeline, that "There is no cost to apply for a license", and the step-3 page describing exactly what to submit in LEAD lists no fee, no check and no payment step at all. The practical instruction that follows is not a guess about which text won: send nothing until the LEAD transaction or your assigned licensor asks for a payment, and if you are told a fee is due, ask for the current schedule in writing. The costly error here is the mirror image on renewal: 7.03(3) makes the renewal filing due "not less than 30 days before the date of expiration", and if a fee is in fact required and arrives late with it, the protection in that same subsection — that a timely renewal keeps the licence in effect until EEC decides — does not attach. Treat "no cost" as EEC's current practice statement and the 2010 schedule as an artefact that has not been taken down, but confirm before you rely on either.
  11. PUT EVERY HOUSEHOLD MEMBER AND FREQUENT VISITOR AGED FIFTEEN OR OLDER THROUGH THE BACKGROUND RECORD CHECK. This is the step that most often decides whether a Massachusetts family child care licence issues, and it reaches people who will never care for a child. 606 CMR 14.05(2) defines the family child care candidate pool as current licensees and applicants for licensure; "household members, as defined by EEC licensing regulations at 606 CMR 7.02: Definitions, 15 years of age or older, regardless of whether such individuals are present while child care children are present; and persons regularly on the premises (including volunteers and other regular visitors) 15 years of age or older"; and all current and prospective assistants and volunteers whether or not unsupervised. Each of them "will be required to complete a CORI, DCF, SORI, NSOR, fingerprint-based check and all out of state checks mandated by CCDBG". EEC's step-4 page spells out what those are: a Massachusetts CORI check including juvenile records, sealed records, delinquent and non-delinquent findings, convictions and non-convictions; a Department of Children and Families check for supported 51B findings of child abuse or neglect; a Sex Offender Registry Information check covering level 1 to 3 classifications; a fingerprint-based FBI national criminal history check; the National Sex Offender Registry; and out-of-state record checks for anyone who has lived outside Massachusetts in the past five years. 606 CMR 14.09(2)(a) is the gate: for family child care licensees, "a BRC must be complete with a final suitability determination issued on all household members and persons regularly on the premises 15 years of age or older ... before EEC will issue a license." 606 CMR 14.08(6) repeats that the licensee's process is complete only when every one of those determinations is in. Timing is the trap. 606 CMR 14.08(3) allows checks to be requested "within a maximum of 45 days from the date the candidate is fingerprinted", excluding review time, and every candidate must attend an in-person fingerprinting appointment. One adult child who will not book fingerprinting freezes the licence indefinitely. Two more obligations survive licensure: 606 CMR 14.07(8) requires the licensee to ensure every candidate signs the consent form "each year that they are present", and 606 CMR 7.04(16)(b) requires notice to EEC "within seven days of approval as a foster or adoptive placement resource, or of any change in the household composition." A new roommate is a licensing event.
  12. HANDLE LEAD PAINT AS A DISCLOSURE AND PEELING-PAINT PROBLEM, NOT AS A DELEADING CERTIFICATE — THIS IS WHERE MASSACHUSETTS ADVICE GOES WRONG. Family child care and centre-based care are treated differently, and copying the centre rule costs thousands of dollars nobody asked you to spend. For centres, 606 CMR 7.07(16)(a) does require a lead paint inspection: a program serving any child younger than five "must provide evidence of a lead paint inspection from the local board of health, or the Massachusetts Department of Public Health, or a private lead paint inspection service and compliance with The Department of Public Health regulations at 105 CMR 460.000: Lead Poisoning Prevention and Control", and 606 CMR 7.03(6)(a)5 lists that inspection among the documents a small or large group applicant must submit. For family child care there is no such requirement. 606 CMR 7.03(5)(a)1 requires only "copies of the lead paint disclosure statement required by 606 CMR 7.07(15)(a)2", and 7.07(15)(a) in full requires you to give parents written information about the risks and sources of lead poisoning, to give all parents "a disclosure statement regarding any known source of lead in the home", to keep a written acknowledgement of receipt in each child's record, to give written notice to all parents if chipping or peeling paint or plaster is found in a home built prior to 1978, and, under 7.07(15)(a)6, to notify EEC and follow DPH guidelines if DPH determines your home to be the source of lead poisoning for any child. 606 CMR 7.04(16)(d) mirrors that last notification duty. What actually bites is peeling paint. 606 CMR 7.07(6) requires the interior and exterior kept "free of chipping, flaking, or peeling paint or broken plaster", and EEC's Family Child Care Licensing policy on Peeling Paint sets the enforcement: the licensee is given the Renovate Right brochure and "a timeframe of up to 60 days" to comply, and until an acceptable plan of compliance is submitted, no new children may be enrolled, an alternative outdoor play space must be used, any interior room with peeling paint cannot be used for child care, entry and exit routes must be free of peeling paint, parents must be verified as notified in writing, and "all children in care must have up-to-date lead tests". Failure to correct means closure and inactive status, then referral to EEC's Legal Unit. Scrape and repaint before the visit; do not commission a deleading order you do not owe.
  13. INSTALL SMOKE DETECTORS AND CARBON MONOXIDE ALARMS TO THE FIRE CODE, AND START THE MONTHLY LOG BEFORE THE VISIT. 606 CMR 7.07(15)(d)1 requires approved smoke detectors on or near the ceiling throughout the home: "on each floor level of the home, including cellars and basements", with a detector installed in each stairway on the ceiling near the base but not within the stairway, a basement detector located near the base of the stairwell leading to the floor above, and detectors "outside of each separate sleeping area", where sleeping areas separated by rooms such as kitchens or living rooms — but not bathrooms — count as separate. 7.07(15)(d)2 then imposes the paperwork that licensors actually cite: detectors "must be maintained in operable condition. The licensee must maintain a safety log of tests made monthly. If the smoke detector is battery operated, the batteries must be replaced at least annually, or more often as necessary, and noted in the safety log." An empty log at the pre-licensing visit is a finding; start testing and writing it down the month before you apply. Carbon monoxide is governed by 606 CMR 7.07(10)(p), which requires approved carbon monoxide alarms "located and maintained in the program in accordance with the provisions of the state fire safety code and guidelines". EEC's Family Child Care Licensing policy on Carbon Monoxide Alarms identifies that code as 527 CMR 31.00, the Board of Fire Prevention Regulations, requiring alarms on every level of a residence except basements and attics without habitable living space, within ten feet of each bedroom door, and in living areas adjacent to garages, in any residence containing fossil-fuel-burning equipment or enclosed parking; approved alarms must be battery-powered with battery monitoring, plug-in with battery backup, hard-wired with battery backup, low-voltage or wireless, or a qualified combination smoke and carbon monoxide unit with distinguishable voice and tone alarms. The policy also places the duty on landlords in rental space and tells tenant providers to report failures immediately and, if the landlord will not act, to report non-compliance to the local fire department. EEC's pre-visit checklist goes further than the regulation and asks for smoke and carbon monoxide detectors "installed on every level of the home, outside of sleeping areas, including levels not licensed for child care". On fire authority generally, 606 CMR 7.07(3) says only that "the licensee shall submit evidence of compliance with applicable fire codes", with no family child care exemption; note that EEC's current list of documents to upload in LEAD does not name a fire department certificate for family child care, so ask your licensor what evidence she wants rather than paying for an inspection nobody requested.
  14. TEST THE WELL IF YOU HAVE ONE, AND CHECK THE TAP TEMPERATURE EITHER WAY. 606 CMR 7.07(4) applies to every licensee including family child care: "The licensee must provide evidence that any private well or water source has been inspected and approved by the local board of health, health department, or private laboratory within one year of licensure and meets Department of Environmental Protection Standards, if applicable." Two riders matter. 7.07(4)(a) requires that evidence to be updated at each regular licence renewal, which for family child care means every three years under 606 CMR 7.03(5)(b). 7.07(4)(b) adds the threshold that turns a household well into a regulated utility: "Programs using well-water to serve 25 or more people for at least 60 days each year require DEP approval as small public water suppliers." A ten-child family child care home with a household of four will not normally cross twenty-five people, but a program that also hosts regular gatherings or a large household should count carefully, because becoming a small public water supplier brings a permitting and sampling regime that has nothing to do with EEC and will not be completed in the ninety days LEAD gives you. EEC's pre-visit checklist restates the requirement in plain terms: "Well water (if used) must be tested and meet MA drinking water standards." If you are on municipal water, no test is required of you, but 606 CMR 7.07(4) is drafted around the water source rather than the town, so keep the answer documented. Separately, 606 CMR 7.07(10)(l) requires running water in sinks used by children and provides that "water temperature must not exceed 120 degrees F", a number EEC's pre-visit checklist repeats as "Hot water less than 120 degrees F"; a licensor will run the tap and read a thermometer, and a water heater set at 140 degrees is a same-day finding you can fix for nothing if you check it first. 606 CMR 7.07(13) additionally requires a source of sanitary drinking water located in or convenient to the space used by children. Finally, if your water source ever changes, notify EEC; the written notification duty at 606 CMR 7.04(17)(f) is drafted for group programs, but the licensor will expect to be told, and an unreported switch to a new well is a compliance problem rather than a paperwork one.
  15. WRITE THE EMERGENCY PLAN WITH ALL SIX REGULATORY ELEMENTS PLUS THE TEN-MINUTE CAREGIVER, AND BEGIN MONTHLY DRILLS. 606 CMR 7.11(7)(f) requires a written plan detailing procedures for meeting potential emergencies "including but not limited to missing children, the evacuation of children from the program in the event of a fire, natural disaster, loss of power, heat or hot water or other emergency situation", and it enumerates what the plan must contain: a method to obtain information from local authorities to determine whether to evacuate or shelter in place in a natural disaster; escape routes from each floor level approved for child care; a designated meeting place outside and away from the home; a method of contacting the fire department or other appropriate authorities after evacuation; a method of communication with parents in the event of an emergency evacuation; and a means to assure that no child is left in the home after evacuation. 7.11(7)(g) requires the plan to be kept current and to meet the needs of all children in care including infants, toddlers and any child who may need additional assistance. Family child care carries one extra element that applicants forget and licensors always look for: 606 CMR 7.11(17)(b) requires that, in addition to 7.11(7)(f), the plan include "the name and telephone number of a potential emergency caregiver who will be available to arrive at the child care home within ten minutes of being summoned to provide temporary child care in case of a medical emergency." You need a named, willing, reachable person, and if that person will be regularly on the premises she becomes a background record check candidate under 606 CMR 14.05(2)(b). Drills are not deferrable to opening day. 606 CMR 7.11(7)(h) requires practice evacuation drills with all groups of children and all educators from each floor level of the approved space "at least monthly", held at different times of the day, using alternative exits, with documentation of the date, time, exit route used, number of children evacuated and effectiveness of each drill. EEC's Exits and Evacuations policy adds that the documentation must show the provider "consistently evacuates the home from all EEC-approved exits", that EEC may ask for a demonstration at any time, and that based on your demonstrated ability to evacuate safely "EEC may limit the age or number of infants and non-mobile children the provider may serve" — a capacity consequence, not just a citation. 606 CMR 7.11(1) requires all educators to be trained in the plan, and 606 CMR 7.11(7)(e) requires exit signs posted in rooms with direct access to the outdoors.
  16. ASSEMBLE THE PARENT PAPER SET AND THE CHILDREN'S RECORD FORMS, BECAUSE BOTH ARE APPLICATION DOCUMENTS. 606 CMR 7.03(1)(c)4 requires the applicant to submit "a copy of the written information for parents, as required by 606 CMR 7.08(6)", and 7.03(1)(c)5 requires "forms to record information required to be maintained in children's records, as required by 606 CMR 7.04(7)". These are not things you write after you open. 606 CMR 7.08(6) lists fourteen items that must be given to families in writing before a child enrols: notice that parents are welcome to visit unannounced at any time while their child is present and that input and communication are encouraged; the frequency of children's progress reports; the medication administration policy per 7.11(2)(a); the procedures for meeting potential emergencies per 7.11(7)(f); the transportation plan per 7.13(1); a program calendar noting closed days and hours; the fee schedule including late payment, late pick-up, field trip and special materials charges; the plan to provide positive and consistent guidance; the criteria for excluding children for serious, contagious and reportable illnesses in conformance with DPH Division of Communicable Disease Control; SIDS risk reduction information including back sleeping per 7.11(13)(e); the procedures relating to children's records per 7.04(7) through (10); notice that educators are mandated reporters who must report suspected abuse or neglect to the Department of Children and Families; notice that the program is licensed by EEC with the telephone number and address of the responsible EEC regional office; and a statement that parents may contact EEC for the program's regulatory compliance history. 606 CMR 7.08(9) adds two family-child-care-only notices: written notice of the existence of a firearm in the home, given at enrolment and whenever a firearm is brought in, and notice of any change in the regular composition of the household or of anyone regularly on the premises. EEC supplies model documents your licensor will expect to see printed, completed and signed: the EEC Family Child Care Enrollment Packet, the EEC Family Child Care Parent Handbook, the EEC Family Child Care Sample Forms packet, the Child Care Provider Safe Sleep Pledge Form, and sample progress report formats. On the record side, 606 CMR 7.04(7)(a)13 requires each child's file to hold immunisation certification, a physical examination within one year prior to admission documented within one month of admission, and a lead poisoning screening statement obtained within one month of admission consistent with 105 CMR 460.050. Build the blank forms now; the licensor checks that they exist, not that they are filled.
  17. STAGE THE HOME EXACTLY AS IT WILL LOOK ON DAY ONE FOR THE PRE-LICENSING VISIT. EEC's instruction is literal: "Before your pre-licensing visit, your home should look exactly as it will on your first day of operation", meaning safe and supplied with the appropriate materials for the children you plan to care for. The visit is a federal requirement as well as a state one; EEC's Inspections and Visits policy, issued under the 2014 CCDBG reauthorisation and 45 CFR 98.42, commits EEC to "at least one pre-licensing visit, and more if needed, to determine, at a minimum, compliance with health, safety, and fire standards", followed by at least one annual unannounced visit thereafter. EEC's step-6 page states the visit "usually takes 1 to 2 hours", and that the licensor checks that you have printed, reviewed and understand the enrolment packet, parent handbook, sample forms, safe sleep pledge and progress report formats, and that your physical space is ready: enough age-appropriate toys, materials and equipment for the number of children you plan to serve, all materials ready and available, and indoor and outdoor spaces meeting safety and program standards. What licensors actually cite is catalogued in EEC's own checklist "Opening a Family Child Care (FCC) Program: Before the Licensing Visit": a written emergency preparedness plan; a first aid kit containing family contact information, each child's medical information, allergies and medications, authorisation for emergency treatment, adhesive tape, bandages, gauze, non-latex gloves, an instant cold pack, scissors, tweezers, a thermometer and a CPR mask; individual napping equipment per child; a diapering area separate from food preparation and eating areas; pets licensed, vaccinated and kept sanitary with outdoor play areas free of animal waste; firearms locked away with ammunition stored separately, as 606 CMR 7.11(17)(a) requires; a refrigerator holding 32 to 40 degrees F with a thermometer inside; outlets covered and cords secured under 606 CMR 7.07(10)(o); stairway handrails and barriers under 606 CMR 7.07(11), with top barriers permanently installed and pressure gates prohibited at the top of stairs; portable space heaters prohibited under 606 CMR 7.07(10)(b); indoor temperature at least 65 degrees F; windows screened, locked or secured and blind cords inaccessible; hazardous materials, medications, cosmetics, batteries and choking hazards out of reach; and playground equipment meeting EEC's Playground Safety policy and the impact-absorbing use-zone rule at 606 CMR 7.07(15)(e). Check your LEAD account one to two days after the visit for the licensor's notes; follow-up items must be completed within two weeks, corrective action plans must include notes and images of the corrections, and some items trigger a second visit.
  18. EXPECT TWO TO SIX MONTHS, A THREE-YEAR LICENCE, AND NO PROVISIONAL PERIOD TO HIDE BEHIND. EEC's own guide sets the planning horizon: "It can take 2-6 months to complete licensing steps." The internal clocks that produce that range are the ninety days LEAD allows to complete the application, the up-to-forty-five days 606 CMR 14.08(3) allows for background record checks to be requested from each federal or state repository after fingerprinting excluding review time, the wait for a final suitability determination on every household member and frequent visitor aged fifteen or older that 606 CMR 14.09(2)(a) makes a precondition to issuance, the scheduling of the pre-licensing visit, and the two weeks allowed for follow-up items. What issues at the end is a regular licence: 606 CMR 7.03(5)(b) provides that for family child care "a regular license or approval is valid for three years from the date of issuance unless revoked, suspended, or made probationary." Note what is absent. The provisional licence at 606 CMR 7.03(6)(b)1, valid six months and renewable once for six more for a program "that has not previously operated, or that has not complied with or is unable to comply with all applicable regulations", is written for small and large group and school age programs only; family child care has no provisional tier, so there is no partially compliant opening. You either meet 606 CMR 7.00 at the visit or you do not open. 606 CMR 7.03(2) fixes what the licence buys: programs are licensed for the maximum number of children who may be in the care of educators at any one time, considering the size and layout of the facility, the number and qualifications of educators, equipment, the needs of the children served and any building certificate capacity, and "at no time shall a program admit, supervise or provide care for more than the maximum number of children indicated on the license." Read 606 CMR 7.03(5)(c) against that number before you enrol anyone: every child living in the home who is younger than school age counts, every home-schooled child in the home counts regardless of age, every child under ten living in the residence who is present more than three consecutive hours on each of five consecutive days counts, every person under fourteen who does not live there and is present during care counts, and during overnight care every person under eighteen in the home counts. Renewal is filed in LEAD not less than thirty days before expiry under 7.03(3) and requires participation in a licence renewal meeting, and 606 CMR 7.03(5)(d) lets you go inactive by returning the licence rather than surrendering it if you stop caring for children.

What you must post on your walls

  • THE CURRENT EEC LICENSE OR APPROVAL, POSTED CONSPICUOUSLY. Two separate regulations impose this, and Massachusetts inspectors cite the one applicants have never read. 606 CMR 7.04(14) opens "Required Postings. The licensee must post the following information in an area easily visible to parents, educators and visitors," and subparagraph (d) is simply "the current license or approval." That is the family child care rule, and it applies to every program type because 606 CMR 7.04 states at its head that "the following requirements apply to all programs, including family child care, small group and school age and large group and school age child care." The second source is 102 CMR 1.00, EEC's enforcement chapter, which the agency still serves today alongside 606 CMR 7.00 on its EEC Laws and Regulations index: 102 CMR 1.03(8), "Posting of License. The provider shall post conspicuously any license issued by the Office." Read together, the standard is not "keep the license where you can find it" but display it where a parent standing in your entry can read it without asking. EEC's own Family Child Care Self-Assessment Tool, the checklist the agency tells you "will assist you in preparing for the licensor's visit to your home" and which "is completed and reviewed during the visit," asks the question in the exact form a licensor will ask it, listing among the items that must be posted in an area easily visible to parents, educators and visitors: "A current EEC License and, if applicable, Assistant Certificates or Approvals." That last clause is the trap. If you employ an EEC-certified family child care assistant or an approved assistant, the assistant's certificate or approval is a posting in its own right, not a file document, and a certificate that expired while the licensor was driving to your home is a finding. Note what "current" means procedurally: under 606 CMR 7.03(3), if you file your renewal application and fee at least 30 days before expiration, "the license, certificate or letter of approval will remain in effect until the Department makes a final determination on the application," so a license showing a lapsed face date is defensible only if the timely renewal is documented. What a monitoring visit checks is physical: the licensor looks for the license, reads the capacity and age range printed on it, and cross-checks that against the children actually present, because 606 CMR 7.03(2) provides that "at no time shall a program admit, supervise or provide care for more than the maximum number of children indicated on the license." The posted license is therefore the instrument by which your capacity violation is proved.
  • THE EMERGENCY PREPAREDNESS PLAN, POSTED IN PLAIN VIEW NEXT TO THE LICENSE. This is the newest posting duty in Massachusetts and it is not in 606 CMR 7.00 at all. EEC policy FO-26-01, "Emergency Preparedness in Child Care Programs," release date 21 August 2026, effective date 1 September 2026, applicability "Licensed and Funded Child Care Programs," states under the heading "Posting and Notification" that all programs must "Post their emergency preparedness plan in plain view next to the program's EEC child care license," must "Provide copies of the emergency preparedness plan to all staff," and must "Share the emergency preparedness plan with parents/guardians prior to child enrollment." The plan itself is required by 606 CMR 7.11(7)(f), which demands "a written plan detailing procedures for meeting potential emergencies including but not limited to missing children, the evacuation of children from the program in the event of a fire, natural disaster, loss of power, heat or hot water or other emergency situation," but the regulation nowhere says post it; the posting obligation exists only in the policy. FO-26-01 lists as its authority "M.G.L. c. 15D § 23 (as amended by Stat. 2026, c. 163, § 3)" together with M.G.L. c. 6 §§ 224 and 226 and 606 CMR 7.11(7), 7.11(6) and 7.04(4). The session law is real and current: An Act promoting rule of law, oversight, trust and equal constitutional treatment, Acts of 2026, chapter 163, an emergency law approved 5 August 2026, whose SECTION 3 adds Section 23 to chapter 15D and whose SECTION 19 requires every licensed child care center, family child care home, school-aged child care program and group care facility to have the resulting policy "in effect not later than September 1, 2026 or the first day of the 2026-2027 school year, whichever is earlier." The plan content that must now hang on your wall is far larger than the old contingency plan: FO-26-01 enumerates eleven required topics, including Communication with Authorities, Communication and Reunification with Families, Power Heat and Water, Missing Child, Shelter in Place, Lockdown, Evacuation, Relocation to two named sites (one within walking distance and one outside the neighborhood), Immediate Continuity of Operations, Staff Training and Practice Drills, and Interactions with Civil Law Enforcement Officers. The policy expressly declares obsolete the EEC Emergency Contingency Plans policy (2014), the Emergency Contingency Plans for Funded Programs policy (2019), and the March 2026 version of the Emergency Preparedness in Child Care Programs policy itself, which means a plan copied from any of those, and the posting made from it, is already out of date. Plans go to EEC through LEAD, the licensing portal, by 1 September 2026 and thereafter prior to initial licensure, at renewal, and before any structural change to the property.
  • THE "CALL 911" REMINDER WITH THE PROGRAM'S OWN TELEPHONE NUMBER AND STREET ADDRESS. 606 CMR 7.04(14)(a) requires the licensee to post, in the area easily visible to parents, educators and visitors, a "'Call 911' reminder and the telephone number and address of the program, including the location of the program in the facility." Three separate pieces of information are named and applicants routinely post only the first. The reminder alone is not compliance; the posting must carry the program's telephone number, the street address, and where in the building the program sits, because the point of the requirement is that a substitute, an assistant, a visiting therapist or a panicking parent can read the address aloud to a dispatcher without knowing the house. In a family child care home the "location of the program in the facility" clause matters most in a two-family or apartment building, where the unit number and floor are exactly what an ambulance crew needs and exactly what a resident of the home never thinks to write down. EEC's Family Child Care Self-Assessment Tool poses the requirement as a licensor's question and attaches a warning that is not in the regulation but is enforced through it: "Do you have the following information posted in an area easily visible to parents, educators and visitors? (Please note that if you are utilizing a cell phone, 911 does not connect you with local authorities. Please plan an alternative method of compliance.)" Family child care providers who have cut the landline are therefore expected to post the direct seven-digit or ten-digit numbers of the local fire and police departments as the alternative method, and EEC's emergency preparedness policy FO-26-01 says the same thing in its plan-content requirements, directing programs to "Include the unique phone numbers of your local fire and police departments so that you can call them directly, rather than be routed through 9-1-1." That posting also pairs with an equipment duty rather than a display duty: 606 CMR 7.11(7)(c) obliges the licensee to "provide to educators a working telephone for the purpose of making and receiving phone calls during all hours of program operation, whether on or off the premises, whenever they are responsible for supervising children," and 606 CMR 7.11(7)(b) requires that "the educator must be able to communicate basic emergency information to emergency personnel." A monitoring visit checks the posting and the phone together: a licensor who sees a compliant 911 card next to a disconnected handset writes both.
  • THE POISON CONTROL CENTER NUMBER AND THE EMERGENCY BACK-UP PERSON. 606 CMR 7.04(14)(b) requires posting, in the same conspicuous area, "the telephone number of the Poison Control Center and the name and telephone number of the emergency back-up person." The regulation does not print a number, so do not copy one from a template; obtain the current Poison Control number for Massachusetts and post that. The second half of the paragraph is the half that fails inspections. The "emergency back-up person" is a named human being with a working telephone number, and in family child care that person is defined by a separate regulation with a hard performance standard. 606 CMR 7.11(17)(b), the additional requirement for family child care, provides that "in addition to the information required by 606 CMR 7.11(7)(f), the plan for potential emergencies must include the name and telephone number of a potential emergency caregiver who will be available to arrive at the child care home within ten minutes of being summoned to provide temporary child care in case of a medical emergency." Ten minutes is the test. A back-up person who lives across the county, who works a shift job, or who is your own spouse commuting into Boston does not satisfy 7.11(17)(b), and because the same name is what you post under 7.04(14)(b), the wall becomes the evidence against the plan. Licensors ask for the back-up person by name during visits and sometimes telephone the number on the wall. Two related practical points follow. First, the posting must be kept current: a back-up person who has moved away leaves a compliant-looking posting that is factually false, and the regulation's requirement of a "current" arrangement runs through 606 CMR 7.11(7)(g), which requires that "the plan must be kept current and must meet the needs of all children in care." Second, this posting is one of the four items 606 CMR 7.04(14) groups together, so a single laminated card carrying the 911 reminder, the program address and location, the Poison Control number and the back-up person's name and telephone satisfies subparagraphs (a) and (b) at once, which is precisely how EEC's Family Child Care Self-Assessment Tool bundles them in its checklist line: "'Call 911' reminder, telephone number and address of the program, telephone number of the Poison Control Center, name and telephone number of the emergency back-up person."
  • THE LIST OF EMERGENCY AND LIFE-SAVING MEDICATIONS, POSTED WITHOUT NAMING WHAT PARENTS MAY NOT SEE. 606 CMR 7.04(14)(c) requires the licensee to post, "in a manner that protects the privacy of each child," first "a list of all emergency or life saving medications, including but not limited to epinephrine auto-injectors, inhalers, and anti-seizure medications, that specifies to which children they belong." The regulation asks for two things that sit in tension and expects you to resolve them: the list must tie a medication to a specific child, and it must not expose that child's medical condition to every parent and visitor who walks past. The workable resolution is a posting located where educators and emergency responders will look but out of the sightline of the general waiting area, using first name and last initial, listing the medication and its storage location rather than the diagnosis. Do not confuse this posting with the child's individualized health care plan. EEC's Individualized Health Care Plans policy, effective 29 October 2010 and updated 30 June 2022, citing 606 CMR 7.11(3), states that "a current copy of the individualized health care plan must be maintained in the child's file" and that "individualized health care plans must be kept confidential and should be shared only with those program staff who might need to deal with an emergency involving the child." The IHCP is a record, not a posting; the medication list is a posting, not a record. Storage rules run alongside: 606 CMR 7.11(2)(e) requires all medications stored out of the reach of children under proper conditions, and 606 CMR 7.11(2)(f) provides that "notwithstanding the provisions of 606 CMR 7.11(2)(e), emergency medications such as epinephrine auto-injectors must be immediately available for use as needed," so the posted list should say where the immediately-available medication actually is. The evacuation duty closes the loop: 606 CMR 7.11(5)(d) requires that a first aid kit, current family contact information, information about allergies and known medical conditions, and emergency or life-saving medications "are easily and readily available at all times, and accompany the children anytime they leave the facility in the care of staff," and FO-26-01 makes the same items a mandatory element of the written evacuation section of the emergency preparedness plan. A monitoring visit tests the list against the medication cabinet and against the children actually enrolled that day.
  • THE ALLERGY AND EMERGENCY MEDICAL INFORMATION LIST. 606 CMR 7.04(14)(c)2 requires posting, in the same privacy-protecting manner as the medication list, "a list of allergies and/or other emergency medical information provided by the parent for each child." The phrase "provided by the parent" is the operative limit and the operative obligation: what goes on the wall is what the family told you, so an allergy disclosed at enrollment but never transcribed onto the posting is a violation even though it sits correctly in the child's record. The catch-all "other emergency medical information" reaches beyond food allergy to insect-sting reactions, seizure triggers, asthma, and any condition an adult in the room would need to know inside thirty seconds. Because the posting must be made "in a manner that protects the privacy of each child," the same discipline applies as to the medication list: identify the child in a way staff recognise, state the allergen and the reaction, and keep the display out of the general public sightline while remaining visible to educators and to any substitute. The related duties are all record duties rather than posting duties, and confusing them is the common error. 606 CMR 7.12(4) provides that "educators must follow the directions of the parents and/or the child's physician regarding any food allergies of a child," and 606 CMR 7.12(3) that educators must follow parents' or physicians' orders in the preparation and feeding of special diets. Neither is a posting. 606 CMR 7.11(5)(d) requires the allergy and known-medical-condition information to travel with the children whenever they leave the premises, which in practice means a portable duplicate of the posted list rides in the emergency bag. FO-26-01 hard-codes that duplicate into the written plan, requiring the evacuation section to state "the program's plan for ensuring they will have with them, as required by 606 CMR 7.11(5)(d): a first aid kit; each child's current family contact information; information about allergies and known medical conditions; any emergency or life-saving medications, such as asthma inhalers and epinephrine auto-injectors, for any children for whom they have been prescribed; and authorizations for emergency care for each child." What a monitoring visit checks is coherence across three surfaces: the posted allergy list, the children's records under 606 CMR 7.04(7), and the contents of the bag by the door. A mismatch among the three is written as a finding on whichever surface is thinnest, and it is almost always the wall.
  • ANY EEC NOTICE OF HEARING, NOTICE OF SANCTION, ORDER OR DECISION. This is the posting nobody prepares for and the one that hurts. 102 CMR 1.09(2)(a) provides that "every licensee shall post in a conspicuous place any current license or approval issued by the Office and any notice of hearing, notice of sanction, order, or decision issued by the Office that pertains to the program or facility. Such posting shall be in an area easily viewed by visitors and employees." The obligation is automatic and self-executing: if EEC issues you a deficiency correction order, places you on probationary status, suspends or moves to revoke, or refuses renewal, the paperwork announcing it goes on the same wall as the license, facing the parents. There is no discretion clause, no grace period, and no exception while you appeal. The surrounding subparagraphs extend the exposure. 102 CMR 1.09(2)(b) provides that EEC "may require that written notice of any deficiency correction order, sanction, probationary status, suspension, revocation or refusal to renew be sent by the licensee to funding agencies, referral sources, and when appropriate, parents and any other agency specified by the Office," and that EEC "may specify the content of such notice"; 102 CMR 1.09(2)(c) allows EEC to require "a signed acknowledgement of receipt of such notice on a form specified by the Office"; and 102 CMR 1.09(2)(d) allows EEC to demand "the names, addresses, and telephone numbers of the parents of all children enrolled at the time of the regulatory action and during the previous five years," with 102 CMR 1.09(2)(e) adding, in family day care cases, "the names of all providers for whom an approved assistant has worked." 102 CMR 1.09(1)(a) meanwhile requires EEC itself to notify state funding agencies of the same actions. Two currency warnings belong with this citation. First, 102 CMR 1.00 speaks throughout of "the Office" and "the Office of Child Care Services," an agency abolished in 2005 when the General Court created EEC; 606 CMR 7.01 records that EEC "combines the functions of the former Office of Child Care Services (OCCS) and the former Early Learning Services Unit at the Department of Education." Second, 102 CMR 1.01 states the chapter "is adopted in accordance with M.G.L. c. 28A" and the closing regulatory authority line reads "102 CMR 1.00: M.G.L. c. 28A," while 606 CMR 7.00 is issued under M.G.L. c. 15D. The stale names do not repeal the posting duty. EEC serves 102 CMR 1.00 today, in a file dated on its own face to an effective date of 1 May 1997, from the same index page as 606 CMR 7.00, and its own 2020 Inspections and Visits policy relies on 102 CMR 1.06 for the authority to walk in.
  • EXIT SIGNS, WHICH ARE A POSTING EVEN THOUGH NOBODY CALLS THEM ONE. 606 CMR 7.11(7)(e) states flatly that "exit signs must be posted in rooms that have direct access to the outdoors." It applies to every program type, family child care included, because 606 CMR 7.11 opens by stating that its requirements apply to all programs. EEC's Exits and Evacuations in Family Child Care Programs policy, effective 29 January 2013 and updated 8 May 2024, goes further than the regulation and is enforced as written: citing 606 CMR 7.07(15)(b), it requires that a family child care home have at least two separate, functioning, accessible exits to the outside, and states that all exits must be "clearly marked with visible exit signs posted above the approved exit," "always kept clear of obstructions," and "easy to open from the inside of the child care space under all lighting conditions without the use of a tool or key." The policy defines separateness so a provider cannot count two doors in sequence: "the two exits must not be two doors in sequence along an exit route (i.e. two doors to the same exit route or passing through one door to get to another)," and it excludes balconies without stairs or ramps, doors exiting to ladders, and any route requiring an elevator, since "elevators may not be used during an emergency evacuation." Bulkheads and garage doors count only if they open manually from the inside without electricity and "remain unlocked at all times children are in care." Apartments are addressed specifically: a unit complies if it has a single exit into the building and the building has two separate distinct exits to outside ground level, but "a converted attic apartment or basement apartment with one exit is not compliant with this policy or EEC regulations unless a certificate of occupancy includes the converted space, and a copy of that certificate of occupancy is provided to EEC." The Family Child Care Self-Assessment Tool asks the licensor's version of the question directly: "Do you have exit signs posted in rooms that have direct access to the outdoors?" alongside "Do you have at least two, separate hazard free exits?" and, for a licensed basement, "are there two means of egress directly to the outside?" 606 CMR 7.07(1) supplies the standing condition, that "exits and evacuation routes must be kept clear of obstructions," and the FCC policy adds that they must be "free of hazards, snow, and ice, and must be well lit." A winter monitoring visit checks the snow.
  • THE ESCAPE-ROUTE DIAGRAM AT EACH MEANS OF EGRESS, WHICH IS A GROUP-PROGRAM POSTING AND NOT A FAMILY CHILD CARE ONE. Applicants routinely install a framed floor plan in a family child care home believing 606 CMR 7.00 requires it. It does not. The diagram requirement lives at 606 CMR 7.11(18)(b), inside the subsection headed "Additional Requirements for Small Group and School Age and Large Group and School Age Child Care," and reads "Escape Routes. A diagram of escape routes must be posted conspicuously at each means of egress in rooms that do not have direct access to the outdoors." Two limits sit inside that one sentence. The diagram is required only in group and school age programs, and even there only in rooms that lack direct access to the outdoors, since rooms with direct outdoor access are covered instead by the exit-sign rule at 606 CMR 7.11(7)(e). The companion group-only posting is 606 CMR 7.04(17)(p), "Required Postings. In addition to the information required to be posted by 606 CMR 7.04(14) the licensee must post the following information: 1. the location of the health care policy; 2. the name, address and telephone number of the health care consultant; 3. the location of the first aid kit; and 4. next to each exit, emergency and evacuation procedures." Item 4 is the one that reads like a family child care duty and is not: written emergency and evacuation procedures posted beside every exit are required of small group, large group and school age programs, not of family child care homes. What a family child care provider owes instead is the written plan under 606 CMR 7.11(7)(f), which must include "escape routes from each floor level approved for child care," a designated meeting place outside and away from the home, a method of contacting the fire department after evacuation, a method of communicating with parents, and "a means to assure that no child is left in the home or facility after evacuation" — a document, not a wall. As of 1 September 2026 that document does go on the wall, but by force of EEC policy FO-26-01 rather than 606 CMR 7.00, and next to the license rather than next to each exit. Applicants who diagram their home anyway are not penalised for it; applicants who diagram their home and skip the written plan are, because the diagram satisfies no regulation that applies to them.
  • THE STAFF WORK SCHEDULE, POSTED WHERE PARENTS CAN READ IT — GROUP PROGRAMS ONLY. 606 CMR 7.10(8) is headed "Additional Provisions for Small Group and School Age and Large Group and School Age Child Care," and subparagraph (b) provides that "whenever more than one educator is providing care: 1. the Licensee must establish a written schedule listing all persons on duty, including volunteers. The schedule must show compliance with at least the minimum educator ratios at all times, including during breaks and planning time; 2. the Licensee must keep the schedule current and posted in an area easily visible to educators, parents and visitors." The posting standard is the same phrase used for the core postings at 606 CMR 7.04(14), which means the same wall. What makes this posting dangerous is the content requirement rather than the display requirement: the schedule must on its face demonstrate ratio compliance during breaks and planning time, so a schedule that shows a lead teacher off the floor from 12:00 to 12:30 without showing who covers the group is a self-documented ratio violation posted by the licensee. Volunteers must be listed by name, which interacts with 606 CMR 7.03(1)(c)7, requiring a volunteer plan with documentation of "the dates, hours of service and responsibilities of each volunteer used by the program" and a provision that "volunteers must be under the direct visual supervision of an EEC qualified educator at all times." The parallel administrative duty at 606 CMR 7.04(17)(o) is a keeping duty, not a posting duty: "the licensee must maintain documentation of appropriate staffing at all times, including when regularly assigned educators are absent due to illness, personal business or vacation." Family child care providers do not owe this posting. The additional requirements applicable to family child care are found at 606 CMR 7.10(6) and (7), which govern unaccompanied outdoor play, same-floor supervision and fifteen-minute nap observation, and contain no schedule-posting clause. A family child care licensee who employs a certified or approved assistant still owes the underlying supervision and ratio compliance and still owes assistant documentation, and under EEC's Self-Assessment Tool must post the assistant's certificate or approval alongside the license — but not a shift schedule. A monitoring visit in a group program photographs the posted schedule and compares it against attendance records required by 606 CMR 7.04(4)(a).
  • THE LOCATION OF THE HEALTH CARE POLICY, THE HEALTH CARE CONSULTANT'S DETAILS, AND THE LOCATION OF THE FIRST AID KIT — GROUP PROGRAMS ONLY. 606 CMR 7.04(17)(p) requires that, in addition to the four items posted under 606 CMR 7.04(14), a small group and school age or large group and school age licensee post "1. the location of the health care policy; 2. the name, address and telephone number of the health care consultant; 3. the location of the first aid kit; and 4. next to each exit, emergency and evacuation procedures." Note the precise object of items 1 and 3: what is posted is the location, not the document and not the kit. A sign reading that the health care policy is in the binder on the office shelf satisfies item 1; pinning up the policy itself does not, strictly, satisfy anything, though no licensor will cite you for excess. Item 2 requires the consultant's full name, address and telephone number, and the consultant is a defined role at 606 CMR 7.11(19)(b): each program must have access to a Health Care Consultant who will "be available to the program for consultation, as needed," "approve the program's health care plan at initial licensure and at each license renewal," and "approve first aid training and training in medication administration for staff." A posted consultant whose approval of the current health care plan has lapsed is a finding on the plan, discovered through the posting. Watch the scope mismatch that catches small group operators: the posting duty at 606 CMR 7.04(17)(p) covers small group and school age as well as large group and school age programs, but the written health care policy whose location you are posting is itself prescribed only at 606 CMR 7.11(19)(a), inside "Additional Requirements for Large Group and School Age Child Care," and its ten mandatory elements run from the consultant's and emergency services' telephone numbers through "a list defining mild symptoms with which ill children may remain in care, and more severe symptoms that require notification of the parents or back-up contact to pick up the child" to "notification to parents that educators are mandated reporters and must, by law, report suspected child abuse or neglect to the Department of Children and Families." Family child care providers owe none of the four 7.04(17)(p) postings, because 606 CMR 7.04 states that additional requirements specific to family child care are at 606 CMR 7.04(16), which covers only notifications to the Department about family child care systems, household composition, firearms and lead. A family child care provider still owes the first aid kit itself: 606 CMR 7.11(5)(d) requires it "easily and readily available at all times," and the Self-Assessment Tool checks its contents item by item. What is not owed is a sign saying where it is.
  • THE DIAPERING AND TOILET-TRAINING PLAN, POSTED IN THE DIAPERING AREA — GROUP PROGRAMS ONLY. 606 CMR 7.11(18)(c)1 provides that "a written plan for diapering and toilet training and for the disposal or cleaning of soiled clothing, linen, blankets and diapers must be developed, implemented and posted in diapering areas." It sits in the subsection headed "Additional Requirements for Small Group and School Age and Large Group and School Age Child Care," so it binds group and school age programs, not family child care homes. The verb sequence is worth reading literally: developed, implemented and posted. A plan drafted and filed is two-thirds compliant and fully citable. The plan must cover both the changing procedure and the fate of soiled items, which is where template plans fail, because they describe glove use and surface disinfection and say nothing about how soiled clothing goes home. The rules the plan must implement follow in the same paragraph: 606 CMR 7.11(18)(c)2 requires that "the diaper changing surface must be covered by a disposable cover that is changed after each child has been diapered and that is disposed of in a closed container," and 7.11(18)(c)3 that "the diaper changing surface must be washed and disinfected after each child has been diapered." Family child care operates under a materially looser surface rule at 606 CMR 7.11(17)(c): "diaper changing surfaces must be covered by either a disposable covering, a covering that is washed and disinfected after every use, or a covering designated for an individual child" — three options rather than one, and no posting. The separation requirement is universal: 606 CMR 7.11(10)(e) provides that "facilities used for hand washing after diapering or toileting must be separate from facilities and areas used for food preparation and food service," and EEC's Family Child Care Self-Assessment Tool turns that into the licensor's question, "Do you have a diapering area that is separate from facilities and areas used for food preparation and food service?" together with questions on whether the changing surface is smooth, intact, impervious to water and easily cleaned. One further universal rule bears on enrollment paperwork rather than the wall: 606 CMR 7.04(17)(g)1 requires group programs to keep a statement of non-discrimination "which must include a statement that toilet training status is not an eligibility requirement for enrollment." A monitoring visit in a group room reads the posted plan and then watches a diaper change against it.
  • THE WEEKLY MENU IS NOT A POSTING — IT IS AVAILABLE ON REQUEST, AND THAT DISTINCTION IS WORTH MONEY. Every guide to Massachusetts family child care tells applicants to post the menu. 606 CMR 7.00 does not say so. The governing text is 606 CMR 7.12(7), which opens "If the licensee provides meals and snacks for children," and whose subparagraph (f) requires that "the licensee must prepare and make available to parents on request written menus, including snacks, for each week." Available on request. The obligation is to have the week's written menu in existence and to hand it over when a parent asks, not to display it. The retention half of the rule is where citations actually arise: 606 CMR 7.12(7)(g) requires that "the licensee must keep previous menus on file for one year." A provider who chalks the day's lunch on a board and wipes it clean each evening has posted more than the regulation asks and kept less, and it is the missing twelve months of menus a licensor writes up. Note the conditional opening: if parents supply all food, subparagraphs (a) through (g) of 7.12(7) do not bite, though 606 CMR 7.12(6) still requires "a method of providing nutritious meals and snacks to children whose parents fail to send meals and/or snacks from home," and 606 CMR 7.12(8) still requires that "meals and snacks provided by parents must be stored safely" with thermometers maintained in all refrigerators verifying 32 to 40 degrees Fahrenheit. Deviation from a planned menu triggers a notification duty, not a posting duty: 606 CMR 7.08(8)(k) requires the licensee to inform parents "whenever the program deviates from the planned menu." Group and school age programs carry extra structure at 606 CMR 7.12(15): "the licensee must designate, according to Department of Public Health (DPH) requirements, one person to be responsible for the food program. This designated person shall review and approve menus," plus a Food Service permit or evidence of local health department inspection for food prepared on site, and equivalent proof for food prepared off site. None of that is a posting either. If you choose to post the menu — and most providers should, because parents ask — understand that you are exceeding the regulation, and that doing so does not discharge the one-year file.
  • THE EVACUATION DRILL LOG IS KEPT AND PRODUCED, NOT POSTED. Massachusetts requires monthly evacuation drills and meticulous documentation of them, and requires that documentation to be retained rather than displayed. 606 CMR 7.11(7)(h) provides that "the educator must hold practice evacuation drills with all groups of children and all educators from each floor level of the approved space at least monthly. Drills must be held during different times of the program day, and must use alternative exits. The educator must document the date, time, exit route used, number of children evacuated and effectiveness of each drill." The record duty is separately imposed at 606 CMR 7.04(4)(a)3, which lists among the records the licensee must maintain "documentation of regular evacuation drills, as required by 606 CMR 7.11(7)(h)," alongside "daily attendance records indicating each child's attendance, including arrival and departure times" and "a method of knowing exactly who is present on the premises at any given point in the day." 606 CMR 7.04(4)(b) adds that all required records must be "legible and dated and signed by the individual making the entry" and "updated at least annually and whenever any material changes occur," and 7.04(4)(c) that attendance and educator records be kept at least five years. EEC's Emergency Preparedness in Child Care Programs policy FO-26-01, effective 1 September 2026, restates and tightens the drill rule without converting it into a posting: programs "must use that day's attendance record to check child and staff attendance during an evacuation practice drill, when gathered in a safe space post-evacuation, and upon return to the program," must log "the date, time, exit route used, number of children evacuated, and the success of the drill (e.g., how long it took to evacuate all children, any lessons learned to improve future drills)," and — the words that settle the question — "the program must retain the above log in a secure location and provide it to EEC staff upon request." A secure location is the opposite of a wall. FO-26-01 also requires a separate training log, stating that programs "must log all staff training dates and provide the log to EEC staff when requested," and provides that in a family child care program where the educator works alone without assistants, the educator "must review their emergency plan at least once annually, determine if changes are needed, and verbally attest to this review with their EEC licensor during licensing visits." The policy's own COMPLIANCE section names what a visit checks: the emergency preparedness plan, the practice drill log, the emergency preparedness training log, and confirmation that a PROTECT Act policy is in place.
  • THE MANDATED REPORTER NOTICE, THE EEC LICENSURE NOTICE AND THE COMPLIANCE-HISTORY STATEMENT ARE GIVEN IN WRITING BEFORE ENROLLMENT, NOT POSTED. This is the single most common misstatement about Massachusetts postings, and 606 CMR 7.08(6) settles it: "Written Information for Parents. The licensee must provide the following information to families in writing prior to enrollment of their child." Among the fourteen items enumerated are (l) "notice that child educators are mandated reporters and must, by law, report suspected child abuse or neglect to the Department of Children and Families"; (m) "notice that the program is licensed by EEC, including the telephone number and address of the EEC regional office responsible for the program"; and (n) "a statement that parents may contact EEC for information regarding the program's regulatory compliance history." Those are handout obligations with a deadline — before the child starts — not wall obligations. The same subsection carries (a) notice that parents are welcome to visit unannounced at any time while their child is present, (c) the medication administration policy, (d) the emergency procedures under 606 CMR 7.11(7)(f), (e) the transportation plan, (f) a calendar of closed days and hours, (g) the fee schedule including late payment, late pick-up, field trip and materials fees, (h) the program's plan to provide positive and consistent guidance to children, (i) the criteria for excluding children from care due to serious illnesses, contagious diseases and reportable diseases, (j) SIDS risk-reduction information, and (k) the children's-records procedures under 606 CMR 7.04(7) through (10). The mandated reporter duty itself is substantive and independent: 606 CMR 7.11(4)(d) provides that "every educator is a mandated reporter under M.G.L. c. 119, § 51A and must make a report to the Department of Children and Families whenever he/she has reasonable cause to believe a child in the program is suffering from serious physical or emotional injury resulting from abuse... or from neglect... no matter where the abuse or neglect may have occurred and by whom it was inflicted," and 606 CMR 7.11(4)(e) requires the licensee to notify EEC immediately after filing or learning that a 51A report has been filed. For large group and school age programs the same notice reappears as element 10 of the written health care policy required by 606 CMR 7.11(19)(a). Family child care licensees must additionally notify parents in writing "of the existence of a firearm in the family child care home... upon enrollment and/or when the firearm is brought into the family child care home" under 606 CMR 7.08(9)(a). What a monitoring visit checks is your enrollment packet, not your bulletin board — and 606 CMR 7.03(1)(c)4 requires a copy of that packet to be filed with your licence application.
  • THE EEC REGULATIONS THEMSELVES MUST BE ON THE PREMISES AND HANDED OVER ON REQUEST — THEY ARE NOT A POSTING, AND NEITHER IS YOUR DAILY SCHEDULE, YOUR DISCIPLINE POLICY OR YOUR ILLNESS-EXCLUSION POLICY. 102 CMR 1.03(6) provides: "Availability of Regulations. The licensee shall have a copy of the regulations applicable to any license issued by the Office on the premises of the program and shall make it available to any person upon request." On the premises, available on request — to any person, not merely to parents. A licensor who asks to see your copy of 606 CMR 7.00 and is told it is bookmarked on a phone will make a judgement about whether "a copy... on the premises" is satisfied; print it. Three items commonly listed as Massachusetts postings have no posting rule at all. First, the daily schedule: 606 CMR 7.00 nowhere requires a daily schedule to be displayed. The only schedule the regulations require to be posted is the staff work schedule at 606 CMR 7.10(8)(b)2, and that binds group and school age programs only. The daily schedule appears substantively at 606 CMR 7.11(13)(d), requiring the licensee to "include, as part of the daily schedule, an extended period of sleep, rest or quiet activities for children in care for longer than four hours," and in the child-record content at 606 CMR 7.04(7), which calls for "information about the child's daily schedule, developmental history, sleeping and play habits" — a record, not a wall. Second, discipline: 606 CMR 7.05 governs interactions and prohibits "spanking or other corporal punishment of children," but requires no posted discipline policy; what is required is that the program's plan for positive and consistent guidance be provided to parents in writing before enrollment under 606 CMR 7.08(6)(h), and that group programs make personnel policies including disciplinary procedures "available to all employees and prospective employees." Third, illness exclusion: 606 CMR 7.11(9)(a) requires the program to "follow exclusion policies for serious illnesses, contagious diseases and reportable diseases in conformance with regulations and recommendations set by the Division of Communicable Disease Control, Department of Public Health," and 606 CMR 7.08(6)(i) requires the exclusion criteria to be given to parents in writing before enrollment; 606 CMR 7.11(9)(b) adds a duty to notify all parents when a communicable disease or condition has been introduced into the program. None of the three is posted. Publishing them anyway is good practice and bad compliance strategy if it substitutes for the enrollment packet EEC actually inspects.

Enrollment forms for each child

  • THE FAMILY CHILD CARE LICENSE APPLICATION IS NOT A FORM — IT IS A LEAD TRANSACTION. Stop looking for a downloadable application PDF: EEC does not publish one. 606 CMR 7.03(1)(c) says the Department may issue a licence provided "the applicant submits a completed application on a form provided by the Department, the required license application fee and the following documents", and the form provided by the Department today is an online "new transaction" opened inside the Licensing Education Analytic Database (LEAD). EEC's own step page, "3. Submit your FCC license application", states it flatly: "You will start your Family Child Care (FCC) license application in the Licensing Education Analytic Database (LEAD). You have 90 days to complete the process." You get a LEAD account first, by requesting access at childcare.mass.gov/eeclead/s/reqaccess-lead-portal or by telephoning your EEC regional office; approval arrives by email with a password link. LEAD then asks you questions about yourself, your household members, and your indoor and outdoor spaces, and everything else — first aid and infant/child CPR certificates, the completed Family Child Care Medical Form, proof of completed online and in-person training, and "other forms about indoor and outdoor safety and program operations" — is uploaded into the LEAD Document Library rather than mailed. The 90-day clock is the trap. It runs from the opening of the transaction, not from the day you finish gathering documents, and applicants routinely open a transaction the week they decide to apply, then spend four months chasing a physician appointment and a fingerprinting slot. Open the transaction only when your medical form, your CPR and first aid cards and your training certificates are already in hand. The second trap is the fee. The Application Fee Schedule EEC still serves (file marker EECLicensingApplicationFeeSchedule20100217) sets Family Child Care Provider, new and renewal, at $100.00, Certified Family Child Care Assistant at $75.00, Upgrade within Licence or Certificate Period at $25.00, and Change of Address at $100.00, and both that schedule and the "Family Child Care Application Payment Instructions" sheet still instruct you to send "a check or money order, payable to the Commonwealth of Massachusetts" to a regional office address printed as a blank template — "Department of Early Education and Care, Regional Office Address, City, MA Zip Code". A 2010 paper-and-cheque instruction sheet sits on the same site as a 2026 online-only application; confirm the current payment channel with your regional licensor rather than posting a cheque into a template address. Note also what the cross-programme library, EEC Licensing Forms Across Program Types, actually contains today: only the Child Care Provider Safe Sleep Pledge Form 2023 with its ten translations, two Safe Sleep parent non-compliance letters, and the Application Fee Schedule. Nothing else. Anyone who tells you there is a general EEC forms library holding the application is describing a site that no longer exists.
  • THE BACKGROUND RECORD CHECK (BRC) CONSENT FORM — ONE PER PERSON, NOT ONE PER APPLICANT. This is the form Massachusetts applicants most often under-count, and 606 CMR 14.00: Criminal Offender and Other Background Record Checks defines exactly how far it reaches. 606 CMR 14.04 defines "Family Child Care Candidate" as "The family child care licensee; family child care assistants; and all household members and persons regularly on the premises of the family child care home 15 years of age or older, regardless of whether the individuals are present during child care hours." 606 CMR 14.05(2) repeats the categories: current licensees and applicants for licensure; household members 15 or older "regardless of whether such individuals are present while child care children are present"; persons regularly on the premises "including volunteers and other regular visitors" 15 or older; and all current and prospective assistants and volunteers "regardless of whether such individuals are present in an unsupervised capacity with children". EEC's own plain-language page spells out who "regularly on the premises" catches: anyone who "frequently and predictably visits your home. This can include a family member, house cleaner, or friend." Your adult son who sleeps there and never sees a child needs a BRC. So does the cleaner who comes every second Tuesday. You do not fill these in yourself. After you submit your LEAD licensing transaction, EEC emails you a BRC consent form, and, in EEC's words, "All household members and visitors 15 years and older will get their own consent form" by separate email. 606 CMR 14.07(2) makes the licensee responsible for submitting consent forms for all candidates with a validated signature, and 14.07(8) imposes the recurring duty applicants forget: "Family child care licensees must ensure that all family child care candidates (including household members and persons regularly on premises 15 years of age or older and family child care assistants) sign EEC's BRC consent form each year that they are present in the family child care program." 606 CMR 14.07(7) adds that failure to complete the consent form "is independent grounds for finding a candidate 'not suitable'" — you can be found unsuitable on paperwork alone, with a clean record. The check itself is fingerprint-based: Massachusetts State Police fingerprint scan for CORI, plus DCF supported 51B findings, plus SORI, plus an FBI national fingerprint check, the National Sex Offender Registry, and out-of-state record checks "for anyone living outside of Massachusetts in the past 5 years". 606 CMR 14.09(2)(a) is the sentence that governs your timetable: a BRC "must be complete with a final suitability determination issued on all household members and persons regularly on the premises 15 years of age or older ... before EEC will issue a license." One teenage stepchild who misses a fingerprinting appointment stops the whole licence, not just their own file.
  • THE CHANGES IN HOUSEHOLD COMPOSITION FORM — A SEVEN-DAY DUTY THAT SURVIVES YOUR LICENCE ISSUE DATE. EEC publishes this as page 3 of the Family Child Care Sample Forms Packet (file marker FCCSampleFormPacket20100203), and it is not an application document: it is the form you will need repeatedly across a three-year licence. The regulation behind it is 606 CMR 7.04(16)(b): "A family child care licensee must notify the Department within seven days of approval as a foster or adoptive placement resource, or of any change in the household composition." Seven days, in writing, and the clock is not forgiving. The sample form asks for the educator's name, address, date of licence expiration and Program ID number, then, for each addition, the name, date of birth, relationship, and "Number of hours at home during the child care day". EEC's covering letter to the packet defines the trigger broadly: "If there are any changes in your household during the 3 year licensing period (i.e. new baby, adopted child, foster children, any person 15 or older that will be present for more than 30 days) you must submit the required information to the Department", and the form itself repeats "including but not limited to new baby, adopted child, foster children, visiting relative, or any person who will reside in your home for more than 30 days". The form then carries the warning applicants ignore: "NOTE: Any person 15 years of age or older must also complete and submit a Background Record Check form." That is the real cost of the change — not the notice, but the fresh fingerprint-based BRC under 606 CMR 14.09(2)(b), which requires licensees to "disclose to EEC any changes to the composition to the family child care home, including the addition or removal of household members, or those regularly on the premises ... to ensure that a background record check is timely completed." A boxed reminder at the foot of the form covers the second duty most providers miss: "PLEASE REMEMBER TO ALSO NOTIFY PARENTS OF ANY CHANGE IN HOUSEHOLD COMPOSITION." That is 606 CMR 7.08(9)(b), which requires the provider to notify parents "of any changes in the regular composition of the household" and to "notify the parents of anyone regularly on the premises". Two separate notifications, to two separate audiences, from one event. The specific way applicants get this wrong is scope: they report a new baby and not the adult sister who moved in for a semester, or the boyfriend who is there five nights a week, on the reasoning that neither has anything to do with the children. 606 CMR 14.04 removes that reasoning — the standard is presence in the household, "regardless of whether the individuals are present during child care hours". Adjacent to this, 606 CMR 7.04(16)(c) requires that "The licensee must notify the Department whenever a firearm is brought into the family child care home", and 606 CMR 7.08(9)(a) requires written notice to parents of the existence of a firearm "upon enrollment and/or when the firearm is brought into the family child care home".
  • THE FAMILY CHILD CARE MEDICAL FORM — YOUR OWN HEALTH, SIGNED BY A CLINICIAN, NOT BY YOU. Still served under that exact title, in PDF and DOCX, from the Licensing forms for Family Child Care providers list, carrying the internal marker FCCMedicalForm20101021. It opens "Dear Physician/Health Care Professional" and is addressed to the clinician, not the applicant: "The Department of Early Education and Care requires that all persons who will be caring for children in their homes or working as an assistant in a licensed family child care home be examined by a physician/health care professional." The clinician records the patient's name, date of birth, address and date of examination; states, in their professional opinion, the patient's general physical and mental health; states whether the patient has "any limitations (for example side effects of medication, inability to lift, etc.) that would affect his/her ability to work with young children"; declares whether they are the treating clinician and for how long; and answers whether "this person been immunized in accordance with the requirements of the Department of Public Health (Mumps, Measles and Rubella)". It closes with signature, printed name, address, telephone and licence number. The authority is 606 CMR 7.09(11), which requires that "Prior to licensure or employment of any educator the licensee must obtain from a licensed health care practitioner: (a) evidence that the educator has had a physical examination within one year prior to employment; (b) evidence that the educator has been immunized in accordance with the recommendations of the Department of Public Health; (c) a statement of any limitations on the educator in working with children." Two dates decide whether your form is accepted. The physical examination must fall within one year before employment or licensure, so a form recording an examination fourteen months old is rejected even though it was signed last week. And 606 CMR 7.09(13) makes this recurring: "The educator must provide documentation of a current physical examination at the time of each license renewal" — a family child care licence runs three years under 606 CMR 7.03(5)(b), so this comes round every renewal, not once. The exemption is narrow and belongs to the clinician: 606 CMR 7.09(12) provides that evidence of immunity "shall not be required from any person who states in writing that vaccination or immunization conflicts with his/her sincere religious beliefs or who presents a written statement by a licensed medical professional that such vaccination or immunization is medically contra-indicated", and the form's own wording restricts the medical route to documentation "signed by a physician stating the specific medical exemption". One warning on the form's face: its explanatory paragraph tells the clinician that "EEC allows a licensee or a certified assistant to care for up to eight children under the age of fourteen without any assistance provided two of the children are school age." That reflects the 606 CMR 7.10(4)(e) tier only. It does not mention that licences for nine or ten children exist under 606 CMR 7.09(15)(b)3 and 7.10(4)(g). Do not take a capacity rule from a 2010 medical form. Upload the completed form to your LEAD Document Library; do not hand it to your licensor at the visit.
  • THE TAX CERTIFICATION STATEMENT (REAP) — THE FORM THAT ARRIVES BY EMAIL AFTER YOU THINK YOU HAVE FINISHED. 606 CMR 7.03(1)(c)6 requires the applicant to submit, with the application, "evidence of compliance with St. 1983, c. 233, Revenue Enforcement and Protection Program (REAP) on a tax certification form provided by the Department". REAP is the Commonwealth's statute conditioning state licences on state tax compliance, and it means your family child care licence is legally hostage to your Massachusetts tax filings. What EEC actually serves today is not a downloadable PDF. Its step-3 page states that after you submit your licensing transaction in LEAD, "EEC will email you 2 more forms", the first being the "Tax certification statement": "You will find a link to this form in your licensing transaction confirmation email from LEAD. By completing this form, you promise that you have filed and paid all required Massachusetts taxes." The second is the BRC consent form, which arrives in a separate email. The failure mode is procedural and silent. Applicants submit the LEAD transaction, see a confirmation, and treat the application as filed — then discover weeks later that the confirmation email itself contained a live link to an unsigned tax certification, and that the application has been sitting incomplete against a 90-day clock. Search your inbox and your spam folder for the LEAD confirmation the day it arrives, and open every link inside it. The substantive trap is different and more expensive. The certification is a promise "that you have filed and paid all required Massachusetts taxes". Applicants who have been minding children informally for cash for two or three years before deciding to become licensed frequently have unreported self-employment income, and signing this statement while that is true is not a paperwork problem. If you are in that position, resolve the filings with the Department of Revenue before you sign, not after. Note also that a family child care licensee under 606 CMR 7.04(15)(l) has an ongoing duty to "notify the Department in writing of any action brought against the licensee by the Internal Revenue Service" — the tax relationship does not end when the licence issues. And 606 CMR 7.03(3) requires you to "file a written application for renewal on forms provided by the Department and pay any required application fee not less than 30 days before the date of expiration of the current license", so the whole application chain, tax certification included, recurs every three years. One structural point worth knowing: 606 CMR 7.03(1)(c)1 requires "evidence of the applicant's compliance with the requirements of 102 CMR 1.05(1)". That cross-reference to a different CMR title looks like a stale citation to a repealed predecessor chapter and is not — EEC still serves 102 CMR 1, "Enforcement standards and definitions for licensure or approval", from its live EEC Laws and Regulations list. The 102 CMR reference is current; do not skip it on the assumption that everything moved to 606 CMR.
  • THE FAMILY CHILD CARE ENROLLMENT PACKET AND ITS FACE SHEET — DUE BEFORE THE CHILD'S FIRST DAY, NOT AFTER. EEC serves this under exactly that title, "Family Child Care Enrollment Packet", in English, Khmer, Portuguese and Spanish, with the internal marker FCCEnrollmentPacket20110406 — a 2011 document still in service in 2026. Its first page is headed FACE SHEET and carries the instruction that decides the deadline: "Please fill out these forms completely. If a question does not apply to your child, write N/A (not applicable). The forms must be in the educator's possession on or before the first day your child begins care." Not within a week of admission. On or before day one. The face sheet exists because 606 CMR 7.04(7)(a)1 requires each child's individual written record to contain "a face sheet or sheets" identifying: the name, date of admission, date of birth, age at admission, and primary language of the child and parent(s) if other than English; the parents' names, home addresses and telephone numbers; the parents' business addresses and telephone numbers; "the name, address and telephone number of the person to contact in case of emergency when the parent is unavailable"; "a physical description or a current photograph of the child"; the name, address and phone number of the child's physician or other source of health care; "information on allergies, special diets, chronic health conditions and/or any special limitations or concerns, including medications the child is taking at home or school and possible side effects of those medications"; "the child's anticipated days and times of attendance"; and, if applicable, the name of the school the child attends. The EEC face sheet tracks that list field by field, and adds a date-of-discharge and reason-for-discharge block, a nickname, an email address, per-parent "Where" and "Instructions" fields for the child-care day, and a boxed physical-description panel — eye colour, hair colour, sex, height, weight — beside an optional photograph. Read that panel carefully: the regulation gives you a choice, "a physical description OR a current photograph", and the packet marks the photograph "*Optional". You cannot be cited for declining to photograph a child, but you can be cited for leaving both blank. 606 CMR 7.04(7)(a)2 adds "copies of any custody agreements, court orders, and restraining orders pertaining to the child, when provided by the parent", and the packet carries this as a tick box. The retention rule is printed on the face sheet itself: "Children's Records must be maintained for at least five (5) years after a child has left the program", which is 606 CMR 7.04(4)(d). Two more traps. 606 CMR 7.04(4)(b) requires all records to be "legible and dated and signed by the individual making the entry" and "updated at least annually and whenever any material changes occur" — an undated face sheet is a finding. And EEC's covering guidance permits you to build your own: "You may make copies of these forms or create your own based upon the information they contain." If you do, every field of 606 CMR 7.04(7)(a)1 must survive the redesign.
  • THE EMERGENCY CONTACT AND AUTHORISED PICK-UP AUTHORISATION — TWO DISTINCT LISTS THAT PROVIDERS COLLAPSE INTO ONE. Massachusetts does not publish a standalone "emergency contact form"; the content lives on pages 1 and 2 of the Family Child Care Enrollment Packet, and it discharges two different regulatory duties that must not be merged. The first is 606 CMR 7.04(7)(a)1.d, which requires the face sheet to carry "the name, address and telephone number of the person to contact in case of emergency when the parent is unavailable". The packet renders this as a numbered list of two: "In the event of an emergency when I may not be reached, the Educator may contact the following individuals (in the order given) whom I authorize to take my child from the child care premises", each with address, telephone and cell phone. The second duty is 606 CMR 7.04(7)(a)6: the record must contain "a list of any person(s) authorized in writing by the parent to take the child from the program or receive the child at the end of the day". The packet carries this separately on page 2 — "I additionally authorize the following individual to take my child from the child care premises. (Please let me know at the beginning of the day when your child will be picked up by one of the authorized individuals.)" — with two further named adults. A grandmother who is an emergency contact is not automatically an authorised routine collector, and a neighbour authorised to collect on Fridays is not automatically an emergency contact. Get both lists filled in, on paper, for every child. Three sharp edges. First, expiry: 606 CMR 7.04(9) provides that "A written consent provided under 606 CMR 7.04(7)(a)3. through 12. shall be valid for one year from the date of its execution unless such consent is withdrawn, in writing, prior to that time." The pick-up authorisation at 7.04(7)(a)6 falls inside that range and dies on its first anniversary. Second, portability: 606 CMR 7.11(5)(d) requires that the following "are easily and readily available at all times, and accompany the children anytime they leave the facility in the care of staff": a first aid kit; "current family contact information"; information about allergies and known medical conditions; "emergency or life-saving medications, such as asthma inhalers and epinephrine auto-injectors, for any children for whom they have been prescribed"; telephone numbers for emergency services; and "authorizations for emergency care for each child". EEC's Children's Records Checklist gives this its operational name — "Emergency Card Information: Indicate with a √ that Emergency Card information is kept in the first aid kit." Your emergency cards live in the first aid kit and go out of the door with you; the file copy stays behind. Third, the posting duty at 606 CMR 7.04(14) is separate again: you must post, visible to parents, educators and visitors, a "Call 911" reminder with your programme's telephone number, address and location in the building, the Poison Control Center number, "the name and telephone number of the emergency back-up person", and, in a manner protecting each child's privacy, a list of emergency or life-saving medications specifying to which children they belong and a list of allergies and other emergency medical information.
  • THE TRANSPORTATION PLAN CONSENT AND THE NOTICE TO PARENT REGARDING SUPERVISION OF CHILDREN INVOLVING TRANSPORTATION. Two distinct transportation documents exist for Massachusetts family child care, and applicants routinely produce only the first. The first is the individual transportation plan consent, which 606 CMR 7.13(2) states in one line: "The licensee must have written parental consent for each child's individual transportation plan." 606 CMR 7.04(7)(a)3 puts that consent inside the child's record as "consent for the child's transportation plan, as required by 606 CMR 7.13(2)(e)". EEC collects it on page 2 of the Family Child Care Enrollment Packet under the heading TRANSPORTATION PLAN / AUTHORIZED PICK-UP, with paired arrival and departure tick lists — Parent Drop-Off or Parent Pick Up, Supervised Walk, Unsupervised Walk, Public/Private Van, Bus or Program Bus/Van, Private Transportation Provided by Parent — and a free-text block asking you to "indicate who will be supervising children during transport or prior to their arrival at the program, who supervises the walk from a bus stop". Note what that captures: a child who walks or arrives by school bus still needs a transportation plan. 606 CMR 7.13(1) requires the programme-level written plan behind the individual consents, describing "how children are transported to and from the program, in an emergency, and on field trips", addressing "the safety and supervision of children who walk and who arrive by public transportation", and including "any special arrangements for children with disabilities"; 606 CMR 7.08(6)(e) requires that plan to be given to families in writing before enrolment. The second document is the one applicants miss: "Notice to Parent Regarding Supervision of Children Involving Transportation" (marker FCCParentNoticeTransSupervision20100202), still served under that exact title. It exists for the moment a child uses specialised transportation and you must step outside to meet the vehicle, leaving the other children indoors. It binds you to six conditions in the first person — all children in care will be on the first floor level before you go outdoors; every child remaining is in a hazard-free environment; you have considered "the number, ages and needs of children in care", with special precautions where a child is "unusually aggressive or active or exhibits behavior difficulties"; you have notified the parents of all children in care and "must obtain written consent of all parents involved"; you "will remain in clear view of the family child care home ... and will not be more than 50 feet from the home"; and you will remain in the home until the vehicle arrives. It then carries a parental consent block naming the educator and the child left indoors. Two limits printed on it decide cases. "This applies to transportation vehicles only. Child care children who walk to or from the school bus stop may walk unescorted if the child's parent gives the provider written authorization." And the infant bar: a child younger than six months at enrolment, within their first six weeks in care, must be under direct visual supervision under 606 CMR 7.10(5)(a), so "I will not be able to accompany a child to and from a transportation vehicle unless I take the infant with me or I have an approved assistant". The consent you need is from every parent whose child stays behind, not only from the parent of the child being met.
  • THE PARENT HANDBOOK AND THE WRITTEN ACKNOWLEDGEMENT OF RECEIPT — A FORM YOU FILE WITH EEC AND A SIGNATURE YOU KEEP. EEC serves a fillable template titled simply "Family Child Care Parent Handbook" under the Family Child Care Recordkeeping Forms heading. It is not optional decoration: 606 CMR 7.03(1)(c)4 requires the application to include "a copy of the written information for parents, as required by 606 CMR 7.08(6)", so the handbook is an application document that a licensor reads before you open. 606 CMR 7.08(6) lists what must be provided to families in writing before enrolment, and every item must be traceable in your handbook: notification that parents may visit unannounced at any time their child is present and that parental input is encouraged; the frequency of children's progress reports; the medication administration policy required by 606 CMR 7.11(2)(a); the procedures for meeting potential emergencies under 606 CMR 7.11(7)(f); the transportation plan under 606 CMR 7.13(1); a programme calendar noting closed days and hours; the fee schedule "including any fees for late payment, late pick-up, field trips, special materials"; the plan for positive and consistent guidance; the criteria for excluding children for serious illness, contagious and reportable disease "in conformance with regulations and recommendations set by the Division of Communicable Disease Control, Department of Public Health"; SIDS risk reduction practices including back sleeping under 606 CMR 7.11(13)(e); the procedures relating to children's records under 606 CMR 7.04(7) through (10); notice that educators are mandated reporters who "must, by law, report suspected child abuse or neglect to the Department of Children and Families"; notice that the programme is licensed by EEC with the telephone number and address of the responsible EEC regional office; and a statement that parents may contact EEC about the programme's regulatory compliance history. The receipt is a separate artefact and lives on page 3 of the Family Child Care Enrollment Packet: "Written Acknowledgement of Receipt of Parent Handbook — I acknowledge that I have received a copy of the provider's parent handbook as well as information regarding lead poisoning prevention (may be included in the parent handbook)", signed and dated by the parent, directly above a second signature block, the Parental Visit Notice: "I understand that I may visit this family child care home unannounced at any time during the hours that my child is in care." 606 CMR 7.04(7)(a)15 requires the record to hold "documentation that the parent has been notified regarding his/her right to visit the program unannounced at any time while his/her child is in care, and has received the written information for parents required by 606 CMR 7.08(6)". Two cautions on the template. It is not current in its links: it directs parents to obtain the regulations at a mass.gov/Eeoe/docs path and the privacy policy at eec.state.ma.us, both of which are dead — replace them with the live download of 606 CMR 7 and the current EEC pages before you hand it out.
  • THE HEALTH CARE RECORD — PHYSICAL EXAMINATION, IMMUNISATION CERTIFICATION AND LEAD SCREENING, EACH ON ITS OWN CLOCK. There is no single EEC "child health form"; 606 CMR 7.04(7)(a)13 requires three separate clinician-sourced documents in every child's record, with three different deadlines, and mixing them up is the most common children's-record finding in Massachusetts family child care. First, immunisation: "a physician's, nurse practitioner's, or physician's assistant's certification that the child has been successfully immunized in accordance with the current Department of Public Health's recommended schedules". Note that the standard is the DPH schedule current today, not the schedule in force when the certificate was signed. Second, the physical examination: "a written statement from a licensed health care practitioner within one month of admission that indicates that the child has had a complete physical examination within one year prior to admission". Two nested windows — the examination within a year before admission, the statement in your hands within a month after it. Third, lead: "a statement signed by a physician or an employee of a health care agency obtained within one month of admission stating that the child has been screened for lead poisoning. Pursuant to Department of Public Health requirements, all children, regardless of risk, must be screened for lead poisoning at least once between the ages of nine and 12 months and annually thereafter at ages two and three. Children must also be screened at age four if they live in a community deemed at high risk for lead poisoning by the Department of Public Health. All providers must comply with the criteria for lead poisoning screening as set forth in 105 CMR 460.050." EEC's Children's Records Checklist reduces this to an operational rule: "Lead screening: If a child is younger than 9 months old, indicate NA (not applicable). If a child is 9 months or older, indicate with a √ that the documentation of lead screening is on file." Two exceptions sit at 606 CMR 7.04(8). The religious and medical exemption: "No child shall be required to have any such immunization if his or her parent(s) objects thereto, in writing, on the grounds that it conflicts with their sincere religious beliefs or if the child's physician, nurse educator, or physician assistant submits documentation that such a procedure is contraindicated." And the school-age shortcut, which saves providers a great deal of chasing: for school age children the licensee may accept either "a written parental statement that the required information is on file with the child's school" or copies of the immunisation, physical examination and lead screening records. The Family Child Care Enrollment Packet implements the shortcut with a parent-initialled certification: "I certify that documentation of physical examination and immunizations in accordance with public school health requirements, and lead poisoning screening in accordance with public health requirements are on file at my child's school." Then the ongoing duty at 606 CMR 7.04(7)(b)1 and 7.04(9): "documentation of annual physical examinations, updated immunizations and lead screening", with records reviewed and updated "no less frequently than once per year".
  • PARENTAL PERMISSION FOR MEDICATION AND RECORD OF MEDICATION ADMINISTRATION — ONE EEC SHEET CARRYING A CONSENT AND A LOG. Page 7 of the Family Child Care Sample Forms Packet holds this under exactly that title, and EEC's covering note defines its scope: "Use this form to get written permission for any prescription or non-prescription medication the parent/guardian may ask you to administer. Use the log to document what you have given." The consent half names the parent, the educator, the child, a start date and an end date, the name of the medication, and "dosage, # of times per day and # of days for that week the medication is to be administered", then asks a question providers skip past: whether the child has taken this medication before, and if not, the date and time the parent first gave it. That question exists because of 606 CMR 7.11(2)(i): "No educator shall administer the first dose of any medication to a child, except under extraordinary circumstances and with parental consent." The log half is a grid — Date, Time, Medication, Dosage, Method of Administration, Given By — answering 606 CMR 7.11(2)(j): "Each time medication is administered, the educator must document in the child's record the name of the medication, the dosage, the time and the method of administration, and who administered the medication." The consent-and-authorisation table at 606 CMR 7.11(2)(l) is where family child care differs sharply from centres, and it is worth reading column by column. All prescription medication: written parental consent yes; health care practitioner authorisation yes, "must be in original container with original label containing the name of the child affixed"; logging required, "name of child, dosage, date, time, staff signature; missed doses must also be noted along with the reason(s) why the dose was missed". Oral non-prescription: parental consent "renewed weekly with dosage, times, days and purpose"; practitioner authorisation "No in FCC" but yes in large and small group. Unanticipated non-prescription for mild symptoms such as acetaminophen, ibuprofen and antihistamines: parental consent "renewed annually"; practitioner authorisation "No in FCC". Topical non-prescription applied to open wounds or broken skin: consent renewed annually; "No in FCC". Topical non-prescription not applied to open wounds or broken skin, such as sunscreen, insect repellent and chapstick: consent renewed annually, no practitioner authorisation, and "No" logging "for items used solely for prevention". The weekly renewal on oral non-prescription is the trap — a signature obtained in September does not cover a cough syrup given in November. 606 CMR 7.11(2)(a) and 7.11(2)(g) require you to hold two written policies of your own — one on administration of prescription and non-prescription medication, one on medication disposal. 606 CMR 7.11(2)(k) adds a same-day verbal duty: tell the parent at the end of each day whenever a topical medication was applied to a diaper rash.
  • THE EEC INDIVIDUAL HEALTH CARE PLAN FORM — A REAL, NAMED, CURRENT EEC FORM, PUBLISHED INSIDE A POLICY. Massachusetts publishes this as "Individual Health Care Plan Policy and Form", a four-page document whose policy carries "Effective Date: October 29, 2010" and "Updated: June 30, 2022", with the blank form attached at page 3 under the heading "EEC Individual Health Care Plan Form". Do not go hunting for it in the forms list — it sits in the Licensing policies for Family Child Care providers list, which is why applicants report that no such form exists. The authority is 606 CMR 7.11(3): "The licensee must maintain as part of a child's record, an individual health care plan for each child with a chronic medical condition, which has been diagnosed by a licensed health care practitioner. The plan must describe the chronic condition, its symptoms, any medical treatment that may be necessary while the child is in care, the potential side effects of that treatment, and the potential consequences to the child's health if the treatment is not administered." 606 CMR 7.04(7)(b)5 puts "a copy of the child's individual health care plan, if applicable" in the ongoing records. The form's fields track the policy: name of child, date of birth, name and description of the chronic health care condition, symptoms, medical treatment necessary while at the programme, "Who has been trained and will be administering this treatment while the child is at the program", potential side effects, and potential consequences if treatment is not administered, plus the child's practitioner's name and contact details. The policy names the conditions that trigger it — "asthma, epilepsy, diabetes, serious allergies, anaphylaxis, physical disabilities, ADD/ADHD" — and expressly allows a substitute: "a program may accept equivalent physician's forms (i.e. asthma action plans, diabetes action plans, IEP with medical content) as long as those forms contain the same information that would be provided on the EEC form." An asthma action plan from the child's paediatrician is acceptable only if it names the trained administrator and states the consequence of non-administration; most do not. Three operational rules follow. Training: 606 CMR 7.11(3)(a)1 requires the educator to have "successfully completed training, given by the child's health care practitioner, or, with his/her written consent, given by the child's parent or the program's health consultant, that specifically addresses the child's medical condition, medication and other treatment needs", and the policy adds that "There must be one person trained in the implementation of a child's individualized health care plan whenever the child is in the care of the program". Expiry: 606 CMR 7.11(3)(a)4 provides that the written parental consent and practitioner authorisation "shall be valid for one year, unless withdrawn sooner", and the policy repeats that plans "must be renewed annually and following any change to the child's condition". Back-up supply: where a plan permits an older school age child to carry their own inhaler or epinephrine auto-injector under 606 CMR 7.11(3)(b), 7.11(3)(c) requires that "the licensee must maintain on-site a back-up supply of the medication for use as needed".
  • THE FAMILY CHILD CARE INCIDENT REPORT — IMMEDIATE TELEPHONE CALL FIRST, FORM WITHIN 48 HOURS SECOND. EEC publishes this as page 11 of the Family Child Care Sample Forms Packet under the heading "Department of Early Education and Care — Family Child Care Incident Report", with a field for your EEC Program ID number. It is dual-purpose, and the form says so: "Regulations require that Educators document certain incidents. Some require immediate notification to EEC while others must be kept in the records at the Program." The immediate-notification list printed on the form is death; serious injury; hospitalisation; "Medication error that results in a child receiving the wrong medication"; "The contagious illness of a child that is a reportable condition as set by the Division of Communicable Disease Control at DPH"; and "Any case in which a child receives emergency treatment by any medical personnel." Then: "Following immediate notification to EEC, this form must be sent within 48 hours to your Regional EEC Office." Check that list against 606 CMR 7.04(15) before you rely on it, because the regulation is broader in one place and narrower in another. 7.04(15)(a) requires immediate telephone report of "the death of any child which occurs while such child is in care, or resulting from an injury or event that occurred while the child was in care" and "any injury to any child which occurs during the hours while such child is in care and which requires hospitalization or emergency medical treatment". 7.04(15)(b) requires immediate report of a reportable contagious illness and of "any medication error which occurred while the child was in care and which: a. required hospitalization or emergency medical treatment, or b. which resulted in a child receiving the wrong medication". 7.04(15)(c) supplies the 48-hour rule: "The licensee must follow its immediate notification to the Department of any death, serious injury, reportable illness, or medication error with a written notice within 48 hours of making the original report." For everything below that threshold, the same form is your file copy: "If the incident did not involve one of the situations noted above (such as a minor injury or a program incident not involving an injury), use this form to document the incident and keep a copy in the appropriate child/ren's records." That is 606 CMR 7.11(5)(f): "The licensee must maintain a record of any unusual or serious incidents including but not limited to behavioral incidents, injuries, property destruction or emergencies. These reports must be reviewed by the licensee or Program Administrator on a monthly basis" — a monthly review a sole-operator family child care provider must still perform and be able to evidence. The parent side is 606 CMR 7.08(8): immediate notice of any injury requiring medical care beyond minor first aid or any emergency administration of non-prescription medication; notice at the end of the day of any minor first aid; and, critically, 7.08(8)(e), written notice "within 24 hours" of any of those. The form's own certification block closes the loop: "I also certify that I have notified the child's parent/guardian about the child's injury/illness."
  • THE EVACUATION LOG AND SMOKE DETECTOR LOG — MONTHLY, PER FLOOR LEVEL, AND CHECKED AT EVERY VISIT. EEC publishes both on page 4 of the Family Child Care Sample Forms Packet under the single heading "Evacuation/Smoke Detector Logs", with the warning that decides how seriously to take them: "You must conduct evacuation drills at least once (1) per month from each approved floor level. This sample form also contains a Smoke Detector Log to document your monthly test of your smoke detectors. These logs will be checked by a licensor on home visits." The evacuation grid has seven columns for each of the twelve months: Month/Date, Time, number of children, Floor Level, Exit Used, Meeting Place, and "Effectiveness of Drill (Including how long it took)". The smoke detector grid has four: Month/Date, Floor Level/Location, Smoke Detector Tested, Date Batteries Replaced. The authority is 606 CMR 7.11(7)(h): "The educator must hold practice evacuation drills with all groups of children and all educators from each floor level of the approved space at least monthly. Drills must be held during different times of the program day, and must use alternative exits. The educator must document the date, time, exit route used, number of children evacuated and effectiveness of each drill." Three requirements hide in that sentence and are the reason logs fail inspection. Every floor level of your approved space, so a two-floor licence means two drills a month, not one. "Different times of the program day", so a log showing 10:00 every month is a finding even though twelve drills were held — rotate through arrival, mid-morning, lunch, nap and late afternoon. "Alternative exits", so the log must show more than one exit used across the year. 606 CMR 7.04(4)(a)3 makes the log itself a required record — the licensee must maintain "documentation of regular evacuation drills, as required by 606 CMR 7.11(7)(h)" — and 606 CMR 7.04(4)(b) requires it, like every record, to be "legible and dated and signed by the individual making the entry". Back-fill a year of drills the night before a renewal visit and you have created a documentary problem on top of the compliance one. The log sits on top of the written plan required by 606 CMR 7.11(7)(f), which must cover "missing children, the evacuation of children from the program in the event of a fire, natural disaster, loss of power, heat or hot water or other emergency situation" and must include a method of obtaining information from local authorities on whether to evacuate or shelter in place, escape routes from each floor level approved for child care, "a designated meeting place outside and away from the child care home", a method of contacting the fire department after evacuation, a method of communicating with parents, and "a means to assure that no child is left in the home or facility after evacuation". Family child care carries one additional plan element at 606 CMR 7.11(17)(b): the plan must include "the name and telephone number of a potential emergency caregiver who will be available to arrive at the child care home within ten minutes of being summoned to provide temporary child care in case of a medical emergency". That person's name and number must also be posted under 606 CMR 7.04(14)(b). If your emergency back-up person lives twenty minutes away, you do not have a compliant plan.
  • THE DAILY ATTENDANCE RECORD — NO EEC FORM, A HARD FIVE-YEAR RETENTION, AND A SECOND REQUIREMENT MOST PROVIDERS MISS. Massachusetts publishes no attendance sheet for family child care; you build your own, and 606 CMR 7.04(4)(a) sets what it must contain. The licensee must maintain complete and accurate accounts, books and all records required by 606 CMR 7.00, "including but not limited to: 1. daily attendance records indicating each child's attendance, including arrival and departure times; 2. a method of knowing exactly who is present on the premises at any given point in the day." Read requirement 2 as separate from requirement 1, because it is. A sheet ticked at 9 a.m. records attendance; it does not tell a firefighter at 2:15 p.m. who is in the building. In a family child care home where children arrive from three different schools at three different hours, the "method of knowing exactly who is present" has to be live, not retrospective. 606 CMR 7.04(4)(b) requires the record, like every record, to be "legible and dated and signed by the individual making the entry" and "updated at least annually and whenever any material changes occur", and 606 CMR 7.04(4)(c) sets the retention: "Attendance records and educator records must be maintained for at least five years." Five years, not three, and not tied to the licence period. Children's records run on a different clock again under 7.04(4)(d) — "at least five years after a child has left the program" — so a child who leaves in 2026 has a record you hold until 2031 while your 2026 attendance sheets expire in 2031 too but from a different starting point. Providers who close their programme are caught here: 606 CMR 7.04(15)(n) requires written notice of intent to close to EEC and to parents "no less than 30 days prior to the anticipated closing", and the notice to the Department "must include a plan to notify parents and a plan for the storage and preservation of all required records". Closing does not discharge the retention duty. The attendance record also has to reconcile with two other documents a licensor reads alongside it. The first is the anticipated schedule on the child's face sheet: 606 CMR 7.04(7)(a)1.h requires "the child's anticipated days and times of attendance", and EEC's Children's Records Checklist asks you to tick "Schedule of days & times in care: Indicate with a √ that record indicates the current days and times that children are scheduled to be in care." The second is the assistant attendance log required by the Family Child Care Assistant Record: "Anytime a Regular or Certified Assistant is working in a Family Child Care Program, their attendance must be documented, including the specific hours they worked." That log is what proves you have stayed inside the limits of 606 CMR 7.09(15)(c)2.a — a regular assistant alone with up to six children "for up to 25 hours in a 12 month period, or up to eight hours in a seven day period". Without hour-level assistant attendance you cannot demonstrate compliance, and EEC's policy on Use of Regular Assistants makes the arithmetic cumulative across assistants: "no provider may leave their child care children with an uncertified assistant for more than a total of 8 hours per week or a total of 25 hours per year, no matter how many assistants he/she uses."
  • THE PHOTOGRAPH AND MEDIA CONSENT — NO EEC FORM EXISTS, AND THE REGULATION IS STRICTER THAN THE RELEASES SOLD ONLINE. Search the EEC forms library for a photo release and you will find nothing, in any language. That absence is not permission. 606 CMR 7.04(2) creates two distinct prohibitions and you need written consent to escape either. The first, 7.04(2)(a): "The licensee must not allow children to participate in any activities unrelated to the direct care of children without the written, informed consent of the parent(s)", and "Activities" is defined to mean, but not be limited to, "1. fund raising; 2. publicity, including photographs and participation in the mass media, and 3. screening, research or unusual treatment." The second, 7.04(2)(b), is absolute in form and independent of the first: "The licensee must not allow any person to produce or distribute a likeness of any child in the program for any purpose without the written informed consent of the child's parent." Note "any person", which reaches a visiting grandparent with a phone as much as it reaches you, and "produce or distribute", which means the taking of the photograph is itself the regulated act, not only its publication. Note "likeness", which is wider than photograph and catches video, a painted portrait, and a recognisable image on your website. And note "written informed consent" — informed means the parent knows what is being produced and where it goes, so a one-line tick box saying "I consent to photographs" does not obviously discharge it. Build a consent that separates the uses: internal documentation and daily-sheet photographs shared only with that child's own parent; photographs displayed on the premises where other families will see them; images used in publicity, on a website, on social media, or in any mass medium; and participation in fund raising. A parent who is content with the first can refuse the last, and the regulation contemplates exactly that granularity. Two further consents in the same family live at 606 CMR 7.04(7)(a)9: "written informed consent for observation of children by anyone other than program staff or the parents of children in the program, if applicable. For observations in which there is no interaction between the child and the observer and no identification of individual children, a general permission may be obtained. When there is interaction between the child and the observer or when individual children are identified to an observer other than parents of children in the program, a specific individual informed consent must be obtained." A student teacher shadowing you, a college researcher, a photographer from a local newspaper — each needs the specific version, not the general one. The expiry rule at 606 CMR 7.04(9) reaches all of this: a written consent given under 606 CMR 7.04(7)(a)3 through 12 "shall be valid for one year from the date of its execution unless such consent is withdrawn, in writing, prior to that time". Your media consents therefore have to be re-signed at the annual record update, alongside everything else. One place where the enrolment paperwork touches this without being a release: the face sheet in the Family Child Care Enrollment Packet offers "*PHOTO OF CHILD (*Optional) PLUS PHYSICAL DESCRIPTION", because 606 CMR 7.04(7)(a)1.e permits "a physical description or a current photograph of the child". That identification photograph is not consent to publish anything.
  • THE ANNUAL UPDATE FORM AND THE CHILDREN'S RECORDS CHECKLIST — THE TWO DOCUMENTS A LICENSOR ASKS FOR FIRST. Both are real EEC documents under those exact names. The Annual Update Form is page 2 of the Family Child Care Sample Forms Packet, and it exists because of 606 CMR 7.04(9): "Children's records must be reviewed and updated as necessary, but no less frequently than once per year. A written consent provided under 606 CMR 7.04(7)(a)3. through 12. shall be valid for one year from the date of its execution unless such consent is withdrawn, in writing, prior to that time." Every consent in that range dies annually: the transportation plan consent, permission to transport to a medical facility and receive emergency medical treatment including epinephrine auto-injection, permission to administer basic first aid and CPR, the authorised pick-up list, consent to off-site activities, consent for older school age children to leave the programme, observation consent, swimming pool consent, consent for unanticipated non-prescription and topical non-prescription medication, and overnight room-sharing consent. The EEC form condenses the renewal into one signature: "By signing this form, you are stating that you give the educator(s) permission to: 1. Transport your child to a medical facility and receive emergency medical treatment***; 2. Administer basic first aid and/or CPR on your child; 3. Take your child off the premises of the family child care home for the specified excursions; 4. Apply the topical medications listed on the applicable permission form; 5. Use the on-site swimming pool (if applicable)." The asterisked footnote is the part that trips people: "The actual permission forms on the Emergency Card/Form that the provider must take with her when she leaves the premises must be signed again." The emergency card that travels in your first aid kit under 606 CMR 7.11(5)(d) needs its own fresh signature; the omnibus annual update does not refresh it. The Children's Records Checklist and Instructions (marker FCCRecordChecklist/Instructions20150427) is the two-page grid you complete for the licensor, and its instruction page states the deadline plainly: "A copy of the current checklist must be submitted to the licensor on the day of the licensing study. (Please note: if you leave a blank space on the checklist, this will indicate that the information is not on file.)" A blank is read as a missing document, not as an oversight. Its twenty rows are the practical index of 606 CMR 7.04(7): child's name and date of birth, date of admission, parents' daytime phone numbers, emergency contact and authorised pick-up person, transportation plan, schedule of days and times in care, acknowledgement of parent handbook, parental visit notice, physician and health care information, individual health care plans if applicable, developmental history, general permission, "CPR/1st Aid/Emergency Medical Consent & Release", emergency card information, date of last physical exam, immunisations, lead screening, annual update, custody agreements if applicable, and date of last progress report. The developmental history row is the one most often blank: 606 CMR 7.08(5)(e) requires that the developmental history "must be updated annually and maintained in the child's record", and the Family Child Care Enrollment Packet supplies the four-page instrument.
  • THE ASSISTANT PAPERWORK — A CERTIFIED ASSISTANT APPLICATION, AN ASSISTANT RECORD, AND A BRC, BUT NO FORM CALLED AN "ASSISTANT APPROVAL REQUEST". Massachusetts family child care has two grades of assistant and only one of them applies to EEC. 606 CMR 7.09(15)(c)1 describes the certified assistant: an educator meeting the licensee's own qualifications who "may replace the licensee at any time, provided notice is given to parents in advance, in accordance with 606 CMR 7.08(8)(c)", and an educator qualified for six or fewer children who "may substitute for a provider licensed to care for up to ten children for up to 25 hours in a 12 month period". 606 CMR 7.09(15)(c)2 describes the regular assistant, "an educator whose qualifications are neither equal to nor greater than the licensee's qualifications", who "may provide care under the general supervision of the licensee", who "may be alone on the premises with up to six children for up to 25 hours in a 12 month period, or up to eight hours in a seven day period, provided s/he is currently certified in first aid and CPR", and who, in a programme licensed for seven or more children, "may provide care only under the supervision of a licensee or certified assistant". Certification is an EEC transaction with a fee: the Application Fee Schedule sets "Certified Family Child Care Assistant = $75.00", and EEC still serves a "Certified Assistant Application Payment Instructions" sheet directing a $75 cheque or money order payable to "Commonwealth Of Mass". There is no published EEC form titled an assistant approval request. What you keep on site instead is the Family Child Care Assistant Record (marker FCCAssistantRecord20100326), served under that exact title, which EEC describes as "a helpful outline of what is required for an assistant's file as well as what aspects of the program an assistant must be oriented to before working with an educator" and which "can be used as a checklist or top sheet to be kept in the assistant's record". Its documentation list is your compliance evidence: copy of EEC certification or approval; copies of first aid and CPR cards; copy of physical and immunisations; plan for needed professional development training; copy of driver's licence and car insurance if transporting children; evidence of training in medication administration if administering medication; and the attendance log. Three warnings. The record carries a miscitation on its face, "Regulation 7.09(15)(3)(f)", for professional development; the real provision is 606 CMR 7.09(15)(f), five hours a year for assistants working more than 25 hours a year but under ten hours a week, ten hours a year above ten hours a week, with at least a third addressing diverse learners. The record notes that "As EEC does not require assistants to submit much of the information listed below, it is the assistant's responsibility to submit copies of documentation to the educators they work with. Licensors will review assistant files during licensing visits" — the gap is yours to close. And 606 CMR 14.09(2)(c) bars the assistant from starting: a BRC "must be complete with a final suitability determination issued ... before EEC will issue a certificate or approval". Finally, a reminder printed on the Assistant Record itself: "all parental permissions for the children in care must include any assistants that will be working in the program" — every consent naming only you must be re-signed to name the assistant too.

What's specific about getting licensed in Massachusetts

Massachusetts is unusual in two ways that trip up home providers. First, there is no 'small' vs 'large' family child care license and no application fee — the whole thing runs on one FCC license through the LEAD system — but the licensed capacity is not something you choose; EEC assigns it based on your space AND the number of EEC-qualified educators present, and you cannot exceed six children unless you add a Certified or Regular Assistant (a second vetted adult), not just more square footage (606 CMR 7.10(4)). Second, and the biggest trap: under the 'Determining Capacity' rule at 606 CMR 7.04(5)(c), your own children living in the home who are younger than school age (plus home-schooled children of any age and certain other resident and visiting children) count toward the 10-child cap and the infant/under-two sub-limits at 606 CMR 7.10(4). A provider with a toddler and an infant of her own has already spent much of a one-educator home's room for children under two. Add that ~16.5 hours of training plus a PQ number and StrongStart account must be finished BEFORE you can even open the application, and the realistic path is months, not weeks.

Common mistakes when getting licensed in Massachusetts

Your own young kids eat your capacity

Under 606 CMR 7.04(5)(c) EEC counts children who live in your home and are younger than school age (plus home-schooled children of any age, resident children under 10 present for long stretches, and non-resident children under 14 present during care) toward your licensed capacity and toward the 'younger than two' and infant limits. With one educator you may have no more than three children under two (including at least one toddler walking independently) — so two little ones of your own can leave almost no room for paying infants/toddlers unless you add a qualified assistant.

Six is a hard wall without a second qualified adult

Going from six to seven-plus children is not a space upgrade — 606 CMR 7.10(4) requires two educators for 7-10 children (and three educators to carry six infants). That second person must be an EEC Certified or Regular Assistant who clears their own BRC; a Regular Assistant left alone with up to six children (limited to 25 hours in a 12-month period, or up to 8 hours in a 7-day period) must hold current first aid and CPR (606 CMR 7.09(15)(c)). Budget time and money for their qualification, not just for enrollment.

Training and accounts are gatekeepers, done BEFORE you apply

You must finish ~16.5 hours (PPT 1 & 2 at 1.5 hours, EEC Essentials 2.0 at 12 hours, and the in-person 3-hour Potential Educator Meeting), obtain a PQ number, and set up a StrongStart account before the LEAD application. Miss the sequence and you stall. Once you do start in LEAD you have a 90-day clock to complete everything.

Everyone 15+ in the household must pass a BRC — including visitors

The background record check under 606 CMR 14.00 covers not just you but every household member and every frequent/predictable visitor age 15 or older, whether or not they help with childcare — mass.gov confirms each gets their own consent form. One roommate, adult child, or regular guest who won't consent or who has a disqualifying record can block your license.

How long it takes and what it costs in Massachusetts

Timeline: EEC states the licensing process takes about 2 to 6 months. Front-loaded steps (getting a PQ number, ~16.5 hours of training including a scheduled in-person Potential Educator Meeting, plus first aid/CPR and the medical form) run before you open the LEAD application; once started you have 90 days to finish, then wait for BRC clearance and a scheduled pre-licensing home visit (usually 1-2 hours, with follow-up items to cure before the license issues).

Cost: No cost to apply for the FCC license (mass.gov states there is no application fee). Real out-of-pocket costs are for prerequisites: basic first aid and infant-and-child CPR certification (commonly ~$70-$120, varies by provider), the healthcare-professional visit to complete the Family Child Care Medical Form, and fingerprinting for the BRC national criminal history check (fee varies — confirm the current amount with EEC and its fingerprinting vendor). EEC training (StrongStart courses and the Potential Educator Meeting) is generally provided at no charge.

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Massachusetts home daycare licensing — FAQ

How many children can I care for in a Massachusetts home daycare?

Ten is the answer, but ten is a regulatory number that survives a statute which no longer says it, and the reason that matters to you is that the statute was amended in 2024 while the regulation was not. Start with what is in force. The Department of Early Education and Care defines your business at 606 CMR 7.02 as "Family Child Care - Temporary custody and care provided in a private residence during part or all of the day for no more than ten children younger than 14 years old or children younger than 16 years old if such children have special needs. Family child care shall not mean an informal cooperative arrangement among neighbors or relatives, or the occasional care of children with or without compensation therefore." Ten. The same section defines the group instrument that gets you there: "Multi-age Grouping - Ten or fewer children from birth through 13 years (or 16 years, if such children have special needs) assigned to a single group." Ten again.

And it defines what a licence number actually is: "Licensed Capacity - Determination by the Department of the number of children that a program can care for at any one time under 606 CMR 7.00." That definition is worth reading twice, because the ceiling on your licence is not ten; it is whatever number the Department writes on your licence, and ten is only the maximum it may write. 606 CMR 7.03(2) tells you how that number is set: "Programs will be licensed for the maximum number of children who may be in the care of educators at any one time, taking into consideration the size and layout of the physical facility, the number and qualifications of educators, the equipment and resources available to the children, the individual needs and characteristics of the children served, and the building certificate capacity, if applicable. At no time shall a program admit, supervise or provide care for more than the maximum number of children indicated on the license." Five inputs, and any one of them can hold you below ten: your square footage, your staffing, your equipment, the children you actually serve, and your building certificate.

The last sentence is the enforcement hook, and it is written in the absolute — admit, supervise, or provide care. A child you are merely supervising for an hour as a favour is over capacity if the number on the licence is full. The three licensable tiers are not created by the capacity rule at all; they are created by your own credentials in the educator-qualification section, and applicants routinely discover this after signing a lease on a bigger house. 606 CMR 7.09(15)(b)1. sets the entry tier: "an applicant for a license to care for six or fewer children must have at least the following: a. one year of experience as a parent; or b. one year of full-time experience, or the equivalent, in caring for children younger than 12 years of age; or c. nine months of full-time experience in caring for children younger than 14 years of age and completion of 15 hours of training, approved by the Department, not including the EEC educator orientation; or d. six months of full-time experience in caring for children younger than 12 years of age and completion of 30 hours of training, approved by the Department, not including the EEC orientation; or e. qualification as a teacher or site coordinator by EEC." 606 CMR 7.09(15)(b)2. sets the middle tier: "An applicant for a license to care for seven or eight children, at least two of whom must be school age, must have evidence of having completed within one year prior to application a pre-service training approved by the Department; and either a. two years of experience as a family child care licensee or certified assistant; or b. one year of experience as a family child care licensee or certified assistant and i. one additional year caring for unrelated children in a group setting; or ii.

EEC certification as a teacher or site coordinator", with "An additional three credits in education or early childhood education may substitute for six months of the required additional experience" and six credits for nine months. 606 CMR 7.09(15)(b)3. sets the top tier: "An applicant for a license to care for nine or ten children must have evidence of having completed within one year prior to application a five hour pre-service training approved by the Department and either a. three years of experience as a family child care licensee or certified assistant, or b. one year of experience as a family child care licensee or certified assistant; and one of the following: i. two additional years caring for unrelated children in a group setting, which may include experience as a family child care licensee or certified assistant; ii. EEC certification as a teacher or site coordinator and one additional year of experience caring for unrelated children in a group setting", with the same credit substitutions. Read the tiers as a clock. A first-time applicant whose only qualifying experience is "one year of experience as a parent" is licensable for six.

The eight-child tier requires prior experience as a family child care licensee or certified assistant — a credential you cannot hold on day one — so nobody in Massachusetts is licensed for eight at first licensure without having first worked in someone else's licensed home or held their own licence. The ten-child tier requires three years of it. The single most expensive planning error here is buying or renting for ten while qualifying for six. Note the structure inside 7.09(15)(b)2.: the licence itself is described as a licence "to care for seven or eight children, at least two of whom must be school age". The school-age composition is welded into the licence, not merely into the daily group. That matches the ratio table at 606 CMR 7.10(4)(e), where "seven or eight children" with "one educator" carries the condition "All children over capacity of six must be school age", and "School Age Child" is defined at 606 CMR 7.02 as "A kindergarten child, or a child who is attending a public or approved private elementary school", with "Kindergarten Child" defined as "A child who is five years old or who will attend first grade the following year in a public or private school".

If your two school age children age out of your programme in June and you replace them with preschoolers in September, you have not merely broken a ratio row, you are operating outside the licence you hold. Now the counting rule, which is where Massachusetts takes seats away from you before you enrol anyone. 606 CMR 7.03(5)(c), headed "Determining Capacity", provides that "The following children will be considered to be in the care of educators: 1. every child who lives in the family child care home who is younger than a school age child; 2. every child who lives in the family child care home who is home schooled, regardless of age; 3. every child younger than ten years old who lives in the residence and is present for more than three consecutive hours on each of five consecutive days, excluding weekends and holidays; 4. every person younger than 14 years old who does not live in the residence and is present during the time that child care is being provided; 5. during overnight care, every person younger than 18 years old who is present in the home." Five separate counters, and applicants read only the first.

Your own preschooler occupies a paid seat. Your home-schooled twelve-year-old occupies a seat regardless of age, and this is the clause that catches families who switch to home schooling mid-licence and never tell the Department. Your nine-year-old who is home for three hours a day for a week of school vacation occupies a seat under clause 3. Your teenage nephew who drops in during care hours occupies a seat under clause 4, because clause 4 says "every person younger than 14 years old who does not live in the residence and is present during the time that child care is being provided" — presence, not participation. And if you are approved for overnight care, clause 5 pulls everyone under eighteen in the house into the count for those hours. Build your enrolment model by subtracting your own household from ten first. The physical plant is the second hard ceiling, and it is arithmetic you can do before you apply. 606 CMR 7.07(15)(c) provides: "The licensee must provide: a. a minimum of 150 square feet of approved activity space for one or two children; b. a minimum of 225 square feet of approved activity space for three to six children; c. 35 square feet of approved activity space for each child when serving seven to ten children."

Ten children therefore require 350 square feet of approved activity space, and "Approved Activity Space" is defined at 606 CMR 7.02 as "The indoor and outdoor areas determined by the Department to be safe and appropriate for children in an early education and care program. This space shall include only usable floor space exclusive of hallways, bathrooms, and portions of rooms or areas that contain furniture or equipment suitable only for adult use." Hallways, bathrooms and the corner occupied by your dining set do not count. Two further limits at 606 CMR 7.07(15)(c) narrow it again: "The approved activity space counted toward the square footage requirement can be located on no more than two adjacent floors" and "No more than one area that is used exclusively for napping purposes can be counted toward meeting the square footage requirements." Outdoors, 606 CMR 7.07(7) requires the licensee to "maintain, or have access to, an outdoor play area of at least 75 square feet per child who is outside at any one time" — note "at any one time", so a staggered outdoor schedule can lawfully shrink the area you must provide, and note also that the rule accepts access to space you do not own.

Egress is a capacity gate too: 606 CMR 7.07(15)(b) requires that "Family child care homes must have at least two separate exits to the outside, approved by the Department", and that a basement approved for child care "must have at least two separate means of egress directly to the outside", with a grandfather clause for homes "initially licensed prior to October 10, 2003, and which remains continuously licensed" that dies "in the event of substantial renovations to the basement". There is one building-code threshold that a family child care home should never cross, and knowing where it sits protects your budget. 606 CMR 7.07(2) provides: "Every program that is not located in a residence and every program that has a licensed capacity of more than ten children must provide a certificate of inspection from the Department of Public Safety or the local building inspector certifying that the facility complies with the applicable 780 CMR: The Sate Building Code." Ten is precisely the number at which the state building-code certificate is not yet required. That is not a coincidence; it is the design of the family child care tier.

Any plan that puts an eleventh child in your house converts your home into a facility that must satisfy 780 CMR, and in most Massachusetts housing stock that is a renovation, not a form. Now the statute, and the amendment the coordinator's brief and most of the press coverage get slightly wrong. M.G.L. c. 15D, § 1A defines "Family child care home" as "a private residence which, on a regular basis, receives for temporary custody and care during part or all of the day, children under 7 years of age, or children under 16 years of age if those children have special needs, and receives for temporary custody and care for a limited number of hours children of school age under regulations adopted by the board. The total number of children under 16 in a family child care home shall not exceed 6, including participating children living in the residence." Six, with your own children counted, and that six is still in the statute today. It defines separately "Large family child care home" as "a private residence which, on a regular basis, receives for temporary custody and care during part, or all of the day, children under 7 years of age, or children under 16 years of age if such children have special needs, and receives for temporary custody and care for a limited number of hours children of school age under regulations promulgated by the board. A large family child care home shall have at least 1 approved assistant when the total number of children participating in child care exceeds 6." Read that definition to the end: it carries no number.

It used to. Section 25 of Chapter 140 of the Acts of 2024, the fiscal year 2025 general appropriation act approved in part by the Governor on 29 July 2024, provides in terms: "Section 1A of chapter 15D of the General Laws, as appearing in the 2022 Official Edition, is hereby amended by striking out, in lines 98 to 100, inclusive, the words ', but the number of children under the age of 16 in a large family child care home shall not exceed 10, including participating children living in the residence'." The legislature deleted the ten from the statute and left the assistant requirement standing. It did not delete the six from the family child care home definition, and it did not raise anything: after that amendment the only place a Massachusetts ceiling of ten still lives is 606 CMR 7.02 and the Multi-age Grouping table at 606 CMR 7.10(4). Press coverage that says the fiscal 2025 budget "removed the statutory cap of 10 children in family childcare programs" is describing the right act and the wrong definition — the cap struck was the large-family-home cap, and the six-child cap on the plain family child care home is still on the books, contradicted daily by a regulation that licenses to eight and ten.

Treat the statutory six as a dead letter that has not been repealed, and rely on your licence. The practical effect of the deletion is that EEC can now move the ceiling by regulation instead of by legislation, and it has started to. In June 2026 the Department announced a family child care capacity pilot to test enrolment of twelve children in a small number of homes; as reported by State House News Service, the pilot "will evaluate whether the cap can be raised to 12 'while maintaining high standards for quality, safety, and regulatory compliance,' EEC said", will include roughly twenty-five to thirty programmes, and is open only to providers who "hold a license in 'good standing,' be currently licensed and have 10 children enrolled, and have operated continuously with a licensed capacity of 10 children for at least three years". The legal vehicle for such a thing already exists in your regulation: 606 CMR 7.03(4)(a) provides that "Proposals for pilot or demonstration projects for the innovative delivery of services related to a program will be considered by the Department upon written request.

However, no project shall be implemented without prior written approval of the Department" and that "Projects shall be implemented only on an experimental basis for a specified period not to exceed the term of the license." Two things follow for an applicant. Twelve is not available to you: you cannot reach the pilot's eligibility floor without three continuous years at a licensed capacity of ten. And nothing about the pilot is codified — as of today the Department's own proposed-rulemaking page states that "Department of Early Education & Care does not have any proposed amendments to its regulations at this time", so the number you will be licensed for in 2026 is six, eight or ten. The other route past a written rule is the variance, and it is narrower than people hope. 606 CMR 7.03(4)(b) allows the Department "upon written request" to "grant a variance of any provision contained in 606 CMR 7.04 through 7.13 and allow an alternative method for compliance with such regulation if the applicant for the variance provides clear and convincing evidence, including, at the request of the Department, expert opinion which demonstrates to the satisfaction of the Department that the applicant's alternative method will comply with the intent of the regulation".

Note the range: 7.04 through 7.13. The definition of family child care at 606 CMR 7.02 and the licensure provisions at 606 CMR 7.03 are outside the variance power, so the ten in the definition cannot be varied even though the square-footage rule at 7.07 and the ratio table at 7.10 can be. Variances are also time-limited — "for a specified period of time not to exceed the term of the license" — and revocable: "If the Department receives or finds evidence that the conditions of the variance have been violated, the variance will be rescinded." Capacity moves downward more easily than upward, and the mechanism is worth knowing before you are on the receiving end of it. EEC's licensing policy statement "Freezing or Reducing Enrollment" (document code EECFreezeReduceEnrollment20110714) states that "When EEC finds that a program or facility is not in compliance with regulations governing the licensure of such program or facility, in order to ensure that the program is soundly administered, EEC may impose a variety of remedial requirements, including prohibiting the enrollment of new children and reducing the number of children a program is licensed to serve", and lists the triggers, which include "insufficient numbers of staff, unqualified staff", "enrollment in excess of the licensed capacity", and "the facility or program has enrolled more children than allowed by the program's building certificate".

The same policy warns that "The enrollment freeze or capacity reduction will be noted in the EEC licensing database and will become part of the program's licensing history" and "will also be reflected in the current EEC licensed program listing on the EEC website", and that "During any enrollment freeze, no new children unless otherwise approved by EEC may be enrolled; no previously terminated children may be re-enrolled; and no vacancies resulting from a child who is graduating, terminating or otherwise leaving the program may be filled." It also states that "EEC may issue a license with a reduced capacity if there is evidence that the program will be unable to continue to serve the number of children for which it had been previously licensed." One over-enrolment visit can therefore cost you the tier you spent three years qualifying for, publicly, in the state's own consumer-facing directory. Three structural limits round out the ceiling. First, one licence per person: 606 CMR 7.03(5)(f) says flatly "A family child care licensee may not hold more than one family child care license."

You cannot double your capacity by licensing a second home in your own name. Second, where the care may happen: 606 CMR 7.03(5)(e) provides that "family child care may only be provided in a dwelling that provides complete independent living facilities for one or more persons including permanent provisions for living, sleeping, eating, cooking, and sanitation", and that the dwelling must either "be occupied for living purposes on a full time basis by either the licensee, or an individual personally known to the licensee, as the occupant's legal residence" or be unoccupied and sit on the same property as the licensee's single-family home, or in the other half of a duplex the licensee lives in, or in a structure "with a maximum of three stories, with no more than one dwelling unit located on each floor level" where the licensee lives in another unit. Third, duration: 606 CMR 7.03(5)(b) gives family child care "A regular license or approval is valid for three years from the date of issuance unless revoked, suspended, or made probationary" — three years, not the two that centres get under 606 CMR 7.03(6)(b)2. One capacity is set outside the daytime table entirely.

If you intend to offer regular overnight care — defined at 606 CMR 7.02 as "Care provided to any child care child between the hours of 11:30 P.M. and 6:00 A.M. more than one day per week for more than eight weeks in a 12-month period" — then 606 CMR 7.11(15)(b)2. requires that "The educator must submit a written plan for approval to EEC and must receive EEC written approval prior to providing any regular overnight care", and that plan must state "the maximum overnight capacity being requested and the age range of children expected to be in care", must include "a floor plan, with designated exit routes, for the entire building where children are located, and the rooms used by children for sleeping", and must give "a specific description of how an evacuation would occur when the maximum capacity of children and educators is present". Your overnight capacity is a separately approved number, and it is bounded further by the counting rule at 606 CMR 7.03(5)(c)5., which during overnight care counts "every person younger than 18 years old who is present in the home". Finally, the good news that most applicants never hear, and that has saved Massachusetts home programmes from the zoning fights that kill them elsewhere.

Section 76 of the same Chapter 140 of the Acts of 2024 rewrote the fifth paragraph of M.G.L. c. 40A, § 3 to read: "Family child care home and large family child care home as defined in section 1A of chapter 15D shall be an allowable use and no city or town shall prohibit or regulate such use in its zoning ordinances or by-laws." No city or town may cap you, zone you out, require a special permit, or attach conditions through its by-law. If a building department tells you a home programme needs a special permit or a change of use, that paragraph is your answer. What still binds is the state building code above ten children under 606 CMR 7.07(2), the fire-code evidence required by 606 CMR 7.07(3) — "The licensee shall submit evidence of compliance with applicable fire codes" — the well-water approval at 606 CMR 7.07(4), and the lead-paint disclosure that 606 CMR 7.03(5)(a)1. requires you to file with your application. Two closing precautions on sourcing, because the wrong document is easy to find here. The Secretary of the Commonwealth's State Bookstore catalogue still sells "102 CMR 1.00 - 12.00", described as including "Standards for the Licensure of Family Child Care and Large Family Care Homes" — that is the pre-2010 Office of Child Care Services regime, superseded when 606 CMR 7.00 took effect, as its own transition clause at 606 CMR 7.14(3) records: "Any license or approval issued under the provisions of 102 CMR 7.00 or 8.00 is in effect immediately prior to January 22, 2010 shall, notwithstanding its expiration date, remain in effect, unless suspended or revoked, until a new license or approval is issued".

Anything citing 102 CMR 8.00 for a large family child care home is describing a dead licence type; 606 CMR 7.00 does not use the phrase "large family child care home" anywhere in its text, only the statute does. And the number on your licence is the only number that is enforceable against you: 606 CMR 7.04(14)(d) requires you to post "the current license or approval" in an area easily visible to parents, educators and visitors, which means the ceiling you are inspected against is the one hanging on your own wall.

What are the adult-to-child ratios for a home daycare in Massachusetts?

Massachusetts does not give family child care a staff-to-child ratio in the form you are expecting, and the first money an applicant loses here is lost by looking for one. There is no line in 606 CMR 7.00 that reads one adult to four toddlers or one adult to seven preschoolers for a home program. The operative instrument is a five-row table inside 606 CMR 7.10(4), headed Multi-age Grouping, whose columns are "Regulation Number", "Group Size", "Minimum Number of Educators Present" and "Limits on Ages of Children". Each row is a permitted shape of a group: a total headcount, the number of educators that shape requires, and an age composition that shape must satisfy. You do not compute a ratio and then fill seats; you pick a row and you stay inside it. 606 CMR 7.10(4) opens by telling you who may use those rows: "The Multi-age Grouping ratios and group sizes specified at 606 CMR 7.10(4)(d) through (h) may be used by: (a) family child care and small group and school age child care programs", and only then, in (b) and (c), by large centres under conditions. The definition at 606 CMR 7.02 fixes the outer edge of the instrument: "Multi-age Grouping - Ten or fewer children from birth through 13 years (or 16 years, if such children have special needs) assigned to a single group." A family child care home in Massachusetts is one multi-age group.

That single sentence is why ten is the number everyone repeats, and it is a regulatory number, not a statutory one — see the capacity field, because the statute that used to carry ten no longer does. Read the five rows exactly as the Department serves them today. 606 CMR 7.10(4)(d): "six or fewer children", "one educator", "No more than three children younger than two years old, including at least one toddler who is walking independently. Additional children must be older than 24 months." 606 CMR 7.10(4)(e): "seven or eight children", "one educator", "No more than three children younger than two years old, including at least one toddler who is walking independently. Additional children must be older than 24 months. All children over capacity of six must be school age." 606 CMR 7.10(4)(f): "six or fewer children", "two educators", "No more than six children younger than two years old." 606 CMR 7.10(4)(g): "seven – ten children", "two educators", "No more than six children younger than two years old, including no more than three infants." 606 CMR 7.10(4)(h): "seven-ten children", "three educators", "No more than six infants.

Additional children must be 15 months of age or older." Four consequences follow, and each one is a place applicants lose money. First, eight children with a single educator is lawful in Massachusetts, at 606 CMR 7.10(4)(e), provided every child above six is a school age child. That is the row that surprises people who arrive from a ratio state. Second, the seventh child is not free: under (e) the seventh and eighth must both be school age, so a seven-child group holding six preschoolers and one four-year-old is not a lawful (e) group, it is an unlawful (d) group. Third, going past eight, or past six with anyone who is not school age, requires a second educator physically present under (g) — not on call, not upstairs, not the spouse who is home. Fourth, the infant sub-limits are the hard edges of every row: three children younger than two years old in the one-educator rows (d) and (e), six children younger than two with no more than three infants in the two-educator row (g), and six infants only in the three-educator row (h). The word infant is defined at 606 CMR 7.02 as "A child who is younger than 15 months old", and toddler as "A child who is at least 15 months of age, but younger than 33 months old".

So "younger than two years old" and "infant" are two different counters running at the same time in row (g), and an inspector counts both. The "at least one toddler who is walking independently" clause in rows (d) and (e) is the single most misread sentence in the Massachusetts table. It is not permission; it is a condition on the composition. If you are carrying three children younger than two in a one-educator group, at least one of those three must be walking independently, and every other child in the group beyond that trio "must be older than 24 months". Two non-ambulatory infants plus one walking toddler is the maximum under-two load a lone educator may carry, and the rest of the group has to be over 24 months — which quietly rules out the twenty-month-old you were planning to add. Who counts as an educator for these rows is a separate question with its own trap. 606 CMR 7.10(3)(a) reads: "For purposes of calculating staff: child ratios, staff shall include only those EEC-qualified persons who are assigned to care for children for specific hours of the day." The words "EEC-qualified" and "assigned" both do work. A person who has not been approved or certified by the Department in one of the family child care roles is not a second educator no matter how competent, how related to you, or how many hours they put in. 606 CMR 7.10(3)(b) closes the volunteer route: "Volunteers and student interns shall not be included in staff: child ratios unless they are at least 16 years of age (in Small and Large Group and School Age Child Care) or at least 18 years of age (in Family Child Care) and are assigned to the program for at least three months."

EEC's own family child care licensing policy statement "Volunteers, Student Interns and Ratios" (document code FCCVolunteer2012.04.26) goes further than the regulation and tells you the practical rule: "Volunteers and Student Interns who wish to be included in staff to child ratios in a family child care setting, must additionally apply and be approved/certified as a Family Child Care Approved Assistant. Once the approval/certification is granted the individual may be counted in the staff to child ratios." Treat that as the operating rule: in a home, the only bodies that count toward the two-educator rows are the licensee, a Certified Assistant, or a Regular Assistant holding a current EEC certificate. And 606 CMR 7.09(15)(a) states the floor plainly: "All educators must be at least 18 years of age." The assistant regime is the historic Massachusetts trap, and it is worth setting out in full because the regulation and the agency's public wording do not read the same. 606 CMR 7.02 defines "Certified Assistant - A person who holds a certified assistant certificate issued by the Department; who, at minimum, meets the qualifications of a provider licensed to care for six children; and who works with or substitutes for the licensee in a family child care home, depending on his/her level of qualification."

It defines "Regular Assistant - A person who holds a regular assistant certificate issued by the Department; does not meet the qualifications of the licensee for whom they are working; and who may replace a licensee or certified assistant on a limited basis in a family child care home as allowed under 606 CMR 7.09(15)(c)2.a." The operative rules sit at 606 CMR 7.09(15)(c). For the certified tier: "An educator who meets the qualifications of the licensee may replace the licensee at any time, provided notice is given to parents in advance, in accordance with 606 CMR 7.08(8)(c)", and "An educator who meets the qualifications of a family child care educator licensed to serve six or fewer children may substitute for a provider licensed to care for up to ten children for up to 25 hours in a 12 month period." For the regular tier: "An educator whose qualifications are neither equal to nor greater than the licensee's qualifications may provide care under the general supervision of the licensee. a. A regular assistant may be alone on the premises with up to six children for up to 25 hours in a 12 month period, or up to eight hours in a seven day period, provided s/he is currently certified in first aid and CPR. b.

In programs licensed to care for seven or more children, a regular assistant may provide care only under the supervision of a licensee or certified assistant." Parse 7.09(15)(c)2.b carefully, because it is where applicants over-read their own capacity. A Regular Assistant is a lawful second educator for the two-educator rows (g) and (h) — nothing forbids it, and the assistant holds a Department certificate, so 7.10(3)(a) is satisfied — but only while you or a Certified Assistant are supervising on the premises. The moment you step out, the group must collapse to six children, the clock at 7.09(15)(c)2.a starts, and that clock is brutal: twenty-five hours in twelve months, and never more than eight hours in any seven day period. EEC's licensing policy statement "Use of Regular Assistants in Family Child Care Homes" (document code FCCRegularAssistants20120626) removes the workaround people try: "no provider may leave their child care children with an uncertified assistant for more than a total of 8 hours per week or a total of 25 hours per year, no matter how many assistants he/she uses.

The maximum amount of time child care children may be left alone with any number of regular assistants is 25 hours in one year, and no more than 8 hours in any seven day period." Hiring a second Regular Assistant does not buy you a second allowance. The same policy also tells you the limit runs per home rather than per person: "the aggregate number of hours that a regular assistant may be left alone with child care children in a variety of homes may be greater than the 8 hours per week or 25 hours per year, but those limits apply to each family child care home separately." And it closes with the sentence that governs your daily staffing: "Regular assistants may work with a provider or Certified Assistant for any length of time when the provider or Certified Assistant is on the child care premises." Now the contradiction you must know about before you build a business plan, because it decides whether you need an assistant at seven children or at nine. M.G.L. c. 15D, § 1A defines "Large family child care home" as "a private residence which, on a regular basis, receives for temporary custody and care during part, or all of the day, children under 7 years of age, or children under 16 years of age if such children have special needs, and receives for temporary custody and care for a limited number of hours children of school age under regulations promulgated by the board. A large family child care home shall have at least 1 approved assistant when the total number of children participating in child care exceeds 6." Read literally, the statute requires an approved assistant above six children.

The regulation the Department actually inspects against does not: 606 CMR 7.10(4)(e) authorises "seven or eight children" with "one educator" so long as "All children over capacity of six must be school age", and 606 CMR 7.09(15)(b)2. licenses a provider "to care for seven or eight children, at least two of whom must be school age" on the strength of the provider's own experience and pre-service training, saying nothing about an assistant. EEC's own consumer page "Learn about Family Child Care" states the regulation's position in plain words — "Up to 8 children: A licensed Family Child Care provider may enroll up to 8 children in their program without an assistant if at least 2 of the children are school age" — and reserves the assistant for the top tier: "Up to 10 children: A licensed Family Child Care provider may enroll up to 10 children in their program if there is an approved assistant working with them." The practical answer for an applicant is that the licence you hold and the row you are standing in govern: at seven or eight, all school age above six, you may be alone; at nine or ten, or at seven and eight with a non-school-age child in the extra seats, you need a second educator present.

But do not let anyone quoting § 1A at you tell you your 7-8 licence is invalid, and equally do not build a nine- or ten-child model on the theory that § 1A's silence about numbers means the ceiling is open — the ceiling is at 606 CMR 7.02 and 7.10(4), and it is ten. The tier you may be licensed for is decided by your own credentials before any child walks in, and that is a capacity question with a ratio consequence. 606 CMR 7.09(15)(b)2. requires, for seven or eight children, "evidence of having completed within one year prior to application a pre-service training approved by the Department" plus "two years of experience as a family child care licensee or certified assistant" or one year of that experience plus a further year with unrelated children in a group setting or EEC teacher/site-coordinator certification. 606 CMR 7.09(15)(b)3. requires, for nine or ten children, "a five hour pre-service training approved by the Department" plus "three years of experience as a family child care licensee or certified assistant" or one year plus two additional years in a group setting, or one year plus EEC teacher or site coordinator certification and one additional year.

In both tiers "An additional three credits in education or early childhood education may substitute for six months of the required additional experience" and six credits for nine months. A first-time applicant with a year of parenting experience qualifies under 606 CMR 7.09(15)(b)1. for six or fewer children and cannot buy the eight-child row with an assistant. The assistant does not upgrade your licence. Your résumé does. Supervision is a separate obligation that survives every ratio row, and Massachusetts writes it as duties, not numbers. 606 CMR 7.10(5) requires that "all licensees and educators must exercise appropriate supervision of the children in their care in order to ensure their health and safety at all times. Such supervision must include, but not be limited to, indoor and outdoor activities, mealtimes, naptime, transportation, field trips, and transitions between activities." The one hard number is at 606 CMR 7.10(5)(a): "Children younger than six months of age at the time of enrollment must be under direct visual supervision at all times, including while napping, during the first six weeks they are in care."

Six weeks of eyes-on a newborn, including through nap, is what an infant enrolment actually costs you in a one-educator group. The judgment factors at 606 CMR 7.10(5)(b) are the five an inspector will walk you through: "the chronological age and developmental needs of each child", "the behavioral characteristics of each child", "the number of educators supervising each group and their qualifications", "the environment and its impact upon the educator's ability to see and/or hear children", and "the nature of the activity and the materials and equipment used". Then 606 CMR 7.10(5)(c) through (f): "Educators must be in sufficient proximity to children at all times in order to be able to intervene quickly when necessary"; "Educators must be positioned to maximize their ability to see and/or hear children in their care"; "Educators must be aware of children's activities at all times"; "Educators must not engage in any other activities or tasks that could unnecessarily divert their attention from supervising the children." That last one is the citation you get for cooking, cleaning or taking a call while alone with eight children.

Two age-based releases loosen the visual tether, and both need paper. 606 CMR 7.10(5)(j): "Children age seven or older may, with written parental consent, participate in activities within the approved indoor space without constant visual supervision by the educator. The educator must be aware of the child's location, monitor the child's activity at regular intervals based on the factors in 606 CMR 7.10(5)(b), be readily available to assist children, as needed, and be able to respond immediately to an emergency situation." 606 CMR 7.10(5)(k): "Children age nine or older may leave the premises with written parent and educator consent, provided that the consent specifies the day and time the child will leave, the time the child will return, if applicable, the method of transportation the child will use, and the parent's responsibility for the child once he or she leaves the premises." Without the written consent on file, the release does not exist and the child counts as unsupervised. The provisions written specifically for homes are at 606 CMR 7.10(6) and (7), and you are expected to know they override the general outdoor rule. 606 CMR 7.10(6) begins "Notwithstanding 606 CMR 7.10(5)(h)" and permits at (a) that "children five years of age or older may be allowed to engage in outdoor activities unaccompanied by the educator if: 1. the outdoor play space is located on the family child care premises of a single family or first floor residence, and is enclosed by a fence at least four feet high; and 2. the children are observed by the caregiver every 15 minutes; 3. the time unaccompanied by the provider does not exceed one hour; and 4. the parents have given written permission."

All four conditions, not three: a four-foot fence, a fifteen-minute observation cycle, a one-hour ceiling, and written parental permission. 606 CMR 7.10(6)(b) extends the seven-and-older release to the approved outdoor space on the same four conditions of awareness, interval monitoring, readiness to assist and immediate emergency response. 606 CMR 7.10(7) then adds the four rules that make a home a home: "(a) Except as provided at 606 CMR 7.10(5)(j), children must always be on the same floor level as the educator. (b) Except when attending to their personal hygiene needs, educators must be actively engaged in child care and education activities during all times when children are in care. (c) Educators must ensure that infants and toddlers are placed in a safe location when educators are unable to maintain direct eye contact with them for any reason. (d) The educator must visually observe napping children at least every 15 minutes. When children are placed in a separate room for naps, the door must remain ajar." The same-floor rule at (7)(a) is the one that quietly kills the basement-playroom-while-I-cook-upstairs plan, and the ajar door at (7)(d) is a recurring monitoring citation.

Know also what does not apply to you, because applicants copy centre rules into home policies and then get audited against them. 606 CMR 7.10(8) is headed "Additional Provisions for Small Group and School Age and Large Group and School Age Child Care" — not family child care. So the written staffing schedule at 606 CMR 7.10(8)(b), which requires that "the Licensee must establish a written schedule listing all persons on duty, including volunteers" and that it "must show compliance with at least the minimum educator ratios at all times, including during breaks and planning time", is a centre obligation. So too is the second-adult rule at 606 CMR 7.10(8)(c): "Notwithstanding the staff: child ratios provided at 606 CMR 7.10(4), there must always be a second adult trained in the program's health care and emergency procedures immediately available in case of an emergency." Massachusetts imposes no second-adult backstop on a family child care home operating a lawful one-educator row. Likewise 606 CMR 7.10(9), the fixed-age and mixed-age tables — infants at 1:3 with a maximum group of 7, toddlers at 1:4 with a maximum of 9, preschoolers at 1:10 full day with a maximum of 20 and 1:12 half day with a maximum of 24, kindergarten at 1:15 with a maximum of 30, school age at 1:13 with a maximum of 26, and the mixed-age rows at 1:3 for an infant/toddler group of 9 with no more than three infants, 1:5 for a toddler/preschool group of 9, 1:10 for a preschool/school age group of 20 with a maximum age of eight, and 1:13 for a kindergarten/school age group of 26 — belong to large group and school age programs.

Those are the numbers a search engine will hand you when you type "Massachusetts daycare ratios". They are not your numbers. Quoting them in your own parent handbook is a self-inflicted finding. Ratios follow the children out of the house. 606 CMR 7.07(9) provides that for programs offering "swimming, boating or other water activities, the licensee must ensure that the area is safe and children are directly supervised at all times during activities involving water, including tubs, pools, showers, or standing water.

Educator/child ratios must be sufficient to maintain the safety of children in or near water" — an open-ended standard, which in practice means the ratio your inspector thinks was sufficient after the fact. 606 CMR 7.13 applies "to all programs, including family child care" and requires at 7.13(1) "a written plan for the safety and supervision of all children during transport" that "must describe how children are transported to and from the program, in an emergency, and on field trips" and "must also address the safety and supervision of children who walk and who arrive by public transportation", and at 7.13(2) "written parental consent for each child's individual transportation plan". 606 CMR 7.13(4)(f) requires that "at least one person on each vehicle is currently certified in first aid and CPR", and 7.13(4)(a) drops a capacity cliff into your transport plan: any vehicle "used for transportation of more than eight passengers at any one time and the driver thereof" must "conform to Massachusetts school bus requirements as contained in the pertinent sections of M.G.L. c. 90 and 540 CMR 7.00: Minimum Standards for Construction and Equipment of School Buses". A ten-child licence plus one educator is eleven occupants, so the day you decide to drive your whole group anywhere, you have crossed into school bus territory. 606 CMR 7.13(3)(i) adds that "Children must not be regularly transported for periods longer than 45 minutes one way", and 606 CMR 7.10(5)(i), cross-referencing 7.13(3)(j), states that "a child must never be left unattended in a vehicle."

Two more ratio-adjacent duties. 606 CMR 7.04(13)(a) requires that when you serve a child with a disability you identify in writing, with the parent's input, the accommodations needed, including "the size of the group to which the child may be assigned and the appropriate staff/child ratio" — meaning your lawful table row can be tightened for a specific child by your own written accommodation, and you will then be held to your own document. And 606 CMR 7.11(14) provides that "Educators providing evening care must comply with all applicable regulations regarding daytime care, including, but not limited to, staffing ratios, supervision of children, curriculum, nutrition, ventilation and lighting, and naptime regulations", with evening care defined at 606 CMR 7.02 as "Child care provided between the hours of 8:00 P.M. and 11:30 P.M." Overnight care adds a wakefulness rule rather than a ratio: 606 CMR 7.11(15)(a) requires that "The educator must remain on the same floor level as child care children during the overnight shift" and that "The educator must remain awake until all the children, including all household members and/or visitors below the age of 12 years old, are asleep."

The authority under which all of this is issued is short and worth memorising, because it is what you cite when someone tells you a different agency licenses you: the regulation's own closing line is "REGULATORY AUTHORITY 606 CMR 7.00: M.G.L. c. 15D", and M.G.L. c. 15D, § 2 provides that "There shall be in the executive office of education a department of early education and care" whose duties include, at § 2(c), to "license or approve child care centers, school-aged child care programs, family child care homes and large family child care homes". EEC has sat inside the Executive Office of Education since it was created; nothing has moved the licensing function out of it. Finally, note what is not in force: as of today the Department's own page listing proposed rulemaking states that "Department of Early Education & Care does not have any proposed amendments to its regulations at this time", so the five rows at 606 CMR 7.10(4) are the rows you will be inspected against, and any number you have read about twelve children belongs to a pilot, not to the table.

What training do I need to run a home daycare in Massachusetts?

Before you can be licensed: START WITH THE DATE, BECAUSE THE MASSACHUSETTS PRE-SERVICE GATE MOVED AND THE DOCUMENT MOST OF THE INTERNET STILL QUOTES IS A 2012 POLICY WHOSE EVERY TRAINING LINK IS DEAD. Verified 26 August 2026 against the operative text and against the live servers, not against a pinned copy. The regulation that licenses you is 606 CMR 7.00, Standards for the Licensure or Approval of Family Child Care; Small Group and School Age and Large Group and School Age Child Care Programs, promulgated by the Department of Early Education and Care under the authority line that closes the chapter: "606 CMR 7.00: M.G.L. c. 15D." The chapter as it stands today was last amended by Massachusetts Register Issue 1452 and Massachusetts Register Issue 1459, both effective 1 September 2021; there is no later amendment to 7.03 or 7.09. The Secretary of the Commonwealth serves that text at reg_pub/pdf/600/606007.pdf, a file whose server stamps it last modified 24 December 2021, and the 2021 emergency-revision content (including the workforce-shortage clause at 606 CMR 7.09(20)) is present in it, which is how you know the file the Secretary serves and the text the codifiers report are the same text.

What has changed since 2021 is not the regulation. It is the policy layer underneath the regulation, and that is where the pre-service requirement actually lives. THE ONE SENTENCE THAT DECIDES WHETHER A LICENCE CAN ISSUE AT ALL IS 606 CMR 7.03(1)(b). The Department may issue a child care license provided that, in the words of the rule, "within one year prior to licensure the licensee (or his or her designee) has attended an orientation to early education and care approved by the Department". That is a condition on the issuance of the licence, not a condition you can cure afterwards. It is reinforced from the educator side at 606 CMR 7.09(9): "All educators must attend an orientation to early education and care approved by the Department." Note the timing trap embedded in the wording. The orientation must sit within the twelve months BEFORE licensure. If you attend orientation, then spend fourteen months finding a dwelling, passing a background record check, chasing a lead paint disclosure and scheduling inspections, your orientation has aged out of the window and you attend again. Applicants front-load the training because it feels like the first step, then discover at the end of a long application that the certificate is stale.

Sequence it late, not early. WHAT "APPROVED BY THE DEPARTMENT" MEANS IS SET BY POLICY, AND THE POLICY THAT DEFINED IT FOR A DECADE IS NOW A GHOST. EEC's policy statement "Orientation to Early Education and Care", document control number EECOrientation20121004, states in its own words: "EEC regulations require the licensee to provide an orientation to its program for all educators it employs. [See 606 CMR 7.09(15)(d) for family child care educators, and 606 CMR 7.09(17)(a) for small or large group and school age child care programs]. In addition to the orientation to the individual program, EEC regulations require that: 'All educators must attend an orientation to early education and care approved by the Department' [See 606 CMR 7.09(9)]. This policy specifies the activities required to comply with 606 CMR 7.09(9)." For family child care it then says: "Applicants for licensure in family child care or for certification as an assistant must attend a five-hour, in-person orientation to family child care delivered by an EEC-approved trainer within one year prior to application for licensure or certification. (This training is approved for 5 EEC Professional Development hours or .5 CEUs.)" It adds a second module: "Family child care licensees and certified assistants first licensed or certified after August, 2010, must complete Module Two of the Family Child Care Orientation within their first six months of licensure or certification."

It adds a capacity-specific module: "Applicants for a license to serve 7 - 10 children in family child care or for certification as an assistant to serve 7 - 10 children must complete the on-line training 'Maintaining Quality While Expanding Your Capacity' ... before receiving a capacity increase. (This training is approved for 2 EEC Professional Development hours.)" It adds an assistant module, a SIDS module required "prior to licensure, certification or approval as an assistant", a transportation module "Look Before You Lock" within sixty days, and "Medication Administration: The Five Rights" before administering any medication. EVERY SINGLE TRAINING URL IN THAT POLICY IS DEAD TODAY, AND THE POLICY ITSELF HAS BEEN DELISTED. Measured 26 August 2026: the SIDS self-study at eec.state.ma.us/docs1/Workforce_Dev/SIDS revised self-study.pps returns HTTP 503; the Look Before You Lock deck at eec.state.ma.us/docs1/Workforce_Dev/20120502-look-before-lock.pps returns 503; the Five Rights medication module at eec.state.ma.us/docs1/regs_policies/FiveRightsMedAdmin/ returns 503; the family child care assistant orientation at eec.state.ma.us/docs1/regs_policies/FCCAssistOrient/ returns 503; the capacity-expansion PowerPoint at mass.gov/edu/docs/eec/20101015-fcc-expansion-training.ppt returns 403; and the professional development calendar the companion policy points to, eec.state.ma.us/ProfessionalDevelopment/WebFindTraining.aspx, returns 503. And EEC's own current index page, Licensing Policies for Family Child Care Providers, does not contain the word "orientation" anywhere: the 2012 policy has been dropped from the list EEC publishes for family child care, even though the file still resolves.

If a consultant hands you a checklist saying "complete the five-hour in-person orientation and the SIDS PowerPoint", they are reading a delisted 2012 document and pointing you at six dead servers. WHAT ACTUALLY GATES YOUR LICENCE IN 2026 IS EEC ESSENTIALS 2.0, AND THE OPERATIVE INSTRUMENT IS A POLICY ADVISORY, NOT A REGULATION. EEC Policy Advisory Field Operations 2024-9, "Policy: EEC Essentials 2.0", carries "Effective Date: May 8, 2024 (staff have until June 30, 2025 to complete EEC Essentials 2.0)" and is signed under Commissioner Amy Kershaw. It states: "The revisions to this policy and the related EEC Essentials training package are in response to requirements from the US Department of Health and Human Services, Office of Child Care within the Administration for Children and Families", and "Completing EEC Essentials 2.0 is mandatory for all new staff entering the field." On applicability it is explicit about you: "All educators and administrators working in EEC-licensed or funded programs will be required to complete the EEC Essentials 2.0 training package. In Family Child Care (FCC) programs, the FCC licensee, certified assistants, and regular assistants, must complete the training package."

And on timing: "Staff that are new to working in EEC-licensed or funded programs Must complete a background check and the EEC Essentials 2.0 before working with children." The companion EEC Essentials 2.0 FAQs, dated April 2024, remove the ambiguity for family child care specifically: "For Family Child Care providers and assistants, the EEC Essential 2.0 training package needs to be completed prior to licensure. Additionally, certification of current training in CPR and first aid is also required prior to licensure." THE PACKAGE IS THIRTEEN COURSES AND ABOUT TWELVE HOURS, AND YOU CANNOT CHERRY-PICK IT. The advisory says: "All applicable staff in early childhood programs (center-based and family child care) will enroll in and complete the 13-course package labeled 'EEC Essentials for Early Childhood 2.0'. This package should take approximately 12 hours." The FAQ lists the modules by name: "Protecting Children from Abuse and Neglect (Mandated Reporter Training), Emergency Response, Introduction to First Aid and CPR, Food Safety, Hazardous Materials, Prevention and Control of Infectious Diseases, Introduction to Child Growth and Development, Medication Administration, Missing Child Prevention, Transporting Children Safely, Physical Premises Safety, Safe Sleeping Practices, and Shaken Baby Syndrome."

There is one certificate for the whole package, not thirteen: "Does each module have its own certificate? No. You must complete all the course modules in the EEC Essentials 2.0 training package." And prior equivalent training does not excuse you: "What if I took an EEC-approved course on any of these topics already or I took the original EEC Essentials? All Staff working directly with children need to complete the EEC Essentials 2.0 course by June 30, 2025. This includes staff that may have taken training on one or more of these topics in the past. These are requirements from the Federal Government." If you took the original twelve-course EEC Essentials, the FAQ answers "Yes" to whether you must take 2.0 anyway. THIS IS WHERE THE MANDATED-TOPIC LIST ACTUALLY LIVES, AND IT IS NOT IN 606 CMR 7.00. Read 606 CMR 7.00 cover to cover and you will not find a rule ordering a course in Sudden Infant Death Syndrome, a course in shaken baby syndrome, or a course in mandated reporting. The regulation imposes the underlying DUTIES without imposing the courses. On safe sleep it commands the practice: "Programs serving infants must: 1. place infants on their backs for sleeping, unless the child's health care professional orders otherwise in writing".

On mandated reporting it commands the status: "Every educator is a mandated reporter under M.G.L. c. 119, s. 51A and must make a report to the Department of Children and Families whenever he/she has reasonable cause to believe a child in the program is suffering from serious physical or emotional injury resulting from abuse inflicted upon the child, including but not limited to sexual abuse, or from neglect, including but not limited to malnutrition, no matter where the abuse or neglect may have occurred and by whom it was inflicted." The training obligations attach through the policy layer. EEC's Safe Sleep for Infants policy, effective 1 October 2023, states: "All staff working with infants under 12 months of age must be trained on safe sleep practices prior to caring for infants. In accordance with the EEC Essentials Policy, Infant Safe Sleep Practices and Shaken Baby Syndrome trainings must be completed prior to working with infants and toddlers in an unsupervised capacity. An educator trained in safe sleep practices must be present at all times where there is a sleeping infant."

And the FAQ closes the mandated-reporter question with three words: "Does this replace the mandatory 51A training? Yes." So the topic list exists, it is federal in origin, it is delivered as one package, and it is enforced through a policy advisory that no version of the Code of Massachusetts Regulations will ever show you. Anyone auditing your readiness by reading only 606 CMR 7.00 will tell you Massachusetts has no SIDS or shaken-baby training requirement. That is a reading of the code, and it is wrong about the world. THE ONLY TRAINING THE REGULATION ITSELF DEMANDS BEFORE A FAMILY CHILD CARE LICENCE ISSUES IS FIRST AID AND CPR, AND IT IS THE ONE MOST APPLICANTS BUY WRONG. 606 CMR 7.09(15)(b) opens: "Prior to being licensed for the first time to provide family child care the applicant must submit evidence of current certification in basic first aid and CPR that is age appropriate for all of the children in care." 606 CMR 7.03(5)(a) repeats it in the documents list: the licensee must submit "certification of current training in CPR and first aid, per 606 CMR 7.09(15)(e)". EEC's policy "CPR and First Aid Training and Certification", effective 1 October 2020 and updated 17 December 2021, sets the acceptance rules.

On CPR: "Online CPR training may be taken as long as the participant is required as part of the online training to demonstrate and successfully complete age-appropriate CPR techniques to a certified instructor. EEC will not accept CPR certification training that does not include hands-on skill demonstration." Appropriate courses must "Address choking and rescue breathing, Include the use of mannequins, Maintain an appropriate mannequin to student ratio, Be appropriate for the ages of the children in care, and Include a requirement that the participant demonstrates age-appropriate CPR technique." On first aid the instructor must be currently certified by one of exactly seven bodies: "1. American Heart Association; 2. American Red Cross; 3. National Safety Council; 4. American Safety and Health Institute; 5. Massachusetts Firefighting Academy; 6. Emergency Medical Instructor/Coordinator Training Course of Department of Public Health; or 7. EMS Safety Services, Inc." The policy then adds the line that costs money: "NOTE: EEC does not maintain an approved list of individual First Aid and CPR trainers."

There is no roster to check against. A twenty-dollar wholly online certificate with no skills demonstration is worthless to EEC, and you will not learn that until a licensor looks at it. Buy the blended course with an in-person or live-proctored skills check, and buy the age-appropriate version covering infants if you intend to enrol infants. THE CAPACITY YOU APPLY FOR CHANGES THE PRE-SERVICE REQUIREMENT, AND THE RULE IS ASYMMETRIC IN A WAY THAT CATCHES PEOPLE. For the base licence, 606 CMR 7.09(15)(b)1 requires "an applicant for a license to care for six or fewer children must have at least the following: a. one year of experience as a parent; or b. one year of full-time experience, or the equivalent, in caring for children younger than 12 years of age; or c. nine months of full-time experience in caring for children younger than 14 years of age and completion of 15 hours of training, approved by the Department, not including the EEC educator orientation; or d. six months of full-time experience in caring for children younger than 12 years of age and completion of 30 hours of training, approved by the Department, not including the EEC orientation; or e. qualification as a teacher or site coordinator by EEC."

Read the exclusions in c and d: the fifteen and thirty hours are "not including the EEC educator orientation". You cannot count the orientation twice. For seven or eight children, 606 CMR 7.09(15)(b)2 requires an applicant "must have evidence of having completed within one year prior to application a pre-service training approved by the Department" plus "two years of experience as a family child care licensee or certified assistant" or one year plus an additional year in a group setting or EEC teacher/site coordinator certification. For nine or ten children, 606 CMR 7.09(15)(b)3 requires "evidence of having completed within one year prior to application a five hour pre-service training approved by the Department" plus three years as a licensee or certified assistant, or one year plus two additional years in a group setting, or EEC certification plus one additional year. Notice what the text does and does not say. The nine-to-ten tier names an hour figure, "a five hour pre-service training". The seven-to-eight tier names no hour figure at all: it says "a pre-service training approved by the Department" and stops.

The number does not exist in the regulation, only in whatever EEC has approved at the moment you apply. Do not budget from a blog post that asserts five hours for both tiers. THE BRIEF HANDED TO THIS RESEARCH SAID MASSACHUSETTS DISTINGUISHES "FAMILY CHILD CARE" FROM A "LARGE FAMILY" LICENCE AT TEN CHILDREN. THE TEXT SAYS OTHERWISE AND YOU SHOULD NOT SHOP FOR A LICENCE THAT DOES NOT EXIST. 606 CMR 7.02 defines family child care as "Temporary custody and care provided in a private residence during part or all of the day for no more than ten children younger than 14 years old or children younger than 16 years old if such children have special needs." There is one family child care licence. What varies is the licensed capacity written on it, and the qualification tier that unlocks each capacity: six or fewer, seven or eight, nine or ten. Massachusetts has no separate "large family child care home" licence category in 606 CMR 7.00. The "six plus two school age" figure people repeat comes from the ratio table, not from a licence type: 606 CMR 7.10(4)(e) permits seven or eight children with one educator on condition that "All children over capacity of six must be school age", while 606 CMR 7.10(4)(g) requires TWO educators for seven to ten children in the general case.

That is the assistant trap the Massachusetts file is famous for. You can be licensed for nine or ten and be unable to lawfully open the door alone, because the ratio row that permits nine or ten requires a second qualified adult in the home. THE ASSISTANT REGIME IS PART OF YOUR PRE-SERVICE PLANNING, NOT AN AFTERTHOUGHT. 606 CMR 7.09(15)(c) splits assistants in two. A certified assistant is "An educator who meets the qualifications of the licensee" and "may replace the licensee at any time, provided notice is given to parents in advance"; separately, "An educator who meets the qualifications of a family child care educator licensed to serve six or fewer children may substitute for a provider licensed to care for up to ten children for up to 25 hours in a 12 month period." A regular assistant is "An educator whose qualifications are neither equal to nor greater than the licensee's qualifications" and "may be alone on the premises with up to six children for up to 25 hours in a 12 month period, or up to eight hours in a seven day period, provided s/he is currently certified in first aid and CPR."

In programmes licensed for seven or more, "a regular assistant may provide care only under the supervision of a licensee or certified assistant." EEC's policy statement on regular assistants, control number FCCRegularAssistants20120626, tightens the arithmetic against aggregation: "no provider may leave their child care children with an uncertified assistant for more than a total of 8 hours per week or a total of 25 hours per year, no matter how many assistants he/she uses." Twenty-five hours is a per-home budget, not a per-assistant budget. And under Policy Advisory 2024-9, your regular assistant must have completed the full thirteen-course EEC Essentials 2.0 package and hold current first aid and CPR before ever being alone with children. REGISTRATION IS A SEPARATE OBLIGATION FROM TRAINING AND IT HAS ITS OWN LIVE SYSTEM. 606 CMR 7.09(4): "All educators must register annually with the Department of Early Education and Care in accordance with EEC policies and procedures." The instrument is the Professional Qualifications Registry, live today at eec.state.ma.us/PQRegistry/, which describes itself as gathering "important information on the size, composition, education, and experience of our current workforce" and states that "Educators, including assistants, who work with infants, toddlers, preschoolers, or school age children in EEC-licensed settings are required to register."

The EEC Essentials FAQ is blunt about keeping it live: "Do I still need to keep my PQR active? Yes. All Staff working directly with children must register in the PQR and continue to keep their PQR in an 'active' status." Your PQR number is also your enrolment key for the training system. Where this bites in 2026 is that EEC is mid-migration. EEC's new Professional Portal at childcare.mass.gov/educators, live today, says: "The Department of Early Education and Care (EEC) is working on a new way to manage your professional trainings and growth. Use the portal to access the new StrongStart and apply for EEC professional certifications." And then, critically: "PQR isn't available in the portal yet. At this time, you need to continue using PQR for annual registration and other tasks you currently complete there." It also warns about older certificates: "If you applied and were approved for a certification before November 2025, a copy of your certificate will be available in the portal in the future. At this time, continue to check wherever you saved your copy." You will hold accounts in two systems, MyMassGov plus the new portal for training and the old single sign-on for PQR, and nobody will merge them for you.

THE TRAINING SYSTEM ITSELF MOVED TWICE AND EVERY PUBLISHED LINK TO IT IS NOW A REDIRECT. The EEC Essentials FAQ instructs: "Go to the URL: https://strongstart.eoe.mass.gov". Fetched 26 August 2026, strongstart.eoe.mass.gov returns HTTP 301 to childcare.mass.gov/educators, and so does every deep link into the old StrongStart course store, including the item pages for "Potential Provider Training for FCC" and "Potential Educator Meeting" that search engines still surface as the canonical way to book your orientation. The eoe.mass.gov host is the fingerprint of the reorganisation: EEC's professional development estate now sits under the Executive Office of Education. That transfer did not change who issues the licence. 606 CMR 7.00 still names the Department of Early Education and Care as the licensing authority throughout, 606 CMR 7.02 still provides that "Department - When used alone shall mean the Department of Early Education and Care", the regulatory authority line is still M.G.L. c. 15D, and EEC's own portal page is headed "DEPARTMENT OF EARLY EDUCATION AND CARE" and footed "© 2026 Commonwealth of Massachusetts".

The web addresses where you do the work have changed twice in about two years, and the policies that instruct you still cite the addresses from before both moves. THERE IS A THIRD PRE-SERVICE OBLIGATION MOST CHECKLISTS OMIT: THE BACKGROUND RECORD CHECK, AND IT REACHES YOUR HOUSEHOLD. 606 CMR 7.03(1)(c)1 conditions issuance on "evidence of the applicant's compliance with the requirements of 102 CMR 1.05(1)". That cross-reference is itself a piece of archaeology worth knowing about, because 102 CMR is titled "OFFICE OF CHILD CARE SERVICES", an agency the General Court folded into EEC in 2005, and the Secretary of the Commonwealth's copy of 102 CMR 1.00 carries a server timestamp of 9 July 2004. The substance still governs: 102 CMR 1.05(1) provides that "An applicant shall not qualify to receive, retain, or have renewed a license if the background of the applicant, household member, or person who is regularly on the premises is not free from conduct which adversely bears on the provider's ability to care for children." The mechanics are in 606 CMR 14.00, Criminal Offender and Other Background Record Checks, which runs candidate categories, submission frequency, disqualifications, provisional hiring, the review process and a Table of Disqualifying Offenses.

Every adult who lives in your home or is regularly present during care is in scope. Start the checks early; they are the step most often outside your control. THE HEALTH FILE IS ALSO PRE-SERVICE. 606 CMR 7.09(11) requires that "Prior to licensure or employment of any educator the licensee must obtain from a licensed health care practitioner: (a) evidence that the educator has had a physical examination within one year prior to employment; (b) evidence that the educator has been immunized in accordance with the recommendations of the Department of Public Health; (c) a statement of any limitations on the educator in working with children", and 606 CMR 7.03(5)(a)3 lists those health records among the documents you must submit. 606 CMR 7.09(15)(g) extends the reach into your household: "Upon request by the Department the licensee must provide a current statement signed by a physician or other professional acceptable to the Department certifying that any household member or person regularly on the premises of the family child care home is in good physical and mental health." Like the orientation certificate, the physical examination carries a one-year shelf life relative to licensure, so book it in the same late window.

DO NOT CONFUSE THE DEPARTMENT ORIENTATION WITH YOUR OWN PROGRAMME ORIENTATION; THEY ARE DIFFERENT OBLIGATIONS AND ONLY ONE OF THEM EARNS HOURS. 606 CMR 7.09(15)(d), headed "Program Orientation", requires that "The licensee must inform all educators of the location of the children's records and the first aid kit and all procedures pertaining to the operation of the program, including, but not limited to, emergency procedures, variances, first aid procedures, supervision, child guidance, children's individual health plans, including infant sleeping positions, and the curriculum plan." That is a duty you owe to anyone working in your home, including a regular assistant. EEC's Professional Development policy, control number EECLicensingProfDev20120904, then rules it out as credit: professional development hours "will not be awarded for ... Program Orientation or staff training in a program's basic policies and procedures." The same policy also excludes "First Aid and CPR training" from professional development hours, which is the single most common accounting mistake made by newly licensed Massachusetts providers.

WHAT TO DO WITH THE PAPER, BECAUSE MASSACHUSETTS ENFORCES ON DOCUMENTS HELD ON SITE, NOT ON FILINGS. 606 CMR 7.04(5) requires a personnel record for each staff member containing "documentation that the employee has the qualifications required under 606 CMR 7.09 including, but not limited to, health records", "copies of licenses, certifications and registrations held", and "documentation of orientation, training and professional development, as required by 606 CMR 7.09(15)(d) through (f), 7.09(16)(c), 7.09(17)(a), 7.11(1), 7.09(18)(d), and 7.09(19)(b)". Policy Advisory 2024-9 adds: "Printed certificates should be available in staff records located within the program", and the FAQ adds the enforcement date: "Starting July 1, 2025, EEC licensing staff will begin monitoring to determine if the EEC Essentials 2.0 training requirements have been completed." The orientation policy sets the standard of completion for online modules in terms you should take literally: "the educator must view and listen to the entire narrated power point presentation, complete all examination questions, and print and maintain the appropriate training certificate on file for review by EEC."

Print everything. The training system has changed platform twice; your learning history is not a substitute for a certificate you hold. THE ORDER THAT ACTUALLY WORKS, GIVEN ALL OF THE ABOVE. Confirm your dwelling qualifies under 606 CMR 7.03(5)(e), which permits family child care only in a dwelling "that provides complete independent living facilities for one or more persons including permanent provisions for living, sleeping, eating, cooking, and sanitation". Start background record checks for yourself and every adult in the household under 606 CMR 14.00 and 102 CMR 1.05(1). Book the physical examination and immunisation evidence under 606 CMR 7.09(11). Register in the Professional Qualifications Registry at eec.state.ma.us/PQRegistry/ and get your PQR number, because you need it to enrol in training. Create a MyMassGov account and a profile in EEC's Professional Portal at childcare.mass.gov/educators, which is the only live door to the new StrongStart Learning Management System. Complete the full thirteen-course EEC Essentials 2.0 package for Early Childhood, about twelve hours, and print the single package certificate.

Take a blended first aid and CPR course with a hands-on skills demonstration, age-appropriate to the children you intend to enrol, from an instructor certified by one of the seven organisations EEC names. Attend the Department-approved orientation, and attend it INSIDE the twelve months before the licence will issue. If you are applying for seven or more children, add the additional Department-approved pre-service training required by 606 CMR 7.09(15)(b)2 or the five-hour training required by 7.09(15)(b)3, and confirm with the licensor in writing which currently approved course satisfies it, because the rule names no course and the 2012 policy that did name one points at a dead server. Then file, with the lead paint disclosure required by 606 CMR 7.07(15)(a)2, the CPR and first aid certification, and the health records, and pay the application fee. The training window and the background checks are the two things that cannot be compressed at the end. ONE LAST WARNING ABOUT WHO IS ALLOWED TO TELL YOU ANY OF THIS. The regulation itself contains an escape hatch at 606 CMR 7.09(20): "In the event the Commissioner of the Department determines there is a significant workforce shortage of early educators, and such shortages prevent programs from obtaining the appropriate staffing necessary to meet the health and safety needs of children, the Commissioner of the Department shall have the authority to revise and/or rescind any educator qualifications and professional development requirements under 606 CMR 7.04 and 7.09 to address this need."

That power is not hypothetical; it has been exercised. EEC's CPR policy records that "On August 31, 2021, the Board of Early Education and Care approved emergency revisions to its licensing regulations to address the workforce shortages caused by the pandemic. One of these revisions was to remove the annual CPR renewal requirement established by 606 CMR 7.11(1)(a)2 and, instead, to adhere to the expiration date listed on the CPR certificate." Which means that in Massachusetts the qualification and training rules can be changed by the Commissioner without a Register amendment you would notice, and the change reaches you through a policy advisory published on a page that has moved twice. Before you spend a dollar on any course, ask your regional EEC licensor by e-mail to confirm, in writing, which orientation and which pre-service training they will accept for the capacity you are applying for, and keep the reply. That e-mail is worth more than any checklist, including this one. Ongoing training: THE DISTINCTION THAT COSTS MASSACHUSETTS PROVIDERS THE MOST MONEY IS THIS ONE: YOUR LICENCE RUNS THREE YEARS, YOUR TRAINING OBLIGATION RUNS EVERY YEAR, AND NOBODY COUNTS THE HOURS FOR YOU UNTIL A LICENSOR IS STANDING IN YOUR LIVING ROOM.

Verified 26 August 2026 against 606 CMR 7.00 as amended by Massachusetts Register Issues 1452 and 1459, both effective 1 September 2021, the current text of the chapter, served by the Secretary of the Commonwealth at reg_pub/pdf/600/606007.pdf and confirmed against the codified version. 606 CMR 7.03(5)(b) provides that for family child care "A regular license or approval is valid for three years from the date of issuance unless revoked, suspended, or made probationary." 606 CMR 7.09(15)(f) states the training requirement PER YEAR. Massachusetts never restates the requirement as a per-renewal-cycle total, and that silence is the trap. A full-time family child care educator owes ten hours a year, which is thirty hours across one licensing period, and the regulation gives you no way to satisfy year two by doubling up in year three. If you are shopping for a training bundle that promises to cover you "for your licence period", you are buying against a rule that does not exist here. HERE IS THE OPERATIVE TEXT, IN FULL, BECAUSE IT IS SHORT AND EVERY WORD IN IT DOES WORK. 606 CMR 7.09(15)(f), Professional Development, provides: "1. Educators in family child care working more than 25 hours per year but less than ten hours per week must complete at least five hours of professional development activities per year. 2. Educators in family child care working more than ten hours per week must complete at least ten hours of professional development per year. 3. At least one third of the required professional development must address diverse learners."

Three thresholds sit inside those thirty-seven words. Below twenty-five hours of work in a year, the regulation states no professional development requirement at all. Between twenty-five hours per year and ten hours per week, five hours a year. Above ten hours per week, ten hours a year. The band you fall in is set by how much you actually work, not by your licensed capacity, and it changes if your enrolment changes. A licensee who dropped to part-time in the middle of a licensing period and back to full-time the next year owes five hours for one year and ten for the other, and must be able to show which is which. THE ONE-THIRD DIVERSE LEARNERS RULE IS THE SINGLE MOST CITED ITEM ON THIS SUBJECT AND ALMOST NOBODY BUDGETS FOR IT. "Diverse Learners" is defined at 606 CMR 7.02 as "Children who have special physical, emotional, behavioral, cognitive or linguistic needs or whose primary learning modality is visual, auditory, tactile or kinesthetic, who may require an adaptation in the environment, interaction or curriculum in order to succeed in their program." If you owe ten hours, at least one third of them, three and one third hours, must address that.

If you owe five hours, at least one and two thirds hours must. Nothing in 606 CMR 7.00 and nothing in EEC's professional development policy authorises rounding that fraction down, so the safe practice is four hours out of ten and two hours out of five. EEC repeats the rule in the policy with the definition attached, under the heading "A Note about Diverse Learners", which is a strong signal about what licensors look for. It is not enough to have ten hours of certificates. Ten hours of certificates with nothing on inclusion, adaptation, dual language learners or sensory and behavioural needs is a citation waiting to be written. AND HERE IS THE TRAP THAT DID NOT EXIST BEFORE 2024 AND THAT MOST MASSACHUSETTS GUIDANCE HAS NOT CAUGHT UP WITH. EEC Essentials 2.0, the thirteen-course federally driven package that runs about twelve hours and that you must complete before licensure, looks on its face like a full year of professional development and then some. EEC's own EEC Essentials 2.0 FAQs, dated April 2024, confirm half of that: "Does the training count towards EEC licensing training hour requirements? Yes, completion of the EEC Essentials 2.0 training package via EEC's LMS will count toward the required yearly professional development training hours the first time it is taken."

Read the qualifier. THE FIRST TIME IT IS TAKEN. And then read the very next question and answer in the same document: "Can any of the trainings count towards EEC licensing training requirements in diverse learners? No, none of these trainings count towards EEC licensing training requirements in diverse learners." So the twelve hours that felt like a comfortable surplus contribute exactly zero toward the three and one third hours of diverse-learner content you owe in the same year. A newly licensed full-time family child care educator who does EEC Essentials 2.0 and nothing else is compliant on the raw hour count and non-compliant on the composition, in year one, on the strength of the very training the Commonwealth required her to take. THE ANNUAL REFRESHER IS A SEPARATE, ADDITIONAL, PERMANENT OBLIGATION. EEC Policy Advisory Field Operations 2024-9, "Policy: EEC Essentials 2.0", with "Effective Date: May 8, 2024", provides: "After completing EEC Essentials 2.0, there will be an annual requirement to complete a 3-hour EEC Essentials refresher course", and again, "In addition, all applicable staff will be required to take the EEC Essentials Refresher package annually."

The enforcement date is stated: "Starting July 1, 2025, EEC licensing staff will begin monitoring to ensure that the EEC Essentials 2.0 Training requirements and annual EEC Essentials Refresher training have been completed a year later (and yearly thereafter) and certificates are available in staff records on-site. A program's failure to ensure that each program staff member/assistant working directly with children and counting in the program's staff-child ratio has completed the training package may result in citations of non-compliance." Note who is caught: "All staff that are included in the count for the maintenance of licensing ratios and group size must complete the entire package, regardless of the frequency that they work. In addition to educators and program administrators, this includes volunteers, interns, and substitutes that are counted in ratio." In family child care that means your certified assistant and your regular assistant, and the FAQ says so directly: "Do FCC Certified Assistants and Regular Assistants need to take the training? Yes." So your annual planning is not ten hours.

It is three hours of refresher plus enough additional professional development that the year still totals ten with at least three and one third of them on diverse learners, for you and for every assistant who counts in your ratio. WHAT CANNOT BE COUNTED IS AS IMPORTANT AS WHAT CAN, AND THE EXCLUSION LIST IS EXPLICIT. 606 CMR 7.09(15)(e) provides, in its own words: "All licensees, certified assistants, and any educator who may be alone with children must maintain current certification of training in basic first aid and CPR, in accordance with EEC policy. Training in first aid and CPR may not be counted toward Professional Development hours." That sentence sits inside the regulation, not merely in policy, and it is the most expensive misunderstanding in the Massachusetts file, because first aid and CPR recertification is the one training every provider reliably does and the one that reliably earns zero credit. EEC's policy statement on Professional Development, control number EECLicensingProfDev20120904 and still published on EEC's Licensing Policies index, extends the list: professional development hours "will not be awarded for: Committee meetings; Staff meetings (except for that portion of the meeting that has previously been identified as training and that meets the documentation requirements of this policy); First Aid and CPR training; Program Orientation or staff training in a program's basic policies and procedures.

For successfully completing an identical professional development activity more than once." That last exclusion is the one that catches providers in year two and year three of a licence. Repeating the same online module you took last year earns you nothing. The policy also narrows how a course's hours are computed: "The calculation of professional development hours is limited to hours approved by the accrediting organization or anticipated by the course presenter. This does not include time for waiting, breaks, meals, discussion unrelated to the professional development topic, and other unrelated activities." A six-hour conference day is not six hours. WHAT DOES COUNT IS DEFINED BY SUBJECT MATTER AND BY WHO TAUGHT IT. The regulation's own definition at 606 CMR 7.02 is broad: "Professional Development - Ongoing education or training designed to increase an educator's skills or knowledge or assist the educator in gaining new competencies in his or her profession or in a field closely related to his or her profession. Professional development may fulfil the annual number of hours required by regulation to maintain a license, registration or credential, and/or may result in college credit or CEUs that lead to career advancement."

The policy narrows it: "All professional development activities intended to satisfy the professional development hours required by EEC's regulations must relate to EEC's Core Competencies", and it prints the eight Core Competency Areas: Understanding the Growth and Development of Children and Youth; Guiding and Interacting with Children and Youth; Partnering with Families and Communities; Health, Safety, and Nutrition; Learning Environments and Implementing Curriculum; Observation, assessment, and documentation; Program planning and development; Professionalism and leadership. Delivery format is generous: "Acceptable professional development can be offered in person at child care programs, lectures, workshops or conferences or by distance-learning through self-guided study or instructor-led communities of practice." THE TRAINER QUALIFICATION RULE IS WHERE CHEAP CERTIFICATES DIE. The same policy provides: "To provide professional development to educators working in EEC licensed programs, trainers/instructors must meet one of the following: Have been approved to present coursework for college credit; Have been approved to offer training that results in CEUs, PDPs, or CECs; Have at least an associate's degree in early childhood education or a related field and at least one year of experience in early education, out of school time, or equivalent; Holding a recognized credential in a specific area of training will be accepted as being qualified within that area of expertise; or Meet EEC's qualifications for lead teacher, site coordinator or have at least three years of experience as a licensed family child care provider."

And where no formal credit is awarded, the burden of proving the trainer shifts onto you: if college credits, CEUs, PDPs or CECs are not awarded, your documentation "must include: Qualifications of the instructor (see the following section); Evidence of completion of all required quizzes, tests, self-assessments and assignments". A twelve-dollar unaccredited online certificate with no named instructor and no assessment is a certificate you cannot defend. Ask the vendor, before paying, which of those five bullets its instructor satisfies, and keep the answer with the certificate. THE CONVERSION TABLE, VERBATIM, BECAUSE PEOPLE GUESS AT IT AND GUESS WRONG. 606 CMR 7.02 defines the unit: "Continuing Education Unit (CEU) - A nationally recognized method for recognizing participation in professional development and training activities. One CEU is granted for each ten hours of instruction. CEUs must be approved by organizations designated by the Department." The policy names the designated organisations: "EEC accepts CEUs awarded by: Accredited colleges or universities; Training organizations with the International Association for Continued Education and Training (IACET) accreditation; Massachusetts Association for the Education of Young Children (MAEYC); National Association for the Education of Young Children (NAEYC); The National Coalition for Education and Cultural Programs (NCECP)."

For the two neighbouring currencies: "One PDP equals one hour of professional development. PDPs are usually offered in blocks of 10 hours" — PDPs being Professional Development Points issued by the Department of Elementary and Secondary Education — and "One CEC equals 1.5 hours of professional development; 2 or more CECs correspond hour for professional development hours (2 CECs = 2 hours; 3 CECs = 3 hours, etc.)", CECs being Competency Education Credits issued by Early Intervention at the Department of Public Health. College credit counts only if "offered by an institution that has been accredited by an accrediting agency or state approval agency recognized by the U.S. Secretary of Education." So half a CEU is five hours, one CEU is your entire annual obligation as a full-time family child care educator, and a training advertised as "1 CEU" from an outfit that is none of the five listed bodies is not one CEU as far as EEC is concerned. THERE IS A BANKING RULE, IT IS NARROW, AND IT IS THE ONLY LAWFUL WAY TO SMOOTH HOURS ACROSS YEARS. The policy provides: "If an educator successfully completes a college course (for credit) that results in more hours than needed for her annual professional development requirement, the additional hours may be credited towards the required professional development hours for the following calendar year ('banked').

Professional development hours for a single course may not be credited toward more than two consecutive year's requirements. At least one third of the course to be banked must address diverse learners." Read every limit in that. Only a COLLEGE COURSE FOR CREDIT can be banked, not a workshop and not an online module. The surplus rolls forward one year only, and a single course can never cover more than two consecutive years. And the diverse-learner fraction follows the banked course, so a three-credit course with no inclusion content cannot be banked at all. Note also the word the policy uses for the year: CALENDAR year. Nothing in 606 CMR 7.00 or in the policy anchors your professional development year to the anniversary of your licence. If you are tracking your hours from licence date to licence date and your licensor is reading them by calendar year, the two of you will disagree about a compliant year, and the licensor's reading is the one that goes in the record. Keep your log by calendar year and date every certificate. ONE MORE CREDIT EXISTS THAT ALMOST NOBODY CLAIMS. "Trainer's Development Credit.

An educator who researches, develops, and presents training that meets the professional development requirements of this policy may be credited for one professional development hour for each hour spent developing and presenting the training up to a maximum to 5 professional development hours per year." If you present at a local family child care system meeting, a CCR&R workshop or a conference, half of a full-time educator's annual obligation can come from your own preparation time, provided the training you deliver would itself qualify and you document it like any other activity. THERE ARE REGULATORY TRAINING TOPICS OUTSIDE THE HOUR COUNT, AND THEY ARE ENFORCED SEPARATELY. 606 CMR 7.11(1) provides: "All educators must be trained in the program's emergency and evacuation procedures, in standard precautions and in medication administration procedures." On medication specifically, 606 CMR 7.11(1)(b) requires that "Each person who administers prescription or non-prescription medication to a child must be trained to verify and to document that the right child receives the proper dosage of the correct medication designated for that particular child and given at the correct time(s), and by the proper method.

Each person who administers medication (other than topical medication) must demonstrate competency in the administration of medication before being authorized by the licensee to administer any medication", that "The licensee must ensure that at least one educator with training in medication administration is present at any and all times when children are in care", and that any person administering medications other than oral or topical medications and epinephrine auto-injectors "must be trained by a licensed health care practitioner and must demonstrate annually to the satisfaction of the trainer, competency in the administration of such medications." That is an ANNUAL competency demonstration, separate from your hour count, for anyone giving anything beyond the oral, topical and epi-pen categories. EEC's Essentials package includes a Medication Administration module and the FAQ confirms it "replaced EEC's legacy training offering in that area" alongside "Nutrition and Choking; Safe Sleep Practices; Look before You Lock; Drivers Transportation Training". It does not replace the annual practitioner-verified competency demonstration that 7.11(1)(b)2 requires for the harder routes.

NUTRITION AND CHOKING IS A STANDING REQUIREMENT WITH NO STANDING COURSE. 606 CMR 7.12(2) requires that "All educators must receive basic training in the following: (a) in USDA recognized nutrition requirements for the healthy growth and development of children; and (b) in food choking hazards." EEC's family child care policy on the point, control number FCCChokingHazardTraining20121128, concedes the gap in its own words: "While CPR training does touch upon choking, it does not deal specifically with food hazards, and therefore does not meet the regulatory requirement of 7.12(b) by itself. There is currently no formalized training solely on this topic, so Family Child Care educators may meet the requirements of this regulation in different ways", and it then allows food-programme training, documented review of USDA Team Nutrition materials, a free online course, or an attended nutrition training. It closes with "NOTE: This training can be counted for 1 hour of professional development", which makes it one of the few obligations that is simultaneously a regulatory topic and an hour you can bank against the ten.

The USDA and NFSMI links printed in that policy are more than a decade old; use current USDA Team Nutrition child care materials and document the date you reviewed them. SAFE SLEEP CARRIES ITS OWN TRAINING TRIGGER AND ITS OWN PUNISHMENT. EEC's Safe Sleep for Infants policy, effective 1 October 2023, states: "All staff working with infants under 12 months of age must be trained on safe sleep practices prior to caring for infants. In accordance with the EEC Essentials Policy, Infant Safe Sleep Practices and Shaken Baby Syndrome trainings must be completed prior to working with infants and toddlers in an unsupervised capacity. An educator trained in safe sleep practices must be present at all times where there is a sleeping infant." And the consequence of a first citation is retraining on a clock: "Within 10 business days of the citation, all educators and staff involved in the care of infants must complete training on Safe Sleep, including SIDS, through the StrongStart Professional Development System. Providers/Program Administrators must request training access from their Licensor via email", followed by an in-person unannounced Safe Sleep Follow-Up Monitoring Visit.

So in Massachusetts a safe-sleep finding does not just generate paperwork; it generates a compulsory training assignment with a ten-business-day deadline and a return visit. THE FIRST AID AND CPR CLIFF IS THE HARSHEST ENFORCEMENT PROVISION IN THE WHOLE TRAINING FILE, AND IT IS NOT IN THE REGULATION. EEC's policy "CPR and First Aid Training and Certification", effective 1 October 2020 and updated 17 December 2021, records that the annual CPR renewal that 606 CMR 7.11(1)(a)2 once required was removed by the emergency revisions the Board approved on 31 August 2021, so the rule today is simply "CPR training must be renewed prior to the expiration date listed on the CPR certificate." Then comes the sanction: "If EEC finds that there is no individual on premises at a family child care home or child care center with current (not expired) certification in age-appropriate CPR and first aid, the program must temporarily cease care at the end of the day when families have left the program. The program may not reopen until evidence of current and valid age-appropriate CPR and first aid certifications can be made available to the EEC licensor."

An expired card closes your business the same day. And remember 606 CMR 7.09(15)(e): the hours you spend renewing it earn you nothing toward the ten. Diarise the expiry ninety days out. WHERE THE HOURS ARE ACTUALLY CHECKED, AND WHY RENEWAL IS NOT THE ANSWER YOU EXPECT. Renewal under 606 CMR 7.03(3) requires you to "file a written application for renewal on forms provided by the Department and pay any required application fee not less than 30 days before the date of expiration of the current license", to "participate in a license renewal meeting approved by the Department", and to "review all of the written plans and documents required by 606 CMR 7.00 and submit copies of: 1. any of the required written plans or documents that have been revised during the licensing period; 2. current inspection certificates required by 606 CMR 7.00; and 3. any document required by 606 CMR 7.00 if requested by the Department." Read that list again. It does not require you to file three years of training certificates with the renewal application. The certificates live in the record you keep. 606 CMR 7.04(5) requires a personnel record for each staff member including "documentation of orientation, training and professional development, as required by 606 CMR 7.09(15)(d) through (f)", and EEC's professional development policy states the standard plainly: "Licensees must maintain and make available documentation to EEC upon request that their staff have met the requirements for professional development."

Policy Advisory 2024-9 says the same of the Essentials certificates: "Printed certificates should be available in staff records located within the program." So the audit happens at monitoring visits, unannounced, at any point in the three years. The provider who plans to "catch up before renewal" is planning against a system that does not wait for renewal, and a licensor visiting in month fourteen can cite a deficient year one that renewal would never have reached. DOCUMENT EACH ACTIVITY TO THE POLICY'S SIX-ITEM SPECIFICATION OR IT DOES NOT EXIST. The professional development policy requires that "Each educator must maintain documentation of successful completion of the professional development activity that includes: Name of the professional development activity; Topic(s) covered and the core competency area addressed; Number of contact hours completed; Date the course or training was completed; Instructional method (lecture, classroom discussion, distance learning, self-guided study or community of practice, etc.); Name of the sponsoring organization (if applicable)." Most vendor certificates give you the name, the date and the hours and stop.

The two fields they omit are the two that prove compliance: the core competency area addressed, which is how you demonstrate the diverse-learner third, and the instructional method. Write them onto your own log at the time. The policy also states that "Professional development should be recorded in the educator's profile in the EEC Professional Qualifications Registry", but note that the Essentials package is handled differently: "This training does not need to be listed in the Professional Qualification Registry (PQR). The training will be captured on each person's SSPDS transcript (available in their learning history)." THE SYSTEMS THAT HOLD YOUR RECORD HAVE MOVED TWICE, WHICH IS AN ARGUMENT FOR PAPER. The Essentials FAQ tells you to "Go to the URL: https://strongstart.eoe.mass.gov". Fetched 26 August 2026, that host returns HTTP 301 to childcare.mass.gov/educators, and so does every deep link into the old StrongStart course store. EEC's new Professional Portal, live at childcare.mass.gov/educators, describes itself thus: "The Department of Early Education and Care (EEC) is working on a new way to manage your professional trainings and growth.

Use the portal to access the new StrongStart and apply for EEC professional certifications", offers "The new StrongStart Learning Management System (LMS) — Complete and track your professional development courses or trainings", and warns that "PQR isn't available in the portal yet. At this time, you need to continue using PQR for annual registration and other tasks you currently complete there", and that for approvals "before November 2025", "continue to check wherever you saved your copy". Meanwhile 606 CMR 7.09(4) still requires that "All educators must register annually with the Department of Early Education and Care in accordance with EEC policies and procedures", the Professional Qualifications Registry at eec.state.ma.us/PQRegistry/ is still the live instrument for that annual registration, and the Essentials FAQ still insists: "All Staff working directly with children must register in the PQR and continue to keep their PQR in an 'active' status." Two annual obligations, two systems, one of which is being replaced under you. Print every certificate the day you earn it and keep a dated paper log by calendar year.

Your learning history in a system that has already been migrated once is not evidence you control. A NOTE ON WHAT MASSACHUSETTS DOES NOT REQUIRE, BECAUSE THE ABSENCE IS ALSO WORTH MONEY. Search 606 CMR 7.00 for an annual mandated-reporter course, an annual SIDS course, an annual shaken-baby course, or a mandated topic list of the kind Texas, Florida or Illinois publish, and you will not find one. The regulation imposes the duties without imposing recurring courses: 606 CMR 7.11(4)(d) makes "Every educator ... a mandated reporter under M.G.L. c. 119, s. 51A", 606 CMR 7.11(13)(e) requires programmes serving infants to "place infants on their backs for sleeping, unless the child's health care professional orders otherwise in writing", and that is the extent of it in the code. The recurring topic obligation arrives entirely through the policy layer, through EEC Essentials 2.0 and its annual three-hour Refresher, and the FAQ confirms the substitution in three words when asked whether Essentials replaces the mandatory 51A training: "Yes." Which means that any compliance product sold to you on the basis of a Massachusetts "mandated annual topic list" pulled from the Code of Massachusetts Regulations is selling you a list that is not there, and any adviser who tells you Massachusetts has no SIDS or shaken-baby training requirement has read only the code and missed the policy advisory that actually binds you.

FINALLY, THE HOUR COUNT ITSELF IS REVOCABLE BY ONE OFFICIAL WITHOUT A REGISTER AMENDMENT. 606 CMR 7.09(20) provides: "In the event the Commissioner of the Department determines there is a significant workforce shortage of early educators, and such shortages prevent programs from obtaining the appropriate staffing necessary to meet the health and safety needs of children, the Commissioner of the Department shall have the authority to revise and/or rescind any educator qualifications and professional development requirements under 606 CMR 7.04 and 7.09 to address this need." That clause entered the chapter in the September 2021 amendments and it has already been used once in the adjacent area, when the Board's emergency revisions of 31 August 2021 struck the annual CPR renewal out of 606 CMR 7.11(1)(a)2. So the hour count you owe in a given year is the hour count in 606 CMR 7.09(15)(f) as of that year, unless the Commissioner has revised it, and the revision will reach you as a policy advisory on a web estate that has changed address twice since 2024. Once a year, before you buy training, open EEC's Licensing Policies for Family Child Care Providers index and its Professional Development Policy and read what is actually listed there, rather than trusting a bundle sold as covering "Massachusetts annual requirements".

The requirements are ten hours a year, at least a third on diverse learners, plus a three-hour Essentials Refresher, plus first aid and CPR that never counts, thirty hours of it across a three-year licence, checked without warning.

What background checks does Massachusetts require?

In Massachusetts the background check is not a step in your family child care application. It is the gate, and the most common reason a file that looks complete sits unissued for months. The licensing authority is the Department of Early Education and Care (EEC), which mass.gov today places under the Executive Office of Education but which still issues the license itself: M.G.L. c. 15D, § 7(a) provides that "The department shall issue and may renew a license to any person ... who meets applicable standards and requirements to establish and maintain ... a family child care home." No transfer of that issuing authority has occurred; EEC sitting inside an executive office describes reporting lines, not the signature on your license. The operative regulation is 606 CMR 14.00, Criminal Offender and Other Background Record Checks. As of 26 August 2026 the EEC index at mass.gov/lists/eec-laws-and-regulations serves exactly one file for it, "EEC BRC Regulations (606 CMR 14)," a 37-page document whose credits line records the last substantive amendment as "1433 Mass. Reg. 81, amended eff. Dec. 25, 2020" and whose currency line reads "current through Register No. 1467, dated April 15, 2022." EEC's proposed-amendments page states on the same date that the "Department of Early Education & Care does not have any proposed amendments to its regulations at this time."

The rules that will be applied to you were fixed in December 2020, and nothing pending will change them before your license issues. Start from the statutory command, because it is broader than most applicants expect and it is where the money is lost. M.G.L. c. 15D, § 7(a)(i) requires that, prior to issuing any license, EEC shall "(1) obtain from the sex offender registry board all available sex offender registry information ... associated with the address of the program, center, facility or home; and (2) conduct fingerprint-based checks of the state and national criminal history databases, as authorized by Public Law 92-544." Note the first clause. The sex offender registry search runs against the ADDRESS of your home, not only against the names you list. If a registered sex offender lives at or near the address you propose to license, EEC finds that without anyone naming him, and 606 CMR 14.11(10) says what follows: "If EEC determines through an address match with SORB that an individual who is registered or required to be registered as a sex offender lives or works on or nearby the premises of a Program, EEC will immediately investigate and take appropriate action related to the Program."

Applicants who chose a unit before running that address search have lost the lease, the deposit and the renovation money. The same statute states who must be fingerprinted, and it reaches into your household. M.G.L. c. 15D, § 7(a)(i) continues: "The fingerprint-based checks shall be conducted on any current holder of or applicant for a family child care assistant certificate or any current holder of or applicant seeking a license for: family child care ... The fingerprint-based checks shall also be required for any household member, age 15 or older, or any person, age 15 or older, regularly on the premises of applicants for family child care licensure, as well as in-home non-relative caregivers." That is the statute, not a policy, and it is why a family child care application is never about one adult. 606 CMR 14.04 then defines the class with precision, and the definition of Family Child Care Candidate is the sentence to memorise: "The family child care licensee; family child care assistants; and all household members and persons regularly on the premises of the family child care home 15 years of age or older, regardless of whether the individuals are present during child care hours."

The closing clause does the damage. Your adult son who sleeps through your entire program day is a candidate; so is your mother-in-law in the finished basement, and your stepdaughter on her fifteenth birthday. None of them has to be near a child, or awake, or home. The threshold for "household member" is set in the licensing regulation, not the BRC regulation: 606 CMR 7.02 defines "Household Member" as "Any person other than the educator who resides in the family child care home for 30 consecutive days or more." Thirty consecutive days is the whole test, and 606 CMR 14.05(2)(b) imports it, requiring checks on "Household members, as defined by EEC licensing regulations at 606 CMR 7.02 ... 15 years of age or older, regardless of whether such individuals are present while child care children are present; and persons regularly on the premises (including volunteers and other regular visitors) 15 years of age or older." A nephew who moves in for a summer internship crosses thirty days at the end of the first month and becomes a person EEC must clear before your license issues or renews. "Regularly on the premises" is defined only in 606 CMR 14.04, and it is defined by exclusion: "Individuals who are present at a family child care home on a recurring basis, but do not reside at the home and are not employed by the program."

Recurring presence is the entire trigger: no hour count, no schedule, no minimum. EEC's applicant guidance at mass.gov/info-details/1-check-if-you-meet-fcc-licensing-requirements requires a BRC of anyone who "Lives in your home. It doesn't matter if they help with child care or are present during child care hours," anyone who "Frequently and predictably visits your home. This can include a family member, house cleaner, or friend," and anyone who "Helps run your program. It doesn't matter if they're paid, unpaid, or occasionally helping." The cleaner who comes every other Tuesday is a candidate; so is the boyfriend who comes to dinner every Thursday. Applicants routinely omit these people because they are not staff, and the omission does not merely delay the file: under 606 CMR 14.10(1)(e) knowingly making "a materially false statement in connection with a BRC" is itself a mandatory disqualification, and 606 CMR 14.04 defines that term to include information that "could have caused EEC to perform an invalid BRC, or lead to the omission of relevant BRC information." "Background check" in Massachusetts is five checks wearing one name. 606 CMR 14.05(2) closes the family child care paragraph: "The above candidates will be required to complete a CORI, DCF, SORI, NSOR, fingerprint-based check and all out of state checks mandated by CCDBG."

EEC at mass.gov/eec-background-record-checks names the same five layers and states the reach of the out-of-state layer: NSOR or "out of state records for any known criminal history, child welfare, and sex offender information where applicants have lived in the past five years." The CORI layer is not the sanitised employer CORI you may have seen before; 606 CMR 14.04 records that "EEC is legally authorized to receive information pursuant to M.G.L. c. 6, §§ 172 and 172F, including information in addition to CORI," and EEC's step 4 applicant page specifies that Massachusetts CORI here "Includes juvenile records, sealed records, non-delinquent findings, delinquent findings, convictions, and non-convictions." Sealed does not mean invisible. The DCF layer is the one applicants never see coming. 606 CMR 14.04 defines the DCF Check as a check of "its Central Registry and Registry of Alleged Perpetrators to determine if a candidate has been identified as the person responsible for abuse or neglect of a child in a supported M.G.L. c. 119, § 51B Report or is the alleged perpetrator of a pending investigation ... under M.G.L. c. 119, § 51A." A 51A filed years ago and supported at the 51B stage is on your record even though no court ever heard it and no conviction exists. A currently PENDING 51A stops everything: 606 CMR 14.11(8) provides that a candidate with "an outstanding warrant for any criminal offense or a pending DCF 51B investigation or out of state equivalent ... is ineligible for any position in an EEC Program" unless the warrant is removed, the investigation closes not supported, or EEC approves in writing.

And if the support lands on someone other than you, 606 CMR 14.11(9)(a) is unforgiving: "If the support or equivalent determination is against a household member or a person regularly on the premises of a family child care home, then the family child care licensee must stop caring for children, unless there is a written agreement with EEC for the program to continue operating." Your business closes on a finding about someone who does not work for you. The process runs through the BRC Navigator Program Portal in a fixed order. 606 CMR 14.08(1) states that "A signed consent form initiates the BRC process. Upon receipt of a BRC consent form, EEC will determine whether there is a final suitability determination on file for the candidate within the prior three years." 606 CMR 14.07(2) puts the paperwork burden on you, not on the household member: "Family child care licensees must submit EEC BRC consent forms for all family child care candidates (including household members and persons regularly on the premises 15 years of age or older)." Fingerprinting comes first, not last; EEC's FAQ states that "Fingerprinting is the first part of the process via the Navigator BRC Program Portal ...

After a candidate completes a fingerprinting scan, the other checks will be triggered." Nothing else moves until every household member has been printed. Appointments are made through IdentoGO and, in EEC's words, "walk-in service is not available"; you cannot book at all without the fingerprint notification letter, which carries the ID number the booking system demands. EEC's warning is set in bold on the state's own site: "If your name does not exactly match what you provide as an identification document, then you may be turned away from your appointment." A hyphenated married name entered one way in the portal and another way on a licence turns a household member away at the counter, and the queue restarts. The federal clock is 45 days and it does not start when you apply. EEC's policy statement of 30 August 2018, "45 Day Turnaround Time for Background Record Check Process," implements 45 CFR 98.43(e) and states that "the timeline begins on the date when the candidate is fingerprinted for EEC ... This 45 day turnaround policy excludes the time necessitated for the review of any relevant findings." 606 CMR 14.08(3) states the same rule as regulation, "within a maximum of 45 days from the date the candidate is fingerprinted by EEC approved means, excluding any time required for the review process."

Read the exclusion. If anything at all appears on any of your five checks, the 45 days stops counting, and an applicant who planned a September opening on the strength of "45 days" with a twenty-year-old dismissed charge on a CORI has mis-planned by a season. Family child care is the program type with the least procedural mercy, and this is the trap that separates it from centre-based care. In a group and school age programme a new hire can begin work provisionally, under supervision, while the checks finish. You cannot. 606 CMR 14.13(2)(e) is explicit: "Licensees, family child care candidates, relative caregivers, in-home non-relative caregivers, transportation personnel, temporary agency staff, and contracted/service providers may not be placed in provisional status." EEC's policy of 22 August 2023, "EEC Background Record Check Process by Program Type," repeats it: "FCC candidates cannot work in a provisional status; instead, they must complete the entire BRC process and obtain a suitable finding before they can receive a license or approval." 606 CMR 14.13(4)(a) states it as regulation: "Family child care licensees may not obtain or renew a license until the licensee and any household members and those regularly on the premises have a final suitability determination of 'suitable.'" There is no partial opening and no conditional day one.

Your slowest household member sets your opening date. Assistants are checked before they are approved, not after they start. 606 CMR 14.05(2)(c) covers "All current and prospective family child care assistants and volunteers, regardless of whether such individuals are present in an unsupervised capacity," and 606 CMR 14.09(2)(c) requires "a BRC ... complete with a final suitability determination issued ... before EEC will issue a certificate or approval." Volunteers in a family child care home are a special case. EEC policy BRC-26-01, "BRC Requirements for the Roles of Intern, Volunteer, and Affiliated Person for All Program Types," released 4 March 2026 and effective 1 April 2026, states that "In family child care programs, all volunteers are required to complete EEC's BRC process," while in every other programme type a volunteer needs a check only if unsupervised or counted in ratio; the 2023 process policy adds that "Volunteers in FCC homes must be run under the role of a person regularly on the premises." BRC-26-01 also states interns and affiliated persons "must complete a full BRC through the program, regardless of whether such individuals work in a supervised or unsupervised capacity" — since 1 April 2026 supervision is no longer an escape for an intern.

If you use a family child care system, the system's home visitor must be cleared: the 2023 policy's table lists "FCC System Staff — Always assumed to be regularly on the premises and unsupervised — Yes." The disqualification structure has three tiers and only one is survivable without work. Mandatory disqualification is defined at 606 CMR 14.10(1): a child care candidate is mandatorily disqualified if they "Are registered, or required to be registered, in any state or national sex offender registry, repository or database"; if they have "a felony conviction after a state or national criminal check" for first or second degree murder, "Crimes involving child abuse or neglect," "Crimes against children, including child pornography," spousal abuse, "Crimes involving rape or sexual assault," kidnapping, arson, or "Physical assault or battery"; if they have "a conviction as an adult ... for a violent misdemeanor committed against a child"; if they "Refuse to consent to an EEC BRC"; or if they "Knowingly make a materially false statement in connection with a BRC." Under 606 CMR 14.10(2) the registry and conviction categories "are for life as long as the disqualification appears on a record," while refusal to consent and false statement "last for up to three years subject to EEC's discretion."

That felony assault and battery line surprises adults with a decades-old bar fight on their record; it is a mandatory bar for life and, per 606 CMR 14.12(1), "A candidate with a mandatory disqualification may not have their disqualification reviewed, unless they successfully dispute the accuracy or completeness of the record." Presumptive disqualification is the tier where a case is winnable but expensive. 606 CMR 14.10(5) makes a candidate presumptively disqualified where the BRC discloses "Any pending charges, adjudications as a juvenile delinquent, Youthful Offender, non-conviction or not delinquent findings for an adult or juvenile, including sealed offenses and the equivalent, mandatory disqualification as defined in 606 CMR 14.10(1)"; "A supported DCF finding or out of state equivalent determination for sexual abuse"; or "A conviction for a felony drug offense within the three years prior to the date of the EEC BRC." Discretionary disqualification, at 606 CMR 14.10(6), captures non-convictions on the presumptive table, anything on the discretionary table, and, critically, where candidates "have been found to be the person responsible for the abuse or neglect of a child ... as appearing on any check of any state or national child welfare or child abuse and neglect registry or database." 606 CMR 14.18 tells you the tables live outside the regulation, "available as an EEC policy on the EEC website found on www.mass.gov," and the three tables EEC currently publishes are each labelled effective 10/1/18. There is a catch-all at 606 CMR 14.10(7): "Any criminal or child welfare offenses that are not specifically listed will be categorized and may warrant review as determined by EEC's General Counsel."

Nothing falls through. If you land in the presumptive tier, budget for a psychiatric evaluation and budget early. 606 CMR 14.12(2)(b)1 requires "A written assessment by a qualified mental health professional who is not the candidate's treating mental health professional or direct employer," concluding "whether the candidate poses an unacceptable risk of harm to the persons served." 606 CMR 14.04 defines Qualified Mental Health Professional narrowly — a psychiatrist under M.G.L. c. 112, § 2, a psychologist under §§ 118-121, a psychiatric nurse under §§ 74 and 80E, or an LICSW under §§ 130-132 — and adds two conditions that shrink the pool to a handful of practitioners: "at least 1,000 hours of experience over a minimum of two years involving assessment, treatment, and consultation concerning individuals with behavior that presents a risk of harm to others," and "Such individual may not have personally provided treatment to the candidate." Your own therapist is barred by rule from writing the letter that saves your licence. The only alternative is at 606 CMR 14.12(2)(b)2, "a letter from the candidate's criminal justice official, including a probation or parole officer that the candidate does not pose a risk of harm"; 606 CMR 14.04 limits that official to "The candidate's probation officer, parole officer or correctional facility superintendent (or designee)."

If you were never supervised, only the paid evaluation remains, and 606 CMR 14.12(2)(b)3 warns that failure to supply it in time "may result in the candidate being issued a 'not suitable' final suitability determination." The standard of proof in the review is high. 606 CMR 14.12(2)(e) provides: "Standard of Review: EEC shall require from the candidate clear and convincing evidence demonstrating the candidate's suitability for licensure, employment or affiliation in light of the concern for children's safety." The documents you may be asked for at 606 CMR 14.12(2)(c) are police reports, docket sheets, a candidate statement, child welfare documentation, reference letters, probation or parole documentation, imprisonment papers and evidence of rehabilitation; certified docket sheets for a 1990s case take weeks, so start on the day EEC's letter arrives. There is no lookback window that saves you: EEC's published answer to whether the age of an offence matters is "No, all offenses and supports are taken into consideration, regardless of how much time has passed since the offense or support.

This includes juvenile and sealed records." Renewal cadence is where the regulation and the statute part company, and you should follow the statute. There is no three-year interval anywhere in 606 CMR 14.09, titled "Submission and Frequency of Background Record Checks," which addresses only the exceptions that force an EARLY re-run. The three-year rule is statutory. M.G.L. c. 15D, § 8(d) provides that a person with unsupervised access to children in a licensed programme "and household members, age 15 or older, or persons regularly on the premises, age 15 or older, of family child care and large family child care homes shall be subject to a background record check not less than every 3 years," and that a person found suitable "shall not be subject to more than 1 fingerprint-based check every 3 years to maintain employment with the same employer." EEC's published guidance confirms the operational rule: "Both BRCs and fingerprints need to be renewed every 3 years," and, in the sentence applicants most often miss, "The BRC renewal cycle is independent of a license renewal cycle." Your family child care licence runs three years under 606 CMR 7.03(5)(b) — "A regular license or approval is valid for three years from the date of issuance" — but the two clocks drift, because the BRC clock starts at fingerprinting and the licence clock at issuance.

Watch the "fingerprint renewal" date in the Navigator portal, which EEC describes as "the date when the fingerprint expires." Seven circumstances force a re-run before the three years are up, and 606 CMR 14.09(3) lists them: candidates "who have moved outside of Massachusetts since the last EEC BRC was completed and who have had a break in employment or affiliation of 30 days or longer"; new charges, a child welfare investigation, or sex offender registration "in Massachusetts or any other state or territory"; candidates "who have a break of more than 180 days from being affiliated with an EEC Program"; discovery of "false, misleading or incomplete information on file"; candidates "who may be involved in any investigation"; resolution of a pending charge or child welfare matter; and candidates "who are changing their role or program type." That last one has a family child care example in EEC's suitability transfer policy BRC-2025-02, released and effective 15 October 2025: asked what a daughter who lives in the home and also wants to work as an assistant should do, EEC answers "Your daughter will need to apply for two Background Record Checks: one as an FCC Household Member and one as an FCC Assistant.

EEC recommends that she apply as an FCC Assistant first ... because the Suitability Determination is more likely to transfer from FCC Assistant to FCC Household Member than vice-versa." Two BRCs for one person under one roof, and the order decides whether you pay for one set of prints or two. That policy also fixes what a break in employment is not: "EEC does not consider a candidate taking leave to be a 'break in employment.'" Consent is annual even though the check is triennial, and this is where quiet licences fall out of compliance. 606 CMR 14.07(7) provides that each candidate "must recertify their consent for EEC on a yearly basis ... Failure to complete the consent form as required is independent grounds for finding a candidate 'not suitable'." 606 CMR 14.07(8) applies it to your household: "Family child care licensees must ensure that all family child care candidates (including household members and persons regularly on premises 15 years of age or older and family child care assistants) sign EEC's BRC consent form each year that they are present in the family child care program." A not suitable household member, under 606 CMR 14.13(4)(c), "may prevent the family child care licensee from obtaining, renewing or retaining their license."

That is a licence lost over a form. You also carry a continuing duty to report changes, and the licensing regulation gives you five days. 606 CMR 14.09(2)(b) requires that "Family child care licensees must disclose to EEC any changes to the composition to the family child care home, including the addition or removal of household members, or those regularly on the premises ... to ensure that a background record check is timely completed." 606 CMR 7.04(15)(d)2 sets the deadline: "In family child care, the licensee must notify the Department in writing within five days of the initiation of the legal proceedings ... which are brought against any educator, household member of the licensee or person regularly on the premises of the family child care home: a. any criminal or delinquency complaint listed in the Department's Background Record Check regulations; b. any civil action in which mistreatment or neglect of a child is alleged; and c. any petition alleging that a child ... is in need of care and protection." Five days from initiation, in writing, about someone who is not you. Separately, 606 CMR 7.11(4)(f) requires that "The licensee must notify the Department immediately upon learning that a report has been filed naming an educator or person regularly on the child care premises (including household members in family child care) an alleged perpetrator of abuse or neglect of any child."

Not the finding — the filing. And 606 CMR 7.08(9)(b) requires that you notify parents "of any changes in the regular composition of the household" and "of anyone regularly on the premises." Three notification duties, three audiences, one household event. When findings appear, EEC's letters carry short deadlines. EEC's published BRC results guidance states that a candidate with a mandatory disqualifying conviction "will be mailed a 'Mandatory Disqualification' letter that requires action within 7 calendar days," and that if confirmed the program must "remove the candidate from the program within 14 calendar days." 606 CMR 14.11(3) adds that "If a candidate with any disqualification fails to complete EEC's BRC Process within 45 days, EEC may issue a final suitability determination of 'not suitable'." Seven days from a mailed letter is how good applicants lose the file for reasons unrelated to the underlying record. What EEC owes you is set out at 606 CMR 14.11(4): before an adverse decision or as part of the licensing appeals process EEC will inform the candidate that they have "a disqualifying background," give them "a copy of their criminal record," and state "the candidate's right to dispute the accuracy of the BRC findings" and the process for doing so, with a copy of the CORI Policy.

Disputing accuracy is a separate route: EEC's guidance notes that a candidate disputes accuracy "with the relevant reporting agency (e.g., the Sex Offender Registry Board)," not with EEC. Appeals split by role, and family child care licensees get the better forum. 606 CMR 14.14(2) provides that "Licensees who have been found 'not suitable' after completing EEC's review process may file for an adjudicatory hearing at the Division of Administrative Law Appeals (DALA) within 21 days of receipt of the 'not suitable' final suitability determination," under 801 CMR 1.01 Formal Rules. Assistants get an internal forum: 606 CMR 14.14(4) sends "Certified and regular family child care assistants who have been found 'not suitable'" to "an adjudicatory hearing at EEC within 21 days" under 801 CMR 1.02 informal rules. The provision that most surprises households is 606 CMR 14.14(3): "A 'not suitable' determination for a family child care licensee due to the BRC of a household member or person regularly on the premises will entitle the family child care licensee to file an appeal ... The right to appeal is held by the licensee, not the family child care household member or person regularly on the premises."

Your housemate cannot appeal his own disqualification through this route; you appeal, in your own name, about his record. Mandatory disqualifications have no appeal at all: 606 CMR 14.14(1) provides that such candidates "do not have the right to undergo an appeals process with EEC. EEC's 'not suitable' determination is final and results in a lifetime ban under CCDBG, unless the candidate's disqualification is expunged, pardoned or otherwise permanently removed from their record." Reapplication windows are long. 606 CMR 14.14(7) lets candidates refused "for failing to respond or providing false information or related to a pending offense ... reapply at any time, but must repay all associated fees," with a three-year bar for repeat offenders. 606 CMR 14.14(8) is harsher: "Candidates whose 'not suitable' results from a comprehensive BRC review of all adverse findings may not reapply for a period of five years." Two traps in EEC's own web pages. The first: the "EEC BRC Requirements: Applicability, Frequency" page reads "For family child care, residential programs, and placement agencies: Only individuals present in an EEC-licensed program with the potential for unsupervised access to children (including household members and persons regularly on the premises in family child care homes) must complete a Background Record Check."

Read literally, that suggests a household member with no access to children escapes. The regulation says the opposite: 606 CMR 14.05(2)(b) requires household members 15 and over "regardless of whether such individuals are present while child care children are present." When an agency page and 606 CMR 14.00 disagree, the regulation is the law and your licensor applies the regulation. The second: the fingerprinting FAQ is headed "If I need to renew my program license with EEC every 2 years must I get fingerprinted every 2 years?" — but 606 CMR 7.03(5)(b) gives a regular family child care licence three years, not two. Do not calendar your renewals off a question heading. Cost and mechanics. There is no application fee for a family child care licence; EEC's applicant guide states that "There is no cost to apply for a license" and that "It can take 2-6 months to complete licensing steps." The fingerprinting is billed to the individual at the IdentoGO appointment, and the charge falls on every adult household member and every person regularly on the premises, not only on you — a four-adult household pays four times. 606 CMR 14.15(1) makes the licensee "responsible for ensuring all candidates submit consent and renew their consents annually," and 606 CMR 14.16 warns that "EEC shall periodically review BRC documentation maintained by Programs."

One last structural point: 606 CMR 14.02 provides that "Nothing in 606 CMR 14.00 shall be construed to create a private right of action," and 606 CMR 14.11(13) lets EEC, where results "may pose a risk of harm to children in the program," "require immediate removal of the candidate or require that the candidate cease caring pending a final suitability determination or sooner within the discretion of EEC." The Department can stop your programme mid-week on a suspicion, and the regulation gives you no cause of action for it. Plan the household, the consents and the fingerprint appointments, and do not sign a lease before you have run the address.

Is this legal advice?

No. DaycareLicensePrep gives general information based on each state's published child-care licensing rules, dated to when we last verified them, and is not a guarantee of licensure. Always confirm with your state's licensing agency before applying.

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Source: PRIMARY SOURCES ACTUALLY OPENED DURING RESEARCH, FIELD BY FIELD (not summarised from memory). [agency] https://www.mass.gov/orgs/department-of-early-education-and-care - EEC organisation page, read 26 Aug 2026; entry point used instead of any pinned regulation URL. Establishes the "Laws, Regulations, Policies" path and that mass.gov serves EEC pages under the Executive Office of Education. https://www.mass.gov/eec-laws-regulations-and-policies - EEC Laws, Regulations, and Policies hub, read 26 Aug 2026; routes to the index of regulations in effect and to the proposed-amendments page. https://www.mass.gov/lists/eec-laws-and-regulations - THE INDEX OF RULES IN EFFECT, read 26 Aug 2026. Serves, as the licensing regulations currently in force: 606 CMR 3 (with an explicit "Effective November 17, 2026" label), 606 CMR 5, "Family, group & school age child care programs (606 CMR 7)" with no forward date, "Enforcement standards and definitions for licensure or approval (102 CMR 1)", 606 CMR 10, 606 CMR 14, 606 CMR 15, and M.G.L. c. 15D. This index, not a pinned PDF, is what fixes the current text. https://www.mass.gov/doc/family-group-school-age-child-care-programs-606-cmr-7-0/download - the 606 CMR 7.00 file the index serves today; 54 pages; full text read.

Source of the version stamp "(Mass. Register #1459 12/24/21)", the closing line "REGULATORY AUTHORITY 606 CMR 7.00: M.G.L. c. 15D", 7.03(1)(b)-(c), 7.03(2), 7.03(5)(b)-(f), 7.14(3) fixing 22 January 2010 as the date 606 CMR 7.00 replaced 102 CMR 7.00/8.00. https://www.sec.state.ma.us/reg_pub/pdf/600/606007.pdf - Secretary of the Commonwealth's own numbered copy of 606 CMR 7.00, reached by navigating the Secretary's regulation-by-number listing (numerical.htm to agencies/102-early-education-and-care.htm), not by a remembered link. Same 54 pages, same text, published 2021-12-24. Two independent servers agreeing is what establishes that no newer version exists. https://www.sec.state.ma.us/divisions/bookstore/numerical.htm and https://www.sec.state.ma.us/divisions/bookstore/agencies/102-early-education-and-care.htm - Secretary of the Commonwealth CMR listing pages, read 26 Aug 2026; confirm 606 CMR is a live title of the Code of Massachusetts Regulations and that 102 CMR 1.00-12.00 is still a sold, live compilation. https://www.mass.gov/info-details/early-education-care-eec-proposed-amendments-to-regulations - read 26 Aug 2026; states verbatim "Department of Early Education & Care does not have any proposed amendments to its regulations at this time."

Establishes that no 606 CMR 7 rulemaking is pending. https://www.mass.gov/doc/enforcement-standards-and-definitions-for-licensure-or-approval-102-cmr-1/download - full text of 102 CMR 1.00 as EEC serves it today.

Source of the "102 CMR: OFFICE OF CHILD CARE SERVICES" headers, 1.01 (adopted under M.G.L. c. 28A), 1.02 definitions naming the Office of Child Care Services, the Office for Children and the Department of Social Services, 1.03, 1.04(1) (effective 1 May 1997), 1.05(1)(a)-(d), 1.06(3)-(4), 1.07(2)-(6) including the $50-$250 family day care fine range and the five-year bar, 1.08(1)-(3) (7-day reconsideration, 21-day Notice of Claim, 801 CMR 1.01), 1.09, and the closing "REGULATORY AUTHORITY 102 CMR 1.00: M.G.L. c. 28A." https://malegislature.gov/Laws/GeneralLaws/PartI/TitleII/Chapter28A - read 26 Aug 2026; the whole chapter is served as "Chapter 28A: OFFICE OF CHILD CARE SERVICES - [Repealed, 2008, 215, Sec. 43.]" This is what proves the sole regulatory authority of 102 CMR 1.00 was repealed in 2008 and that the regulation is nonetheless still incorporated by reference by 606 CMR 7.03(1)(c)1 and 7.03(5)(d). https://malegislature.gov/Laws/GeneralLaws/PartI/TitleII/Chapter15d - chapter index for M.G.L. c. 15D as the Legislature serves it today: Sections 1 through 22 only, no Section 23. https://malegislature.gov/Laws/GeneralLaws/PartI/TitleII/Chapter15D/Section23 - returns 404 Page Not Found on 26 Aug 2026. This is the direct evidence that the codified chapter has not absorbed the PROTECT Act and that only the session law carries the current requirement. https://malegislature.gov/Laws/GeneralLaws/PartI/TitleII/Chapter15D/Section1A, /Section2, /Section3, /Section4, /Section4A, /Section6, /Section7, /Section8, /Section9, /Section10, /Section11, /Section15, /Section17, /Section21 - full current text of each read individually 26 Aug 2026. Sources of every statutory quotation in the entry, including Section 2 first sentence and clause (c);

Section 3(a)-(b) (board, quorum of 6, 6 affirmative votes); Section 4 (2/3 vote nomination, secretary appoints, board removes by majority); Section 4A(a) (sub-state regions); Section 6(a) and 6(e); Section 7(a)(i)-(ii), 7(b), 7(d); Section 8(a)-(m) including 8(c) large-family prerequisites, 8(d) three-year BRC cycle, 8(g) fine caps, 8(h) consultation duty, 8(i) five-year regulatory review, 8(l) fingerprint fee and Fingerprint-Based Background Check Trust Fund; Section 9(a)-(c) including the "large family day care homes" inspection mandate; Section 10; Section 15(a)-(b); Section 17(b), (e), (j). https://malegislature.gov/Laws/SessionLaws/Acts/2026 - index of the Acts of 2026 swept act by act, read 26 Aug 2026; used to locate Chapter 137 (FY2027 GAA) and Chapter 163, and to establish that no standalone early-education act was enacted in 2024, 2025 or 2026. https://malegislature.gov/Laws/SessionLaws/Acts/2026/Chapter163 - full enrolled text of the PROTECT Act, "AN ACT PROMOTING RULE OF LAW, OVERSIGHT, TRUST AND EQUAL CONSTITUTIONAL TREATMENT," emergency preamble, "Approved, August 5, 2026." SECTION 3 adds M.G.L. c. 15D, Section 23 (quoted verbatim in the entry);

SECTION 19 sets the family child care policy deadline of 1 September 2026 or the first day of the 2026-2027 school year, whichever is earlier. https://malegislature.gov/Laws/SessionLaws/Acts/2026/Chapter137 and https://malegislature.gov/Laws/SessionLaws/Acts/2025/Chapter9 - full text of the FY2027 and FY2026 General Appropriation Acts, downloaded and searched.

Both mention chapter 15D only in line-item conditions; neither amends any section of chapter 15D. Establishes that the budget outside sections did not change the licensing scheme. https://www.mass.gov/doc/eecfo-26-01emergency-preparednessadvisory/download - EEC Policy Advisory FO-26-01, "Emergency Preparedness in Child Care Programs," Release Date August 21, 2026, Effective Date September 1, 2026. Source of the citation "G.L. c. 15D, Section 23(b) (codifying Stat. 2026, c. 163, Section 3)", the attestation route, the 4 September 2026 LEAD "Protect Act" upload category and the 1 November 2026 LEAD Section 11 deadline. https://www.mass.gov/lists/eec-policy-transmittals - EEC policy transmittal index read 26 Aug 2026; establishes the 2026 advisory set including RP-26-13 Interactions with Civil Law Enforcement, FO-26-04, FO-26-03, FO-26-02, FO-26-01, BRC-26-01. https://www.mass.gov/orgs/department-of-early-education-and-care/locations - EEC locations page read 26 Aug 2026; "Showing 1 - 6 of 6 results".

Source of every regional address, phone number and business-hours line, and of the fact that the published regions are 1, 2, 3, 5 and 6 with no Region 4. https://www.mass.gov/info-details/staff-directory-key-contacts-at-the-department-of-early-education-and-care-eec - read 26 Aug 2026; source of Commissioner Amy Kershaw, Deputy Commissioner of Field Operations Joseph Rucker, and the five named regional licensing directors. https://www.mass.gov/info-details/members-of-the-board-of-early-education-and-care - read 26 Aug 2026; source of the current board roster, including the published "Massachusetts Teachers Association and Massachusetts Federation of Teachers Seat - VACANT". https://www.mass.gov/about-the-department-of-early-education-and-care-eec - read 26 Aug 2026; source of "The Department of Early Education and Care (EEC) is part of the Executive Office of Education...", the Zrike and Healey references, and the scale figures (approximately 9,000 programs, estimated 257,000 children of capacity, average 62,000 children supported daily). https://www.mass.gov/info-details/3-submit-your-fcc-license-application - read 26 Aug 2026; source of "You have 90 days to complete the process", the LEAD access route, the tax certification statement and the BRC consent-form sequence including separate consent forms for household members aged 15 or older. https://www.mass.gov/info-details/4-complete-your-fcc-background-record-check - read 26 Aug 2026; source of the CORI, DCF 51B, SORI, FBI, NSOR and five-year out-of-state check list. https://www.mass.gov/child-care-program-licensing - read 26 Aug 2026; confirms the LEAD portal and the Unlicensed Child Care Complaint Form at childcare.mass.gov/reportunlicensedcare.

CONTRADICTION OF THE BRIEF, STATED EXPLICITLY AS METHOD REQUIRES. The brief instructed me to "verifier si le transfert d'EEC annonce sous l'Executive Office of Education a change l'autorite qui delivre." The official text contradicts the premise. There is no 2026 transfer. M.G.L. c. 15D, Section 2 has read "There shall be in the executive office of education a department of early education and care" since the 2008 education reorganisation, and EEC's own About page states the same placement today. The licensing authority has not changed, the rule citation has not changed, and no session law of 2024, 2025 or 2026 touches it. What the brief could not have known, and what is genuinely new, is the opposite kind of change: Chapter 163 of the Acts of 2026, approved 5 August 2026, added a Section 23 to chapter 15D that the Legislature's own codified chapter did not yet serve on 26 August 2026, imposing a written civil-law-enforcement policy on every family child care home by 1 September 2026. That is the current Massachusetts development, and it is in the session law only. UNVERIFIED: the amount of the family child care licence application fee. 606 CMR 7.03(1)(c) requires "the required license application fee" and 102 CMR 1.03(5) says only that "A fee schedule may be obtained from the Office."

No fee schedule is published on any EEC page read on 26 August 2026, and EEC's own six-step "Become a Family Child Care Provider" guide never mentions a fee. The entry says the fee is required by rule and does not state an amount. UNVERIFIED: whether EEC has ever formally repealed, replaced or re-promulgated 102 CMR 1.00 under M.G.L. c. 15D rather than the repealed c. 28A. No Massachusetts Register citation for such an action was found, and EEC's current index still serves the 1997 text unchanged. The entry reports the conflict rather than resolving it. UNVERIFIED: whether a Region 4 exists as an internal EEC designation. Five regional offices are published, numbered 1, 2, 3, 5 and 6, with five named regional directors. The entry states what is published and does not speculate about the missing number. UNVERIFIED: the date on which Amy Kershaw's current term as Commissioner began. EEC's person page returned no biography text when read on 26 August 2026; only the staff directory listing was readable. The entry names her as the sitting Commissioner and gives no start date. NOTE ON ACCESS: www.mass.gov and www.sec.state.ma.us both refused direct requests from this machine (mass.gov returned HTTP 403 to a normal browser user-agent; sec.state.ma.us is behind an Incapsula challenge).

Every mass.gov and Secretary of the Commonwealth document above was retrieved through the r.jina.ai reader proxy, which returns the target page's own text; the content is the official text, the transport was not direct. malegislature.gov was reached the same way. No dated or previously known URL was re-downloaded to confirm itself; every regulation was reached by navigating the agency's current index or the Secretary's current listing. [annual_training_hours] All URLs below were opened on 26 August 2026 from this machine. HTTP status codes quoted in the field text were measured, not assumed. https://www.sec.state.ma.us/reg_pub/pdf/600/606007.pdf — Secretary of the Commonwealth's copy of 606 CMR 7.00, Standards for the Licensure or Approval of Family Child Care; Small Group and School Age and Large Group and School Age Child Care Programs. Downloaded and converted to text in full (253,115 characters). Server reports last-modified Fri, 24 Dec 2021. Source of every verbatim quotation of 7.02 (definitions of Family Child Care, Diverse Learners, Professional Development, Continuing Education Unit, Educator, Department), 7.03(1)(b), 7.03(1)(c)1, 7.03(3), 7.03(5)(a)-(e), 7.04(5), 7.09(4), 7.09(9), 7.09(11)-(12), 7.09(15)(b)-(g), 7.09(17)(a), 7.09(20), 7.10(4)(d)-(h), 7.10(7)(d), 7.11(1), 7.11(2), 7.11(4)(d), 7.11(13)(e), 7.11(19)(a)9, 7.12(2), and the closing REGULATORY AUTHORITY line "606 CMR 7.00: M.G.L. c. 15D". https://www.law.cornell.edu/regulations/massachusetts/606-CMR-7-09 — Cornell LII, 606 CMR 7.09. Used ONLY as a second, independent witness to the amendment history, per method rule 1 (never treat one pinned file as self-confirming).

Notes read verbatim: "Amended by Mass Register Issue 1452, eff. 9/1/2021. Amended by Mass Register Issue 1459, eff. 9/1/2021." No later amendment listed. Cornell's rendering of 7.09(20) matches the Secretary's PDF word for word, which is how the 2021 file was confirmed to be the text in effect rather than a stale copy. https://www.sec.state.ma.us/reg_pub/pdf/100/102001.pdf — 102 CMR 1.00, Enforcement Standards and Definitions for Licensure or Approval, headed "102 CMR: OFFICE OF CHILD CARE SERVICES", server last-modified 9 July 2004. Source of the 102 CMR 1.05(1) quotation. Establishes that 606 CMR 7.03(1)(c)1 still routes an applicant to a chapter of a title named for an agency folded into EEC in 2005. https://www.sec.state.ma.us/reg_pub/pdf/600/606014.pdf — 606 CMR 14.00, Criminal Offender and Other Background Record Checks; section list read (14.05 candidate categories, 14.09 submission and frequency, 14.10 disqualifications, 14.13 provisional and conditional hiring, 14.18 Table of Disqualifying Offenses). Server last-modified 24 Dec 2020. https://childcare.mass.gov/educators — EEC's new Professional Portal, live, HTTP 200, footer "© 2026 Commonwealth of Massachusetts", masthead "DEPARTMENT OF EARLY EDUCATION AND CARE".

Source of the quotations about the new StrongStart LMS, about PQR ("PQR isn't available in the portal yet. At this time, you need to continue using PQR for annual registration..."), and about certifications approved "before November 2025". Establishes that the licensing agency is still EEC despite the move of its web estate. https://strongstart.eoe.mass.gov/ — HTTP 301 redirect to https://childcare.mass.gov/educators, measured. The two StrongStart course-store item pages that search engines still return as the canonical booking route for family child care orientation, /ets/store/item/?id=ca359579-4d3a-11ec-aacd-c718e78a9b2f ("Potential Provider Training for FCC") and /ets/store/item/?id=942c5145-4e7c-11ef-ac0a-e9894fafac72 ("Potential Educator Meeting"), both also return 301 to the same landing page. No course detail is served at either. https://www.eec.state.ma.us/PQRegistry/ — Professional Qualifications Registry, live, HTTP 200. Source of "Educators, including assistants, who work with infants, toddlers, preschoolers, or school age children in EEC-licensed settings are required to register" and of the annual-registration/renewal description. https://www.mass.gov/doc/professional-development-policy/download — EEC Licensing POLICY STATEMENT: Professional Development, control number EECLicensingProfDev20120904, 7 pages.

Source of the Core Competencies requirement, trainer/instructor qualification bullets, the exclusion list (committee meetings, staff meetings, First Aid and CPR, program orientation, repeats), the hour-calculation rule, CEU/PDP/CEC conversions and accepted CEU-awarding bodies, the "banking" rule and the calendar-year wording, Trainer's Development Credit, the six-item documentation specification, and the restatement of 7.09(15)(f), 7.09(16)(c) and 7.09(19)(b) hour counts. https://www.mass.gov/doc/orientation-to-early-education-and-care-0/download — EEC POLICY STATEMENT: Orientation to Early Education and Care, footer control number EECOrientation20121004 (document properties: printed 4 Oct 2012, last modified 16 Oct 2014). Source of the five-hour in-person family child care orientation by an EEC-approved trainer within one year prior to application, Module Two within six months, "Maintaining Quality While Expanding Your Capacity" for 7-10 capacity, the regular-assistant module, the SIDS module before licensure, "Look Before You Lock" within 60 days, "Medication Administration: The Five Rights", and the completion standard for online modules. https://www.mass.gov/doc/eec-policy-advisory-field-operations-9-eec-essentials-training-policy/download — EEC POLICY ADVISORY, Field Operations 2024-9, "Policy: EEC Essentials 2.0", Effective Date May 8, 2024, signed under Commissioner Amy Kershaw.

Source of the CCDBG/Office of Child Care origin, the "before working with children" rule for new staff, the FCC-specific applicability sentence, the 13-course / ~12 hour package figure, the annual 3-hour Refresher, the 1 July 2025 monitoring start, the ratio-counted staff scope including volunteers/interns/substitutes, and the statement that it supersedes the EEC Essentials policy revised 1 February 2020. https://www.mass.gov/doc/eec-essentials-faq/download — EEC Essentials 2.0 FAQs, dated April 2024, 8 pages.

Source of the thirteen module titles verbatim, "For Family Child Care providers and assistants, the EEC Essential 2.0 training package needs to be completed prior to licensure", "counts toward ... the first time it is taken", "none of these trainings count towards EEC licensing training requirements in diverse learners", "Does this replace the mandatory 51A training? Yes", the CPR/First Aid non-replacement answer, the legacy-training replacement list, the single-certificate rule, and the PQR-active requirement. https://www.mass.gov/doc/cpr-and-first-aid-training-and-certification/download — EEC POLICY: CPR and First Aid Training and Certification, Effective Date October 1, 2020, Updated December 17, 2021. Source of the 31 August 2021 emergency-revision account removing annual CPR renewal, the hands-on skills-demonstration requirement, the CPR course content bullets, the seven acceptable first-aid instructor certifying organisations, "EEC does not maintain an approved list of individual First Aid and CPR trainers", and the cease-care sanction for expired certification. https://www.mass.gov/doc/eec-safe-sleep-policy-2023-0/download — EEC Policy: Safe Sleep for Infants, Effective Date October 1, 2023. Source of the pre-service safe sleep / Shaken Baby training sentence and the 10-business-day retraining consequence after a first citation.

https://www.mass.gov/doc/choking-hazard-training/download — EEC family child care POLICY STATEMENT: Required USDA Nutrition Guidelines and Choking Hazard Training, control number FCCChokingHazardTraining20121128. Source of "There is currently no formalized training solely on this topic" and of the 1 professional development hour allowance. https://www.mass.gov/doc/use-of-regular-assistants-in-family-child-care-homes/download — EEC POLICY STATEMENT: Use of Regular Assistants in Family Child Care Homes, control number FCCRegularAssistants20120626. Source of "no provider may leave their child care children with an uncertified assistant for more than a total of 8 hours per week or a total of 25 hours per year, no matter how many assistants he/she uses."

ACCESS NOTE ON THE mass.gov DOCUMENTS ABOVE. Every www.mass.gov URL returns HTTP 403 to this machine (both direct GET and the WebFetch tool), for HTML pages and for /doc/ downloads alike; the block is at mass.gov's edge, not a permissions issue. Each of the seven policy documents was therefore retrieved through the Internet Archive (web.archive.org/web/2026/<mass.gov URL>), which serves the mass.gov file itself. The documents' own internal control numbers and effective dates (EECLicensingProfDev20120904, EECOrientation20121004, Field Operations 2024-9 of 8 May 2024, CPR policy updated 17 Dec 2021, Safe Sleep 1 Oct 2023, FCCChokingHazardTraining20121128, FCCRegularAssistants20120626) are quoted from the retrieved files, so the dating does not depend on the archive's timestamp. https://web.archive.org/web/20260613122642/https://www.mass.gov/info-details/eec-licensing-policies-forms-and-technical-assistance — EEC Licensing Policies, Forms and Technical Assistance index, snapshot 13 June 2026. Confirms "Professional Development Policy" is still a currently published EEC policy. https://www.mass.gov/lists/licensing-policies-for-family-child-care-providers-0 (via web.archive.org snapshot 3 September 2025) — EEC's index of Licensing Policies for Family Child Care Providers.

Full page text extracted and searched: the string "orientation" appears ZERO times. The 2012 Orientation to Early Education and Care policy is no longer listed among the policies EEC publishes for family child care, although its /doc/ file still resolves. The page does list "EEC Policy Advisory - Field Operations 9 - EEC Essentials Training Policy", "EEC Essentials FAQ", "CPR and First Aid Training and Certification", "EEC Safe Sleep Policy 2023", "Choking Hazard Training" and "Use of Regular Assistants in Family Child Care Homes". DEAD-LINK MEASUREMENTS, taken 26 August 2026, each cited inside the field text: http://www.eec.state.ma.us/docs1/Workforce_Dev/SIDS%20revised%20self-study.pps — HTTP 503 http://www.eec.state.ma.us/docs1/Workforce_Dev/20120502-look-before-lock.pps — HTTP 503 http://www.eec.state.ma.us/docs1/regs_policies/FiveRightsMedAdmin/The5RightsofMedicationAdminis.htm — HTTP 503 http://www.eec.state.ma.us/docs1/regs_policies/FCCAssistOrient/FCCAssistantOrient.htm — HTTP 503 http://www.eec.state.ma.us/ProfessionalDevelopment/WebFindTraining.aspx — HTTP 503 http://www.mass.gov/edu/docs/eec/20101015-fcc-expansion-training.ppt — HTTP 403 (The first five are every training URL the operative 2012 orientation policy instructs a family child care applicant to use; the sixth is the capacity-expansion module for 7-10 children.) CONTRADICTIONS OF THE LOT 7 BRIEF, WITH THE TEXT IN HAND: 1. The brief asks whether "le transfert d'EEC annonce sous l'Executive Office of Education a change l'autorite qui delivre".

It has NOT. 606 CMR 7.00 names the Department of Early Education and Care as licensing authority throughout; 606 CMR 7.02 provides "Department - When used alone shall mean the Department of Early Education and Care"; the regulatory authority line is still M.G.L. c. 15D; EEC's own live portal is masthead-headed "DEPARTMENT OF EARLY EDUCATION AND CARE" with a 2026 copyright. What moved is the professional development web estate (strongstart.eoe.mass.gov, now 301 to childcare.mass.gov/educators). Reporting an authority change would be false. 2. The brief frames MA as "distinction family child care <= 6 + 2 d'age scolaire vs large family (10)". THERE IS NO SECOND LICENCE CATEGORY. 606 CMR 7.02 defines family child care as one thing, "no more than ten children younger than 14 years old". What varies is licensed CAPACITY and the qualification tier that unlocks it: 7.09(15)(b)1 for six or fewer, 7.09(15)(b)2 for seven or eight, 7.09(15)(b)3 for nine or ten. The "six plus two school age" figure is a RATIO row, 606 CMR 7.10(4)(e), which permits seven or eight children with ONE educator only where "All children over capacity of six must be school age"; 7.10(4)(g) requires TWO educators for seven to ten in the general case.

Massachusetts uses no "large family child care home" licence. 3. The brief's framing of a mandated topic list (SIDS/safe sleep, shaken baby, medication administration, mandated reporter) is not satisfied by 606 CMR 7.00. The chapter imposes the underlying duties (7.11(13)(e) back sleeping, 7.11(4)(d) mandated reporter status, 7.11(1) medication administration training) but enumerates NO course in SIDS, shaken baby or mandated reporting. The topic list exists only in the policy layer, as the thirteen modules of EEC Essentials 2.0 under Policy Advisory Field Operations 2024-9, which the FAQ says replaces "the mandatory 51A training". Anyone deriving the topic list from the Code of Massachusetts Regulations alone will get it wrong in both directions. 4. Method rule 1 applied and it mattered: the Secretary of the Commonwealth's 606 CMR 7.00 file is dated December 2021 and would have confirmed itself. It was cross-checked against the codified amendment notes (Register Issues 1452 and 1459, eff. 9/1/2021) before being relied on, and 606 CMR 7.09(20) was found in both, which is what makes the 2021 file the text in effect rather than a stale artefact.

FIELD-SPECIFIC NOTE (annual_training_hours): the per-year vs per-cycle question resolves cleanly and against the way most vendors sell training. 606 CMR 7.09(15)(f) states the obligation PER YEAR (five hours or ten hours by work volume); 606 CMR 7.03(5)(b) makes the family child care licence valid "for three years from the date of issuance"; the two are never reconciled into a per-renewal total anywhere in the chapter or in EEC policy. The arithmetic consequence (thirty hours across a licensing period for a full-time educator) is stated in the field text as arithmetic, not quoted as rule text. The YEAR is a calendar year, established from the banking clause of EECLicensingProfDev20120904 ("the following calendar year"), not from the licence anniversary. The second finding worth flagging to the coordinator: EEC Essentials 2.0 counts toward the annual hours only "the first time it is taken", and "none of these trainings count towards EEC licensing training requirements in diverse learners". Both sentences are verbatim from the April 2024 FAQ. Together they mean the federally mandated twelve-hour package cannot satisfy the one-third diverse-learner composition rule in 606 CMR 7.09(15)(f)3 in any year, including the year it is taken.

UNVERIFIED: whether the annual three-hour EEC Essentials Refresher itself counts toward the ten annual professional development hours. Policy Advisory 2024-9 imposes the Refresher; the April 2024 FAQ's crediting answer is written about "completion of the EEC Essentials 2.0 training package ... the first time it is taken" and predates the Refresher's release (the FAQ says EEC "anticipates they will be available in April 2025"). No EEC document reachable from this machine addresses the Refresher's credit status. The field text therefore treats the Refresher as an additional obligation and does not assert that it does or does not count. UNVERIFIED: whether EEC has issued any professional development policy superseding EECLicensingProfDev20120904. It is still listed as "Professional Development Policy" on EEC's Licensing Policies index as of the 13 June 2026 snapshot, and no successor is listed there, but mass.gov's live HTML is unreachable from here so a very recent replacement cannot be excluded. UNVERIFIED: whether the Commissioner has exercised 606 CMR 7.09(20) to revise or rescind the 7.09(15)(f) hour counts at any point after the 31 August 2021 emergency revisions.

No such advisory appears on the EEC policy indexes reachable from here. The field text names the power and tells the reader to check the index annually rather than asserting that it has not been used. [background_check] All URLs below were opened on 26 August 2026, starting from the EEC index of regulations in effect (never from a pinned dated file). https://www.mass.gov/lists/eec-laws-and-regulations — THE INDEX OF RULES IN EFFECT as served today. Under "Background Record Checks (BRC) Regulations" it serves exactly one file, "EEC BRC Regulations (606 CMR 14)" (PDF, 974.99 KB). Under "EEC Laws" it links only to M.G.L. c. 15D. This is the starting point required by method rule 1. https://www.mass.gov/doc/eec-brc-regulations-606-cmr-14/download — the full 37-page text of 606 CMR 14.00 that EEC serves TODAY. Established every quotation from 14.01 through 14.18. Two facts about the file itself matter: its credits lines record the last substantive amendment as "1433 Mass. Reg. 81, amended eff. Dec. 25, 2020", and its currency line reads "The Massachusetts Administrative Code titles are current through Register No. 1467, dated April 15, 2022." The file EEC publishes as its BRC regulation is a Westlaw print, not a live-current text. https://www.mass.gov/info-details/early-education-care-eec-proposed-amendments-to-regulations — "Department of Early Education & Care does not have any proposed amendments to its regulations at this time."

Confirms nothing is pending against 606 CMR 14.00 or 606 CMR 7.00 as of 26/08/2026. https://malegislature.gov/Laws/GeneralLaws/PartI/TitleII/Chapter15D/Section7 — M.G.L. c. 15D, § 7 verbatim, as the legislature's site serves it today. Established the licensing authority sentence in § 7(a), the SORB ADDRESS search and P.L. 92-544 fingerprint mandate in § 7(a)(i), and the statutory extension to "any household member, age 15 or older, or any person, age 15 or older, regularly on the premises." https://malegislature.gov/Laws/GeneralLaws/PartI/TitleII/Chapter15D/Section8 — M.G.L. c. 15D, § 8 verbatim.

Established that the THREE-YEAR BRC cadence is statutory (§ 8(d)), not regulatory, and the one-fingerprint-per-three-years rule for the same employer; § 8(j) established the State Police / FBI routing. https://www.mass.gov/doc/family-group-school-age-child-care-programs-606-cmr-7-0/download — 606 CMR 7.00 as served today (running header "(Mass. Register #1459 12/24/21)"). Established the 606 CMR 7.02 definition of "Household Member" (30 consecutive days), 7.03(5)(b) three-year license term, 7.04(15)(d)2 five-day written notification duty, 7.08(9)(b) parent notification of household composition, 7.11(4)(f) immediate notification on a 51A filing. https://www.mass.gov/doc/background-record-check-process-by-program-type-for-all-program-types-policy/download — EEC policy effective 22 August 2023. Established that FCC candidates cannot work provisionally, that all household members and persons regularly on the premises must be suitable before a license issues, that FCC volunteers are run under the "person regularly on the premises" role, and the Third Party Affiliates table ("FCC System Staff — Always assumed to be regularly on the premises and unsupervised — Yes"). https://www.mass.gov/doc/transfer-of-suitability-and-frequency-of-background-record-checks/download — EEC policy BRC-2025-02, released and effective 15 October 2025. Established the seven ineligibility grounds for a suitability transfer, the "leave is not a break in employment" rule, and the FCC daughter FAQ (two BRCs, assistant first).

Note: this policy carries EEC's current address, 50 Milk Street, 14th Floor, Boston, MA 02109 — EEC has moved from 51 Sleeper Street. https://www.mass.gov/doc/eecbrc-26-01interns-volunteers-and-affiliated-personspolicy-1/download — EEC policy BRC-26-01, released 4 March 2026, EFFECTIVE 1 APRIL 2026. Newest instrument in this field. Established that in family child care ALL volunteers require a BRC, and that interns and affiliated persons need a full BRC "regardless of whether such individuals work in a supervised or unsupervised capacity." Replaces the September 2019 interns and volunteers policy. https://www.mass.gov/doc/45-day-turnaround-time-for-background-record-check-process/download — EEC policy statement dated 30 August 2018 implementing 45 CFR 98.43(e); established that the 45-day clock starts at FINGERPRINTING and excludes review time. https://www.mass.gov/info-details/eec-brc-requirements-fingerprinting — established the three-year BRC and fingerprint renewal, "The BRC renewal cycle is independent of a license renewal cycle," the IdentoGO booking mechanics (no walk-ins, letter required), the bolded name-match warning, and that fingerprinting is the FIRST step in Navigator. https://www.mass.gov/info-details/questions-on-other-background-record-check-brc-topics — EEC's "BRC Requirements: Applicability, Frequency" page.

Established the seven early re-run triggers as EEC states them and the staff-roster window (no earlier than 120 days, no later than 30 days before license expiry). https://www.mass.gov/info-details/eec-brc-results — established the 7-calendar-day mandatory disqualification letter, the 14-calendar-day removal letter, "Federal law does not provide appeal rights for a Mandatory Disqualification," and "No, all offenses and supports are taken into consideration, regardless of how much time has passed." https://www.mass.gov/eec-background-record-checks — established EEC's own five-layer description of a BRC and the five-year out-of-state residence reach. https://www.mass.gov/info-details/4-complete-your-fcc-background-record-check — established that the MA CORI layer here "Includes juvenile records, sealed records, non-delinquent findings, delinquent findings, convictions, and non-convictions." https://www.mass.gov/info-details/1-check-if-you-meet-fcc-licensing-requirements — established EEC's plain-language statement of who must be checked (lives in your home; frequently and predictably visits; helps run your program, paid or unpaid). https://www.mass.gov/guide/become-a-family-child-care-provider — established "There is no cost to apply for a license" and "It can take 2-6 months to complete licensing steps." https://www.mass.gov/lists/background-record-check-brc-policies — the BRC policy index as served today; established that the three Tables of Disqualifying Offenses (Mandatory, Presumptive, Discretionary) EEC currently publishes are each labelled "effective 10/1/18." WHERE I CONTRADICT THE BRIEF AND THE AGENCY 1. CONTRADICTS THE BRIEF.

The Lot 7 brief asks whether "le transfert d'EEC annoncé sous l'Executive Office of Education a changé l'autorité qui délivre." Measured on the text: it has not. M.G.L. c. 15D, § 7(a) still vests issuance in "the department" (EEC), 606 CMR 7.03 and 606 CMR 14.00 are still EEC regulations, and mass.gov's breadcrumb placing EEC under the Executive Office of Education is an organisational listing, not a transfer of licensing authority. The hint should not be repeated as fact anywhere in the MA entry. 2. CONTRADICTS MY OWN TASK BRIEF. I was told to describe "the renewal cadence" in 606 CMR 14.00. There is NO three-year interval anywhere in 606 CMR 14.00. 606 CMR 14.09, despite being titled "Submission and Frequency of Background Record Checks," contains only the exceptions that force an EARLY re-run; 606 CMR 14.08(1) merely has EEC look for a determination "within the prior three years." The three-year rule is STATUTORY, at M.G.L. c. 15D, § 8(d) ("not less than every 3 years"). Anyone citing "606 CMR 14.09" for a three-year renewal is citing a section that does not say it. 3. CONTRADICTS THE AGENCY (method rule 3). EEC's own page "EEC BRC Requirements: Applicability, Frequency" says that for family child care "Only individuals present in an EEC-licensed program with the potential for unsupervised access to children ... must complete a Background Record Check."

That is narrower than the regulation. 606 CMR 14.05(2)(b) requires household members 15 and over "regardless of whether such individuals are present while child care children are present," and 606 CMR 14.04 defines Family Child Care Candidate to include them "regardless of whether the individuals are present during child care hours." The regulation governs; the page understates the duty and would cost an applicant the file. 4. CONTRADICTS THE AGENCY. The same EEC fingerprinting FAQ is headed "If I need to renew my program license with EEC every 2 years..." A regular family child care license is valid THREE years under 606 CMR 7.03(5)(b). The page's premise is stale for family child care. 5. INTERNAL CONFLICT WORTH FLAGGING. "Volunteer" is defined twice and differently: 606 CMR 7.02 says "Any person who assists in an unpaid capacity on a regular basis in an EEC licensed or funded program," while 606 CMR 14.04 says "Any person who assists in an unpaid and unsupervised capacity." For family child care the conflict is resolved in practice by EEC policy BRC-26-01 (eff. 1 April 2026): in FCC, ALL volunteers need a BRC. 6. DOCUMENT-CURRENCY FINDING.

The BRC regulation EEC serves today is a Westlaw snapshot "current through Register No. 1467, dated April 15, 2022," last amended eff. 25 December 2020. It is the only version the index offers, and the proposed-amendments page is empty, so it is operative — but any future writer must re-check the index rather than re-download this file (method rule 1). UNVERIFIED: the $35 fingerprinting fee. Multiple search summaries attribute "$35.00 fee to undergo a fingerprint-based check" to mass.gov pages, but I could not open a mass.gov page stating the amount directly during this task (the fee is not on the EEC fingerprinting FAQ, the SAFIS scheduling page, or the FCC step-4 page as served today). The background_check.txt text therefore states only that fingerprinting is billed to the individual at the IdentoGO appointment and falls on every adult household member, without naming an amount. UNVERIFIED: the contents of the three Tables of Disqualifying Offenses (Mandatory / Presumptive / Discretionary, each labelled effective 10/1/18). I confirmed the tables exist and are published as EEC policy at mass.gov, and quoted 606 CMR 14.18's incorporation of them, but I did not open the tables themselves; no specific offence is asserted from them.

UNVERIFIED: the "Suitability Transfer tables" referenced by BRC-2025-02. Their existence and function are quoted from the policy; the tables themselves were not opened. NOTE ON ACCESS: www.mass.gov returns HTTP 403 to direct fetches from this environment; every mass.gov document above was read through the r.jina.ai text-extraction proxy against the live mass.gov URL. malegislature.gov is likewise unreachable directly and was read the same way. The URLs listed are the canonical ones. [capacity_max] https://www.mass.gov/lists/eec-laws-and-regulations — EEC's index of licensing regulations in effect, opened today through r.jina.ai (mass.gov answers direct requests from this machine with HTTP 403, Incapsula). Method rule 1 check: the index serves one family child care rule document today, "Family, group & school age child care programs (606 CMR 7)", and no successor or dated replacement. https://www.sec.state.ma.us/reg_pub/pdf/600/606007.pdf — 606 CMR 7.00 as the Secretary of the Commonwealth's regulations database serves it today, fetched directly (HTTP 200, 368,061 bytes, 54 pages).

Source of every regulation quotation in this field: 7.02 definitions of Family Child Care ("no more than ten children younger than 14 years old"), Multi-age Grouping ("Ten or fewer children"), Licensed Capacity, Approved Activity Space, School Age Child, Kindergarten Child, Regular Overnight Care; 7.03(2) Licensed Capacity in full; 7.03(4)(a) pilot or demonstration projects and 7.03(4)(b) standard variances; 7.03(5)(a)1., (5)(b), (5)(c)1.-5. Determining Capacity in full, (5)(e)1.-2.c. and (5)(f); 7.03(6)(b)2.; 7.04(14)(d); 7.07(2), (3), (4), (7); 7.07(15)(b)1.-3. and (15)(c)1.a.-c., 2. and 3.; 7.09(15)(b)1.a.-e., 2.a.-b. and 3.a.-b.; 7.10(4)(e); 7.11(15)(b)2.a.-e.; 7.14(3) Prior Licenses. https://www.mass.gov/doc/family-group-school-age-child-care-programs-606-cmr-7-0/download — EEC's own copy of the same chapter, retrieved today via r.jina.ai, 54 pages. Probe-compared against the Secretary's text on six strings including "35 square feet of approved activity space for each child when serving seven to ten" and "no more than ten children younger than 14 years old": identical. Establishes that regulator and Secretary are not out of step on this chapter. https://malegislature.gov/Laws/SessionLaws/Acts/2024/Chapter140 — Chapter 140 of the Acts of 2024 (the fiscal year 2025 general appropriation act, House No. 4800, "Approved (in part) by the Governor, July 29, 2024"), full text retrieved today via r.jina.ai, 1.55 MB.

Establishes SECTION 25 verbatim: "Section 1A of chapter 15D of the General Laws, as appearing in the 2022 Official Edition, is hereby amended by striking out, in lines 98 to 100, inclusive, the words ', but the number of children under the age of 16 in a large family child care home shall not exceed 10, including participating children living in the residence'." Also establishes SECTION 76, amending the fifth paragraph of M.G.L. c. 40A, § 3 to read "Family child care home and large family child care home as defined in section 1A of chapter 15D shall be an allowable use and no city or town shall prohibit or regulate such use in its zoning ordinances or by-laws." This is the legislative sweep required by method rule 2, and it changed the answer. https://malegislature.gov/Laws/SessionLaws/Acts/2024 — index of the 2024 session acts, opened today, used to identify Chapter 140 as the FY2025 general appropriation act before opening it. https://malegislature.gov/Laws/GeneralLaws/PartI/TitleII/Chapter15D/Section1A — M.G.L. c. 15D, § 1A as served today.

Confirms the amendment took: the "Large family child care home" definition now ends at the approved-assistant sentence and contains no number, while the "Family child care home" definition still reads "The total number of children under 16 in a family child care home shall not exceed 6, including participating children living in the residence." https://malegislature.gov/Laws/GeneralLaws/PartI/TitleII/Chapter15D/Section2 — § 2 and § 2(c), opened today; department sits in the executive office of education and licenses family child care homes and large family child care homes. https://www.mass.gov/info-details/learn-about-family-child-care — EEC's public statement of the three capacities (6, 8 without an assistant with at least 2 school age children, 10 with an approved assistant), opened today. https://www.mass.gov/doc/freezing-or-reducing-enrollment/download — EEC licensing policy statement, internal code EECFreezeReduceEnrollment20110714, read in full today. Source of the downward-capacity mechanism, the four triggers, the database and public-listing consequences, and "EEC may issue a license with a reduced capacity if there is evidence that the program will be unable to continue to serve the number of children for which it had been previously licensed." https://www.mass.gov/info-details/early-education-care-eec-proposed-amendments-to-regulations — opened today; establishes "Department of Early Education & Care does not have any proposed amendments to its regulations at this time", i.e. no rulemaking is pending that would move the ten. https://www.wbur.org/news/2026/06/23/mass-family-child-care-expansion-pilot — State House News Service report (Alison Kuznitz), 23 June 2026, read in full today.

Source of the capacity pilot: EEC announced it in June 2026 (the report is dated 23 June 2026 and says the announcement was made the preceding Monday), it tests raising the cap to 12 "while maintaining high standards for quality, safety, and regulatory compliance", it covers about 25 to 30 programmes, and eligibility requires a licence in good standing, ten children currently enrolled, and continuous operation at a licensed capacity of ten for at least three years. Used only for the pilot paragraph and attributed in the field as a report of an EEC announcement, not as regulation. https://www.sec.state.ma.us/divisions/bookstore/agencies/102-early-education-and-care.htm — the Secretary's State Bookstore catalogue for the Department of Early Education and Care, opened today. Establishes that the Commonwealth still sells "102 CMR 1.00 - 12.00 ... Standards for the Licensure of Family Child Care and Large Family Care Homes", the pre-2010 OCCS regime superseded by 606 CMR 7.00. Named in the field as a live citation trap. CONTRADICTION OF THE BRIEF. The brief posed the capacity question as "distinction family child care ≤ 6 + 2 d'âge scolaire vs large family (10)". Three things are wrong or stale in that framing, and the text settles all three.

First, "large family child care home" is not a regulatory category in Massachusetts: the phrase appears zero times in the 54 pages of 606 CMR 7.00. There is one licence, family child care, capped at ten by 606 CMR 7.02, with three capacities EEC may write on it. Second, the "≤ 6 + 2" arithmetic misdescribes the middle tier: 606 CMR 7.09(15)(b)2. licenses "seven or eight children, at least two of whom must be school age" and 606 CMR 7.10(4)(e) requires that "All children over capacity of six must be school age" — so seven children with a single non-school-age seventh is unlawful, and the tier is not six-plus-two but a seven-or-eight licence with a school-age composition condition. Third, and most consequentially, the number ten is no longer statutory. Section 25 of Chapter 140 of the Acts of 2024 struck ", but the number of children under the age of 16 in a large family child care home shall not exceed 10, including participating children living in the residence" out of M.G.L. c. 15D, § 1A. Ten now lives only in 606 CMR 7.02 and the Multi-age Grouping table, which is precisely why EEC was able to open a twelve-child pilot in June 2026 without new legislation.

Any Massachusetts capacity note written before August 2024 that calls ten a statutory cap is stale on its face. SECOND CONTRADICTION, OF THE PRESS AND OF THE COMMON SUMMARY. The State House News Service report and the secondary coverage describe the FY2025 budget as having "removed the statutory cap of 10 children in family childcare programs". Read against the enrolled act, that is the right act and the wrong definition: SECTION 25 struck the ten from the LARGE family child care home definition only. The six-child cap in the plain "family child care home" definition at § 1A was left untouched and is still on the books today, in direct tension with a regulation that licenses to eight and to ten. The field says so rather than repeating the tidier press summary. UNVERIFIED: EEC's own published page or notice for the family child care capacity pilot. The pilot is sourced here to a State House News Service report of an EEC announcement, read in full; a search of mass.gov's EEC newsletters for June and August 2026, of the EEC laws-and-regulations index and of the licensing policy list found no EEC-hosted pilot page, and mass.gov's site search returns nothing usable through the proxy.

The pilot's application deadline (reported elsewhere as 30 June 2026) and its current status are therefore not stated in the field. UNVERIFIED: the last-amendment date of 606 CMR 7.00. No effective-date line survives text extraction from the Secretary's PDF, and the Massachusetts Register cumulative table is behind the subscription login at sec.state.ma.us/reg_pub/login.aspx. The chapter's own transition clause at 606 CMR 7.14(3) dates the regime to 22 January 2010; nothing in the field turns on a later date. UNVERIFIED: whether EEC has, by policy rather than regulation, issued any capacity guidance for licensees whose own children move in and out of the count under 606 CMR 7.03(5)(c). The full family child care policy list was read today and contains no such policy. NETWORK NOTE: www.mass.gov returns HTTP 403 (Incapsula) to direct requests from this machine, for HTML and for /doc/.../download PDFs alike; all mass.gov items above were read through the r.jina.ai proxy against those exact URLs. www.sec.state.ma.us served both its PDF and its bookstore pages; malegislature.gov HTML was read through the same proxy after direct requests failed. [cpr_first_aid_required] All URLs below were opened on 26 August 2026, starting from the EEC index of regulations in effect (never from a pinned dated file). https://www.mass.gov/lists/eec-laws-and-regulations — THE INDEX OF RULES IN EFFECT as served today.

Under "Licensing Regulations" it serves "Family, group & school age child care programs (606 CMR 7)" (PDF, 376.41 KB) as the current text.

Method rule 1 starting point. https://www.mass.gov/doc/family-group-school-age-child-care-programs-606-cmr-7-0/download — the full 54-page text of 606 CMR 7.00 that EEC serves TODAY; running header reads "(Mass. Register #1459 12/24/21)". Established verbatim: 7.03(5)(a)2 (certification of current CPR and first aid is a document required for FCC licensure); 7.03(5)(b) (three-year license term); 7.09(15)(b) (evidence of current certification in basic first aid and CPR "age appropriate for all of the children in care" PRIOR to first licensure); 7.09(15)(c)1 and 2 (certified vs regular assistant, and the 25-hours-per-12-months / 8-hours-per-7-days alone rule conditioned on first aid and CPR); 7.09(15)(e) (licensees, certified assistants and any educator who may be alone with children must maintain certification; "Training in first aid and CPR may not be counted toward Professional Development hours"); 7.09(15)(f) (5 / 10 hour PD tiers, one third diverse learners); 7.09(17)(d) (small/large group: basic first aid within six months of employment, "appropriate to the population served"); 7.09(20) (Commissioner's shortage power, limited on its face to 606 CMR 7.04 and 7.09);

7.07(9)(f) (off-site water activities: lifeguard AND current CPR and first aid); 7.11(1)(a)1-3 (the universal rule, the certificate-expiry renewal rule, and "Only educators who are currently certified in first aid and CPR may provide first aid and CPR"); 7.11 first aid supplies list including "CPR mouth guard" and the take-with-you kit list; 7.11(18)(d) (small/large group: document first aid certification within six months of employment); 7.11(19)(b)3 (Health Care Consultant approves first aid training — large group and school age only); 7.13 (at least one person on each vehicle currently certified in first aid and CPR); and the child-record item "permission to administer basic first aid and/or CPR". https://www.mass.gov/doc/cpr-and-first-aid-training-and-certification/download — EEC POLICY "CPR and First Aid Training and Certification", Applicability: All Licensed and Funded Child Care Programs, Effective Date: October 1, 2020, Updated: December 17, 2021. THE decisive document for this field.

Established: that "On August 31, 2021, the Board of Early Education and Care approved emergency revisions ... to remove the annual CPR renewal requirement established by 606 CMR 7.11(1)(a)2 and, instead, to adhere to the expiration date listed on the CPR certificate"; the CPR course criteria (CPR Trainer instructor, choking and rescue breathing, mannequins, mannequin-to-student ratio, age-appropriate, demonstration); "EEC will not accept CPR certification training that does not include hands-on skill demonstration"; the first aid course criteria (standardized written test plus demonstration) and the same online restriction; the CLOSED SEVEN-ORGANISATION list of acceptable FIRST AID instructor certifiers (American Heart Association; American Red Cross; National Safety Council; American Safety and Health Institute; Massachusetts Firefighting Academy; Emergency Medical Instructor/Coordinator Training Course of Department of Public Health; EMS Safety Services, Inc.); "Participants are responsible for verifying that the instructor has a current certification with the organization chosen";

"NOTE: EEC does not maintain an approved list of individual First Aid and CPR trainers"; the full approved first aid syllabus (Acute Injuries and Illness / Emergency Action Principles / General Injury Prevention); the certificate content rules (printed; name of participant; date of completion; indication the training was age-appropriate); and the ENFORCEMENT rule that a program with no current age-appropriate certification on premises "must temporarily cease care at the end of the day" and "may not reopen" until evidence is produced, with denial of subsidy payment for funded programs. https://www.mass.gov/lists/licensing-policies-for-family-child-care-providers — the FCC licensing policy index as served today; located the CPR and First Aid policy under "Family Child Care Personnel and Training Policies" and the regular-assistant policy. https://www.mass.gov/doc/use-of-regular-assistants-in-family-child-care-homes/download — EEC policy statement "Use of Regular Assistants in Family Child Care Homes".

Established that the 8-hours-per-week / 25-hours-per-year cap is PER HOME and cumulative across assistants ("no matter how many assistants he/she uses"), that the caps apply to each home separately for an assistant working in several homes, and that a regular assistant may work any length of time while the provider or Certified Assistant is on the premises. https://www.mass.gov/info-details/first-aid-and-cpr-training-for-child-care-providers — EEC's provider-facing page. Established the three named example vendors (American Red Cross, American Heart Association, Heart Savers) and "You must renew your First Aid and CPR certifications prior to the expiration date listed on the certificate." https://www.mass.gov/info-details/learn-about-family-child-care-assistant-requirements — established EEC's plain-language statement of the regular assistant rule ("care for up to 6 children alone ... for a limited time period (25 hours in 12 months, or 8 hours in 7 days), if you are certified in CPR and First Aid appropriate to the age of children in care") and that "The Regular Family Child Care Assistant letter of approval is valid for 3 years." https://www.mass.gov/info-details/learn-about-family-child-care — established the three FCC capacity tiers (6 / 8 with at least 2 school age / 10 with an approved assistant) and the certified vs regular assistant distinction. https://www.mass.gov/info-details/early-education-care-eec-proposed-amendments-to-regulations — "Department of Early Education & Care does not have any proposed amendments to its regulations at this time."

Confirms 606 CMR 7.00 as served is not about to change. WHERE I CONTRADICT THE BRIEF AND COMMON PRACTICE 1. THE ANNUAL CPR RENEWAL IS REPEALED. Massachusetts is widely described, including by training vendors selling to Massachusetts providers, as requiring ANNUAL CPR renewal. That requirement was in 606 CMR 7.11(1)(a)2 and was removed by Board emergency revisions approved 31 August 2021. The rule served today is "CPR training must be renewed prior to the expiration date listed on the CPR certificate" — in practice two years on an AHA or Red Cross card. Any MA entry stating "CPR must be renewed annually" is publishing a repealed rule and costing readers a class a year. 2. CPR AND FIRST AID ARE NOT GOVERNED BY THE SAME INSTRUCTOR RULE. The closed seven-organisation list in the EEC policy applies to FIRST AID INSTRUCTORS only. For CPR the policy requires merely "an instructor who holds a current certificate as a CPR Trainer" and names no organisation. Writers who present the seven-name list as covering both are over-stating the CPR rule. 3. THE CENTRE RULE IS NOT THE FAMILY CHILD CARE RULE. 606 CMR 7.09(17)(d) and 7.11(18)(d) give small group / large group educators SIX MONTHS from employment and name FIRST AID only.

Family child care gets neither concession: 606 CMR 7.09(15)(b) requires evidence of current first aid AND CPR certification "Prior to being licensed for the first time." A general "MA requires first aid within six months of hire" statement is false for family child care. 4. CONTRADICTS THE BRIEF'S FRAMING OF THE ASSISTANT REGIME. The Lot 7 brief calls "le régime des assistants et le plafond réel avec assistant approuvé" the historic MA trap, which is right, but the trap in THIS field is narrower and sharper than a capacity number: without current first aid AND CPR certification a regular assistant may not be left alone with children AT ALL under 606 CMR 7.09(15)(c)2a, and EEC's policy caps the alone-time at 25 hours a year and 8 hours in any seven days per home cumulatively across ALL assistants used, not per assistant. 5. THE COMMISSIONER'S SHORTAGE WAIVER DOES NOT REACH THE PRESENCE RULE. 606 CMR 7.09(20) authorises the Commissioner to "revise and/or rescind any educator qualifications and professional development requirements under 606 CMR 7.04 and 7.09". 606 CMR 7.11(1)(a)1 — at least one certified educator present at all times — sits in 7.11 and is not within that grant.

This is a reading of the section boundaries on the face of the text, stated as such in the entry. UNVERIFIED: the typical cost of a CPR/first aid course in Massachusetts. The entry says "about a hundred dollars every two years" as an order-of-magnitude figure; no official source states a price and EEC publishes none. If this needs to be defensible, drop the figure. UNVERIFIED: that AHA and Red Cross cards run exactly two years. This is those organisations' standard, not a Massachusetts rule; the entry is careful to say the governing date is the one printed on the card. I did not open an AHA or Red Cross page during this task. UNVERIFIED: whether any 2022-2026 session law amended M.G.L. c. 15D in a way bearing on CPR/first aid. § 8(c) as the legislature serves it today speaks only to large family child care training hours (5 hours pre-service, 10 hours annually) and does not mention CPR or first aid; I found no session-law layer on this specific subject, but I did not sweep the 193rd and 194th General Court act by act. NOTE ON ACCESS: www.mass.gov returns HTTP 403 to direct fetches from this environment; every mass.gov document above was read through the r.jina.ai text-extraction proxy against the live mass.gov URL.

The URLs listed are the canonical ones. [home_type_definition] https://malegislature.gov/Laws/GeneralLaws/PartI/TitleII/Chapter15D/Section1A — M.G.L. c.15D s.1A as the Legislature serves it TODAY (26/08/2026, 194th General Court). Verbatim definitions of "Family child care home" (total under 16 shall not exceed 6, including participating children living in the residence), "Large family child care home", "Family child care system", "School-aged child care program", "Child care center", "Department". DECISIVE FINDING: the live text of "Large family child care home" NO LONGER contains any numeric cap. The clause ", but the number of children under the age of 16 in a large family child care home shall not exceed 10, including participating children living in the residence" has been struck. Only the sentence "A large family child care home shall have at least 1 approved assistant when the total number of children participating in child care exceeds 6" survives. https://budget.digital.mass.gov/summary/fy25/outside-section/section-25-large-family-child-care-cap — FY2025 enacted budget, outside SECTION 25 "Large Family Child Care Cap": the repealing instrument, quoted verbatim. https://malegislature.gov/Laws/SessionLaws/Acts/2024/Chapter140 — full session-law text of the FY2025 GAA.

Confirms SECTION 25 (strikes the 10-child cap on large family child care homes) and SECTION 76 (rewrites the fifth paragraph of M.G.L. c.40A s.3 on zoning). This is the act number to cite: St. 2024, c. 140. https://www.sec.state.ma.us/reg_pub/pdf/600/606007.pdf — 606 CMR 7.00 as the Secretary of the Commonwealth's regulation repository serves it today (54 pp., PDF built 2021-12-24; no newer file is served and no 2025/2026 amendment was found). Text extracted locally with pdftotext -layout.

Established verbatim: 7.02 definitions of Family Child Care, Small Group and School Age Child Care, Large Group and School Age Child Care, Private Residence, Household Member, Relative, Child, School Age Child, Kindergarten Child, Approved Activity Space, Licensed Capacity, Certified Assistant, Regular Assistant, Group, Multi-age Grouping, Mixed Age Group; 7.03(2) Licensed Capacity; 7.03(5)(b) three-year licence; 7.03(5)(c) Determining Capacity (the five clauses that count the provider's own and visiting children); 7.03(5)(e) Location of Care; 7.03(5)(f) one licence per licensee; 7.04(16) family-child-care notifications; 7.07(15)(b)-(c) exits and square footage; 7.09(15) educator qualifications and assistants; 7.14(3) prior licences under 102 CMR 7.00/8.00. https://malegislature.gov/Laws/GeneralLaws/PartI/TitleII/Chapter15D/Section6 — s.6(a) licence required, s.6(a) approval instead of licence for public bodies, s.6(e) advertising must carry the licence number. https://malegislature.gov/Laws/GeneralLaws/PartI/TitleII/Chapter15D/Section15 — s.15(a) penalty for unlicensed operation: fine up to $5,000 or house of correction up to 2 1/2 years, or both, per violation. https://malegislature.gov/Laws/GeneralLaws/PartI/TitleII/Chapter15D/Section8 — s.8(a) board's rulemaking mandate;

s.8(c) mandatory content of large-family-child-care regulations (approved assistants, 3 years experience, 5 hours specialised pre-service, 10 hours annually); s.8(d) background record checks for household members 15+ and persons regularly on the premises 15+. https://malegislature.gov/Laws/GeneralLaws/PartI/TitleVII/Chapter40A/Section3 — current zoning text: "Family child care home and large family child care home as defined in section 1A of chapter 15D shall be an allowable use and no city or town shall prohibit or regulate such use in its zoning ordinances or by-laws."

Also the weaker, separate protection for "child care facility" (centres and school-age programs only). https://www.mass.gov/child-care-program-licensing — EEC's licensing landing page, served under both "Department of Early Education and Care" and "Executive Office of Education": "EEC licenses or approves group, school age, and family child care programs; family child care assistants; residential programs for children; and adoption/foster care placement agencies." LEAD portal at childcare.mass.gov/providerlicensing; unlicensed-care complaint form at childcare.mass.gov/reportunlicensedcare. https://www.mass.gov/info-details/learn-about-family-child-care — EEC applicant-facing statement of the three capacities (6 / 8 without an assistant if at least 2 are school age / 10 with an approved assistant) and of the two assistant types. https://www.mass.gov/info-details/learn-about-family-child-care-assistant-requirements — certified vs regular family child care assistant qualifications; both certificates valid 3 years. https://www.mass.gov/doc/determining-capacity/download — EEC "Family Child Care Licensing TECHNICAL ASSISTANCE: Determining capacity".

Establishes "There are no longer separate categories of Family Child Care, i.e. FCCP and LFCC" and "Family Child Care Educators now will have a license capacity of 6 or 8 or 10", plus the participating-child rules. CAUTION recorded in the field text: the file's own printed identifier is FCCDeterminingCapacityTA20110516, i.e. it dates from 2011, and its paraphrase of the three-hour rule DROPS the regulation's "on each of five consecutive days" element. Method rule 3 applies — the sheet is guidance, 606 CMR 7.03(5)(c) is the law. https://www.wbur.org/news/2026/06/23/mass-family-child-care-expansion-pilot — State House News Service, 23 June 2026: EEC's Family Child Care Capacity Expansion Pilot (10 to 12), 25-30 programs, eligibility criteria, "The pilot stems from fiscal 2025 state budget language that removed the statutory cap of 10 children in family childcare programs." Fetch note: malegislature.gov and www.mass.gov both refuse connections from this host (ECONNREFUSED / 403 / Incapsula). All malegislature and mass.gov texts above were obtained through the r.jina.ai text proxy against the official URLs on 26 August 2026, and each is the live page, not a pinned or dated file.

The 606 CMR PDF was fetched directly from sec.state.ma.us. CONTRADICTS THE BRIEF (three times, text in hand). 1. The Lot 7 brief says to check the "distinction family child care <= 6 + 2 d'age scolaire vs large family (10)". That is not how Massachusetts licenses today. 606 CMR 7.00 contains NO definition of "family child care home" or "large family child care home"; it defines a single activity, "Family Child Care", for "no more than ten children younger than 14 years old". EEC's own technical assistance states that "There are no longer separate categories of Family Child Care, i.e. FCCP and LFCC" and that there is ONE licence with a capacity of 6, 8 or 10. The two-category framing survives only in the statute, which EEC does not administer as two licence types. 2. The brief's "large family (10)" is a repealed number. St. 2024, c. 140 s.25 struck the 10-child statutory cap out of M.G.L. c.15D s.1A. There is no statutory ceiling on a Massachusetts home program today; the ten is regulatory only, which is precisely why EEC could open a 12-child pilot in June 2026 without new legislation. 3. The brief says to "verifier si le transfert d'EEC annonce sous l'Executive Office of Education a change l'autorite qui delivre".

It has not, and there is nothing to verify: EEC has sat under the Executive Office of Education throughout, mass.gov still serves the licensing pages under both org labels, and 606 CMR 7.00's regulatory authority line still reads "M.G.L. c. 15D". No transfer of licensing authority occurred. The brief WAS right about one thing: "Le regime des assistants et le plafond reel avec assistant approuve sont le piege historique du MA." Confirmed, and it is a live statute-versus-regulation conflict — M.G.L. c.15D s.1A requires "at least 1 approved assistant when the total number of children participating in child care exceeds 6", while 606 CMR 7.10(4)(e) and EEC guidance permit 7 or 8 children with one educator when the children above six are school age. UNVERIFIED: whether the FY2026 General Appropriations Act or any 2025-2026 session law further amended M.G.L. c.15D s.1A (only the FY2025 act was swept act by act). UNVERIFIED: the formal EEC policy document or board vote authorising the Family Child Care Capacity Expansion Pilot — mass.gov's own pilot page and EEC board slide decks could not be retrieved from this host; the pilot's terms are taken from State House News Service reporting of EEC's 22 June 2026 announcement, not from EEC's own text.

UNVERIFIED: 102 CMR 1.05(1), cross-referenced by 606 CMR 7.03(1)(c)1, was not opened. [max_group_size] https://www.sec.state.ma.us/reg_pub/pdf/600/606007.pdf — 606 CMR 7.00 as the Secretary of the Commonwealth serves it today (54 pp.; PDF built 2021-12-24; the index serves no newer file and no 2025/2026 amendment to 606 CMR 7.00 was found). Extracted locally with pdftotext -layout. THE primary source for this field.

Established verbatim: 7.03(2) Licensed Capacity ("At no time shall a program admit, supervise or provide care for more than the maximum number of children indicated on the license"); 7.03(5)(c) Determining Capacity, the five clauses that decide which children occupy a slot; 7.07(15)(b) two approved exits and basement egress; 7.07(15)(c) 150 / 225 / 35 sq ft activity space; 7.09(15)(a) all educators at least 18; 7.09(15)(b) the 6 / 7-8 / 9-10 licensee experience ladder; 7.09(15)(c) the certified and regular assistant regime with the 25-hours-per-12-months and 8-hours-per-7-days ceilings; 7.09(15)(e) first aid and CPR for anyone who may be alone with children; 7.09(16) small group and school age educator qualifications; 7.10(1)-(3) general duty and who counts as staff in ratio; 7.10(4) Multi-age Grouping including the full five-row table at 7.10(4)(d) through (h); 7.10(5) supervision, including (a) direct visual supervision of children under six months for the first six weeks and (j) the age-seven indoor consent rule; 7.10(6) outdoor unaccompanied play in family child care; 7.10(7) same-floor rule and 15-minute nap checks;

7.10(8)(b)-(c) posted schedule and second adult immediately available in group programs; 7.10(9)(a) fixed-age-group deviation and the "no more than two children outside the chronologically defined age range" cap; 7.10(9)(b) the large-group fixed age table (infants 7, toddlers 9, preschool 20 full day / 24 half day, kindergarten 30, school age 26); 7.10(9)(c) the mixed age table (I/T 9 with no more than three infants, T/P 9, P/SA 20 with maximum age eight, K/SA 26); 7.11(17)(d) overnight care, including two educators with one awake for seven to ten children; 7.03(4)(b) variances; and the 7.02 definitions of Group, Multi-age Grouping, Mixed Age Group, Infant, Toddler, School Age Child, Kindergarten Child, Approved Private Elementary School, Licensed Capacity, Approved Activity Space, Certified Assistant, Regular Assistant, Evening Care, Regular Overnight Care, Occasional Overnight Care. https://www.mass.gov/doc/determining-capacity/download — EEC "Family Child Care Licensing TECHNICAL ASSISTANCE: Determining capacity".

Establishes the operating rule EEC licensors apply: "There are no longer separate categories of Family Child Care, i.e. FCCP and LFCC ... Family Child Care Educators now will have a license capacity of 6 or 8 or 10"; "FCC Providers with a capacity of '10' children must work with a second Educator at any time there are more than 6 pre-school aged children. A FCC Educator with a capacity of 10 can care for up to 8 children by her/himself if two of the children are school-aged. The second Educator can be another Provider, a Certified Assistant, or a Regular Assistant."; the definition of "walking unassisted"; and the half-day-kindergarten point. CAUTION: the sheet's own printed identifier is FCCDeterminingCapacityTA20110516 (2011), and its paraphrase of the three-hour rule omits the regulation's "on each of five consecutive days" condition.

Method rule 3 — the sheet is guidance, 606 CMR 7.03(5)(c) is the law, and the field text says so. https://www.mass.gov/info-details/learn-about-family-child-care — EEC's applicant-facing statement of the three capacities, including the sentence that creates the conflict: "Up to 8 children: A licensed Family Child Care provider may enroll up to 8 children in their program without an assistant if at least 2 of the children are school age". https://www.mass.gov/info-details/learn-about-family-child-care-assistant-requirements — certified vs regular family child care assistant scope of practice;

restates "25 hours in 12 months, or 8 hours in 7 days" for a regular assistant alone with up to 6 children, and that a certified assistant at the provider's own level may cover "any length of time". https://malegislature.gov/Laws/GeneralLaws/PartI/TitleII/Chapter15D/Section1A — live statutory text, 26/08/2026. Source of the surviving sentence "A large family child care home shall have at least 1 approved assistant when the total number of children participating in child care exceeds 6", and proof that the numeric cap clause is gone. https://budget.digital.mass.gov/summary/fy25/outside-section/section-25-large-family-child-care-cap and https://malegislature.gov/Laws/SessionLaws/Acts/2024/Chapter140 — St. 2024, c. 140 SECTION 25, the outside section that struck ", but the number of children under the age of 16 in a large family child care home shall not exceed 10, including participating children living in the residence". https://www.wbur.org/news/2026/06/23/mass-family-child-care-expansion-pilot — State House News Service, 23 June 2026, on EEC's Family Child Care Capacity Expansion Pilot testing 10 to 12: "Licensed providers who run programs out of their homes can currently enroll up to 10 children if they have an 'approved assistant' working with them";

about 25 to 30 programs; eligibility (good standing, currently enrolled at 10, licensed at capacity 10 continuously for at least three years); "The pilot stems from fiscal 2025 state budget language that removed the statutory cap of 10 children in family childcare programs." https://mybrightwheel.com/licensing-requirements/massachusetts/massachusetts-large-family-child-care-home-licensing-requirements/ — read only to identify the false claim named in the field text ("typically licensed to care for up to 12-14 children total").

No Massachusetts instrument has ever authorised fourteen children in a home. Not relied on for any assertion. Fetch note: www.mass.gov and malegislature.gov both refuse this host (403 / Incapsula / ECONNREFUSED). Those texts were obtained through the r.jina.ai text proxy against the live official URLs on 26 August 2026 — live pages, not pinned or dated files, per method rule 1. The 606 CMR 7.00 PDF came directly from sec.state.ma.us and its currency was checked against a search of the Massachusetts Register for 2025-2026 amendments to 606 CMR 7.00 (none found). CONTRADICTS THE BRIEF. 1. The brief frames Massachusetts as "family child care <= 6 + 2 d'age scolaire vs large family (10)", i.e. two licence categories. 606 CMR 7.00 has one, "Family Child Care", capped at ten on its face, with capacities of 6, 8 or 10 written on the licence; EEC's own technical assistance says the FCCP/LFCC split no longer exists. The "6 + 2 school age" is not a category — it is row 606 CMR 7.10(4)(e) of the multi-age grouping table, which permits "seven or eight children" with "one educator" provided "All children over capacity of six must be school age". 2. The brief's "(10)" for large family is a repealed statutory number.

Since St. 2024, c. 140 s.25 there is no statutory cap at all; ten is regulatory and EEC is currently piloting twelve. 3. The brief was RIGHT that "Le regime des assistants et le plafond reel avec assistant approuve sont le piege historique du MA", and the field text names the trap precisely: M.G.L. c.15D s.1A still requires at least one approved assistant above six children, while 606 CMR 7.10(4)(e), mass.gov and EEC's determining-capacity sheet all permit eight children with one educator when two are school age. Both instruments are in force; EEC inspects to the regulation. UNVERIFIED: no EEC-authored document setting out the Family Child Care Capacity Expansion Pilot's group-size or ratio terms could be retrieved (mass.gov pilot page and EEC board slide decks were unreachable); the pilot's terms above rest on 22-23 June 2026 press reporting of EEC's announcement. UNVERIFIED: 606 CMR 7.09(18)(c)2 and 7.09(19)(a)2, the Infant/Toddler Teacher, Preschool Teacher and Group Leader qualification cross-references cited inside the large-group tables, were not read in full. UNVERIFIED: whether any 2025 or 2026 session law further amended M.G.L. c.15D on capacity — only the FY2025 act was swept section by section. [prelicensing_steps] https://www.sec.state.ma.us/reg_pub/pdf/600/606007.pdf — Full text of 606 CMR 7.00 as served today by the Secretary of the Commonwealth's regulation index (downloaded and converted to text, 253,115 characters).

Established verbatim: 7.03(1)(b) orientation within one year prior to licensure; 7.03(1)(c) application, "the required license application fee" and the six document classes including REAP tax certification under St. 1983 c. 233; 7.03(2) licensed capacity; 7.03(3) renewal 30 days before expiry plus renewal meeting; 7.03(5)(a) FCC documents (lead paint disclosure, CPR/first aid, health records); 7.03(5)(b) three-year regular licence; 7.03(5)(c) who counts toward capacity; 7.03(5)(d) inactive status; 7.03(5)(e) location of care; 7.03(5)(f) one licence only; 7.03(6)(b)1 provisional licence limited to group programs; 7.04(7) children's records; 7.04(16) FCC notifications (household composition within 7 days, firearms, lead); 7.07(3) fire code evidence; 7.07(4) water source inspection and DEP small public water supplier threshold; 7.07(6) chipping paint; 7.07(7) outdoor 75 sq ft; 7.07(10)(l) 120 F; 7.07(10)(o) outlets; 7.07(10)(p) CO alarms per state fire safety code; 7.07(11) stairways; 7.07(15) FCC lead poisoning, exits, space 150/225/35, smoke detectors and monthly safety log, playground; 7.07(16)(a) lead paint INSPECTION for group programs only; 7.08(6) and 7.08(9) written information for parents; 7.09(4) annual EEC registration; 7.09(9) orientation; 7.09(11)-(14) educator health; 7.09(15) FCC qualifications by capacity tier, assistants, in-service, 7.09(15)(g) household member health statement; 7.10(4) multi-age grouping table; 7.11(7) emergency plan and monthly drills; 7.11(17) FCC firearms, ten-minute emergency caregiver, overnight care; 7.14(1) licensure does not relieve other legal obligations; regulatory authority M.G.L. c. 15D. https://www.sec.state.ma.us/reg_pub/pdf/600/606014.pdf — Full text of 606 CMR 14.00, Criminal Offender and Other Background Record Checks.

Established 14.05(2) family child care candidate categories including household members and persons regularly on premises 15 years or older regardless of presence during care; the CORI/DCF/SORI/NSOR/fingerprint/out-of-state battery; 14.07(2) and 14.07(8) annual consent by all candidates; 14.08(3) 45-day request window from fingerprinting; 14.08(6) licensee process complete only on final suitability for all household members; 14.09(2)(a) no licence issues until all determinations are in; 14.09(2)(b) duty to disclose changes in household composition; 14.09(3) exceptions permitting early re-runs. https://www.sec.state.ma.us/reg_pub/pdf/100/102001.pdf — Full text of 102 CMR 1.00. Established that this chapter is still drafted for the abolished Office of Child Care Services with an effective date of May 1, 1997 (102 CMR 1.04(1)); that 102 CMR 1.03(5) requires an application fee by check payable to the Commonwealth with "a fee schedule may be obtained from the Office"; that 102 CMR 1.05(1) is the disqualifying-background provision cross-referenced by 606 CMR 7.03(1)(c)1, including 1.05(1)(d) on household members; and 102 CMR 1.06 EEC's right to visit. https://www.mass.gov/lists/eec-laws-and-regulations — EEC's current index of regulations in effect.

Established that 102 CMR 1.00 is still listed as a live licensing regulation alongside 606 CMR 3, 5, 7, 10, 14 and 15, and that 606 CMR 7.00 is served as "Family, group & school age child care programs (606 CMR 7)". https://www.mass.gov/info-details/early-education-care-eec-proposed-amendments-to-regulations — Checked 26 August 2026: "Department of Early Education & Care does not have any proposed amendments to its regulations at this time." No pending rewrite of 606 CMR 7.00. https://www.mass.gov/child-care-program-licensing — EEC's licensing hub. Established that EEC licenses FCC, that the page is co-offered by the Department of Early Education and Care and the Executive Office of Education, and the entry points to LEAD and StrongStart. https://www.mass.gov/guide/become-a-family-child-care-provider — EEC's six-step applicant guide.

Established the 2-6 month timeline, the statement "There is no cost to apply for a license", the pre-licensing visit at 1-2 hours, and the two-week follow-up window. https://www.mass.gov/info-details/1-check-if-you-meet-fcc-licensing-requirements — Established the experience options, landlord/HOA permission, two exits, the BRC scope for household members and frequent visitors, and the (understated) "Indoor space: 35 square feet per child" summary. https://www.mass.gov/info-details/2-complete-fcc-program-trainings — Established the PQ number registration step, the StrongStart account, Potential Provider Training PPT1/PPT2 (1.5 hours, EN/ES/PT/ZH) and the in-person 3-hour Family Child Care Potential Educator Meeting (PEM). https://www.mass.gov/info-details/3-submit-your-fcc-license-application — Established the LEAD account request route, "You have 90 days to complete the process", the LEAD Document Library upload list (first aid/CPR, EEC medical form, training proof), and the two follow-on emails (tax certification statement, BRC consent form for each household member and visitor 15+).

Established that no fee or payment step is described anywhere in the submission instructions. https://www.mass.gov/info-details/4-complete-your-fcc-background-record-check — Established the in-person fingerprinting appointment and the exact database list (CORI incl. juvenile/sealed/non-convictions, DCF supported 51B, SORI levels 1-3, FBI fingerprint national check, NSOR, out-of-state checks for the past 5 years). https://www.mass.gov/info-details/5-prepare-your-home-for-child-care — Established the "look exactly as it will on your first day of operation" instruction and the two self-guided checklists. https://www.mass.gov/info-details/6-complete-your-fcc-pre-licensing-visit — Established the document set checked at the visit (Enrollment Packet, Parent Handbook, Sample Forms, Safe Sleep Pledge, progress report formats), the 1-2 day wait for licensor notes in LEAD, the 2-week correction window, the requirement that corrective action plans include notes and images, and the possibility of a second visit. https://www.mass.gov/doc/opening-a-family-child-care-fcc-program-initial-considerations/download — EEC checklist published February 2026. Established the residential-use, association, landlord, municipal permit and third-floor questions;

the correct indoor figures 150/225/35 and outdoor 75 sq ft per child; the capacity effect of children aged 0-10 in the home; and the BRC composition of an EEC check. https://www.mass.gov/doc/opening-a-family-child-care-fcc-program-before-the-licensing-visit/download — EEC pre-visit checklist published February 2026. Established the required training documentation list, which includes "EEC Essentials 2.0 training" in addition to PEM, FCC PPT1 and FCC PPT2; the first aid kit contents; refrigerator 32-40 F; smoke and CO detectors on every level including levels not licensed for child care; hot water under 120 F; permanently installed top-of-stair barriers; no portable space heaters; 65 F minimum; outdoor square footage worked examples (6 = 450, 8 = 600, 10 = 750); and that well water must be tested to Massachusetts drinking water standards. https://www.mass.gov/doc/exits-and-evacuations-in-family-child-care-programs-policy/download — EEC policy effective January 29, 2013, updated May 8, 2024. Established the definition of two separate exits, the exclusion of sequential doors, exit signage, bulkhead and garage door conditions, the exclusion of balconies and ladders, the elevator prohibition, the apartment rule and certificate-of-occupancy exception for converted attic/basement units, and EEC's power to limit the number or age of infants and non-mobile children based on demonstrated evacuation ability. https://www.mass.gov/doc/fcc-peeling-paint-policy-0/download — EEC Family Child Care Licensing policy on Peeling Paint.

Established the up-to-60-day compliance window, the Renovate Right brochure, the enrolment freeze, the alternative outdoor play space, the room closure, the parent notification verification, the requirement that all children in care have up-to-date lead tests, and referral to EEC's Legal Unit on failure. https://www.mass.gov/doc/carbon-monoxide-alarms/download — EEC Family Child Care Licensing policy on Carbon Monoxide Alarms. Established 527 CMR 31.00 as the controlling fire prevention regulation, the every-level/ten-feet-of-bedroom-door/adjacent-to-garage placement rule, the approved alarm types, and the landlord's responsibility in rental space. https://www.mass.gov/doc/water-safety-2/download — EEC Family Child Care Licensing policy on Water Safety.

Established the second-adult requirement for swimming pools under 606 CMR 7.07(9)(e), the household-member-16-or-older accommodation, and that a caretaking role still requires approval as a Regular or Certified Assistant aged 18. https://www.mass.gov/doc/eec-inspections-and-visits-policy/download — EEC Inspections and Visits policy (updated April 4, 2020). Established that under 45 CFR 98.42 EEC conducts at least one pre-licensing visit covering health, safety and fire standards, and at least one annual unannounced visit thereafter, and cited 102 CMR 1.06 as EEC's visit authority. https://www.mass.gov/lists/licensing-policies-for-family-child-care-providers — EEC's current FCC policy index; established which policies are in force today (peeling paint, CO alarms, exits and evacuations, water safety, safe sleep 2023, playground safety, emergency preparedness, inspections and visits). https://www.mass.gov/guides/licensing-education-analytic-database-lead — Established that LEAD handles all licensing transactions and that FCC applicants may self-request a LEAD Provider Portal account. https://childcare.mass.gov/eeclead/s/reqaccess-lead-portal — The live LEAD access request form (reached directly, HTTP 200); confirms the self-service route for FCC applicants exists today. https://www.mass.gov/doc/application-fee-schedule-1/download — EEC Application Fee Schedule, internally dated EECLicensingApplicationFeeSchedule20100217, still published.

Established the 100.00 dollar FCC provider fee (new and renewal), 75.00 certified assistant, 25.00 upgrade, 100.00 change of address, and the statement that a non-refundable fee "must accompany all applications". https://malegislature.gov/Laws/GeneralLaws/PartI/TitleII/Chapter15D/Section6 — M.G.L. c. 15D s. 6(a): licence required to operate a family child care home or large family child care home. https://malegislature.gov/Laws/GeneralLaws/PartI/TitleII/Chapter15D/Section1A — M.G.L. c. 15D s. 1A definitions. Established that a "family child care home" is capped at 6 children under 16 "including participating children living in the residence", and that a "large family child care home" "shall have at least 1 approved assistant when the total number of children participating in child care exceeds 6", with a school-age carve-out under board regulations. https://malegislature.gov/Laws/GeneralLaws/PartI/TitleII/Chapter15D/Section8 — M.G.L. c. 15D s. 8(a): the Board's rulemaking mandate for family child care homes and large family child care homes; no per-applicant fee amount is set in statute. https://malegislature.gov/Laws/GeneralLaws/PartI/TitleII/Chapter15D — Chapter 15D section index as served on 26 August 2026; confirms the chapter is intact and still titled Department of Early Education and Care.

WHERE I CONTRADICT THE BRIEF AND THE AGENCY The brief asked me to verify whether EEC's move under the Executive Office of Education changed the issuing authority. It has not. The licensing pages are co-branded "Department of Early Education and Care" and "Executive Office of Education", but 606 CMR 7.00 is unamended on this point, its regulatory authority line is still M.G.L. c. 15D, and the licence is issued by EEC. Piste disproved, not confirmed. The task prompt framed Massachusetts lead paint compliance as "a Massachusetts-specific and expensive one" for family child care. That is wrong for family child care and right only for centres. 606 CMR 7.03(5)(a)1 and 7.07(15)(a) require a lead paint DISCLOSURE statement and parent notification, not an inspection or deleading certificate; the inspection requirement at 606 CMR 7.07(16)(a) with 105 CMR 460.000 applies to small and large group and school age programs. The real and expensive family child care exposure is the peeling-paint enforcement track (60 days, enrolment freeze, room closure, mandatory up-to-date lead tests for all children in care), not deleading.

The prompt also assumed "fire department sign-off" as a family child care step. 606 CMR 7.07(3) requires only "evidence of compliance with applicable fire codes", 606 CMR 7.07(2) exempts residences and programs of ten or fewer children from the building inspection certificate, and EEC's current step-3 list of documents to upload to LEAD names no fire department certificate for family child care. What EEC actually enforces is 606 CMR 7.07(15)(d) smoke detector placement plus a monthly safety log, and 606 CMR 7.07(10)(p) carbon monoxide alarms per 527 CMR 31.00. EEC contradicts itself twice in the material an applicant is told to read. First, mass.gov step 1 summarises the indoor requirement as "35 square feet per child", which is false for capacities of one to six children; 606 CMR 7.07(15)(c)1 requires 150 square feet for one or two and 225 for three to six. EEC's own February 2026 Initial Considerations checklist states the correct figures.

Second, mass.gov step 2 lists only PPT1, PPT2 and the PEM, while EEC's February 2026 pre-visit checklist also requires documented completion of "EEC Essentials 2.0"; and the guide's headline figure of "about 16 hours" of training does not reconcile with the 4.5 hours of courses named on step 2. UNVERIFIED: Whether a family child care application fee is payable today. 606 CMR 7.03(1)(c) still speaks of "the required license application fee", 102 CMR 1.03(5) still requires a check payable to the Commonwealth, and EEC still publishes a fee schedule internally dated 2010 setting the FCC provider fee at 100.00 dollars — yet EEC's current applicant guide states "There is no cost to apply for a license" and its step-by-step submission instructions contain no payment step. I could not find any regulation amendment, session law or EEC Board vote eliminating the fee, and mass.gov's document endpoints are behind an anti-bot layer that blocked direct retrieval of board minutes. Do not mail a check unprompted; confirm with the assigned licensor or the regional office. UNVERIFIED: The exact content and total hour count of the "about 16 hours" of pre-application training EEC advertises.

Only PPT1/PPT2 (1.5 hours), the PEM (3 hours) and EEC Essentials 2.0 (hours not stated on any page I could read) are named in official material. UNVERIFIED: Whether a licensed basement may in practice use interior stairs to a first-floor exit as one of its two means of egress. EEC's Exits and Evacuations policy (updated May 8, 2024) and the Initial Considerations checklist both say it may; 606 CMR 7.07(15)(b)2 as codified requires "two separate means of egress directly to the outside". I could not find a variance instrument reconciling the two. UNVERIFIED: How the seven-or-eight-child no-assistant tier permitted by 606 CMR 7.10(4)(e) and by EEC's "Learn about Family Child Care" page is reconciled with M.G.L. c. 15D s. 1A, which requires a large family child care home to have at least one approved assistant "when the total number of children participating in child care exceeds 6". The school-age carve-out in the s. 1A definitions is the likely reconciliation but no official text states it. UNVERIFIED: Current EEC processing statistics behind the "2-6 months" figure, and whether the 90-day LEAD window can be extended on request. [preservice_training] All URLs below were opened on 26 August 2026 from this machine.

HTTP status codes quoted in the field text were measured, not assumed. https://www.sec.state.ma.us/reg_pub/pdf/600/606007.pdf — Secretary of the Commonwealth's copy of 606 CMR 7.00, Standards for the Licensure or Approval of Family Child Care; Small Group and School Age and Large Group and School Age Child Care Programs. Downloaded and converted to text in full (253,115 characters). Server reports last-modified Fri, 24 Dec 2021. Source of every verbatim quotation of 7.02 (definitions of Family Child Care, Diverse Learners, Professional Development, Continuing Education Unit, Educator, Department), 7.03(1)(b), 7.03(1)(c)1, 7.03(3), 7.03(5)(a)-(e), 7.04(5), 7.09(4), 7.09(9), 7.09(11)-(12), 7.09(15)(b)-(g), 7.09(17)(a), 7.09(20), 7.10(4)(d)-(h), 7.10(7)(d), 7.11(1), 7.11(2), 7.11(4)(d), 7.11(13)(e), 7.11(19)(a)9, 7.12(2), and the closing REGULATORY AUTHORITY line "606 CMR 7.00: M.G.L. c. 15D". https://www.law.cornell.edu/regulations/massachusetts/606-CMR-7-09 — Cornell LII, 606 CMR 7.09. Used ONLY as a second, independent witness to the amendment history, per method rule 1 (never treat one pinned file as self-confirming).

Notes read verbatim: "Amended by Mass Register Issue 1452, eff. 9/1/2021. Amended by Mass Register Issue 1459, eff. 9/1/2021." No later amendment listed. Cornell's rendering of 7.09(20) matches the Secretary's PDF word for word, which is how the 2021 file was confirmed to be the text in effect rather than a stale copy. https://www.sec.state.ma.us/reg_pub/pdf/100/102001.pdf — 102 CMR 1.00, Enforcement Standards and Definitions for Licensure or Approval, headed "102 CMR: OFFICE OF CHILD CARE SERVICES", server last-modified 9 July 2004. Source of the 102 CMR 1.05(1) quotation. Establishes that 606 CMR 7.03(1)(c)1 still routes an applicant to a chapter of a title named for an agency folded into EEC in 2005. https://www.sec.state.ma.us/reg_pub/pdf/600/606014.pdf — 606 CMR 14.00, Criminal Offender and Other Background Record Checks; section list read (14.05 candidate categories, 14.09 submission and frequency, 14.10 disqualifications, 14.13 provisional and conditional hiring, 14.18 Table of Disqualifying Offenses). Server last-modified 24 Dec 2020. https://childcare.mass.gov/educators — EEC's new Professional Portal, live, HTTP 200, footer "© 2026 Commonwealth of Massachusetts", masthead "DEPARTMENT OF EARLY EDUCATION AND CARE".

Source of the quotations about the new StrongStart LMS, about PQR ("PQR isn't available in the portal yet. At this time, you need to continue using PQR for annual registration..."), and about certifications approved "before November 2025". Establishes that the licensing agency is still EEC despite the move of its web estate. https://strongstart.eoe.mass.gov/ — HTTP 301 redirect to https://childcare.mass.gov/educators, measured. The two StrongStart course-store item pages that search engines still return as the canonical booking route for family child care orientation, /ets/store/item/?id=ca359579-4d3a-11ec-aacd-c718e78a9b2f ("Potential Provider Training for FCC") and /ets/store/item/?id=942c5145-4e7c-11ef-ac0a-e9894fafac72 ("Potential Educator Meeting"), both also return 301 to the same landing page. No course detail is served at either. https://www.eec.state.ma.us/PQRegistry/ — Professional Qualifications Registry, live, HTTP 200. Source of "Educators, including assistants, who work with infants, toddlers, preschoolers, or school age children in EEC-licensed settings are required to register" and of the annual-registration/renewal description. https://www.mass.gov/doc/professional-development-policy/download — EEC Licensing POLICY STATEMENT: Professional Development, control number EECLicensingProfDev20120904, 7 pages.

Source of the Core Competencies requirement, trainer/instructor qualification bullets, the exclusion list (committee meetings, staff meetings, First Aid and CPR, program orientation, repeats), the hour-calculation rule, CEU/PDP/CEC conversions and accepted CEU-awarding bodies, the "banking" rule and the calendar-year wording, Trainer's Development Credit, the six-item documentation specification, and the restatement of 7.09(15)(f), 7.09(16)(c) and 7.09(19)(b) hour counts. https://www.mass.gov/doc/orientation-to-early-education-and-care-0/download — EEC POLICY STATEMENT: Orientation to Early Education and Care, footer control number EECOrientation20121004 (document properties: printed 4 Oct 2012, last modified 16 Oct 2014). Source of the five-hour in-person family child care orientation by an EEC-approved trainer within one year prior to application, Module Two within six months, "Maintaining Quality While Expanding Your Capacity" for 7-10 capacity, the regular-assistant module, the SIDS module before licensure, "Look Before You Lock" within 60 days, "Medication Administration: The Five Rights", and the completion standard for online modules. https://www.mass.gov/doc/eec-policy-advisory-field-operations-9-eec-essentials-training-policy/download — EEC POLICY ADVISORY, Field Operations 2024-9, "Policy: EEC Essentials 2.0", Effective Date May 8, 2024, signed under Commissioner Amy Kershaw.

Source of the CCDBG/Office of Child Care origin, the "before working with children" rule for new staff, the FCC-specific applicability sentence, the 13-course / ~12 hour package figure, the annual 3-hour Refresher, the 1 July 2025 monitoring start, the ratio-counted staff scope including volunteers/interns/substitutes, and the statement that it supersedes the EEC Essentials policy revised 1 February 2020. https://www.mass.gov/doc/eec-essentials-faq/download — EEC Essentials 2.0 FAQs, dated April 2024, 8 pages.

Source of the thirteen module titles verbatim, "For Family Child Care providers and assistants, the EEC Essential 2.0 training package needs to be completed prior to licensure", "counts toward ... the first time it is taken", "none of these trainings count towards EEC licensing training requirements in diverse learners", "Does this replace the mandatory 51A training? Yes", the CPR/First Aid non-replacement answer, the legacy-training replacement list, the single-certificate rule, and the PQR-active requirement. https://www.mass.gov/doc/cpr-and-first-aid-training-and-certification/download — EEC POLICY: CPR and First Aid Training and Certification, Effective Date October 1, 2020, Updated December 17, 2021. Source of the 31 August 2021 emergency-revision account removing annual CPR renewal, the hands-on skills-demonstration requirement, the CPR course content bullets, the seven acceptable first-aid instructor certifying organisations, "EEC does not maintain an approved list of individual First Aid and CPR trainers", and the cease-care sanction for expired certification. https://www.mass.gov/doc/eec-safe-sleep-policy-2023-0/download — EEC Policy: Safe Sleep for Infants, Effective Date October 1, 2023. Source of the pre-service safe sleep / Shaken Baby training sentence and the 10-business-day retraining consequence after a first citation.

https://www.mass.gov/doc/choking-hazard-training/download — EEC family child care POLICY STATEMENT: Required USDA Nutrition Guidelines and Choking Hazard Training, control number FCCChokingHazardTraining20121128. Source of "There is currently no formalized training solely on this topic" and of the 1 professional development hour allowance. https://www.mass.gov/doc/use-of-regular-assistants-in-family-child-care-homes/download — EEC POLICY STATEMENT: Use of Regular Assistants in Family Child Care Homes, control number FCCRegularAssistants20120626. Source of "no provider may leave their child care children with an uncertified assistant for more than a total of 8 hours per week or a total of 25 hours per year, no matter how many assistants he/she uses."

ACCESS NOTE ON THE mass.gov DOCUMENTS ABOVE. Every www.mass.gov URL returns HTTP 403 to this machine (both direct GET and the WebFetch tool), for HTML pages and for /doc/ downloads alike; the block is at mass.gov's edge, not a permissions issue. Each of the seven policy documents was therefore retrieved through the Internet Archive (web.archive.org/web/2026/<mass.gov URL>), which serves the mass.gov file itself. The documents' own internal control numbers and effective dates (EECLicensingProfDev20120904, EECOrientation20121004, Field Operations 2024-9 of 8 May 2024, CPR policy updated 17 Dec 2021, Safe Sleep 1 Oct 2023, FCCChokingHazardTraining20121128, FCCRegularAssistants20120626) are quoted from the retrieved files, so the dating does not depend on the archive's timestamp. https://web.archive.org/web/20260613122642/https://www.mass.gov/info-details/eec-licensing-policies-forms-and-technical-assistance — EEC Licensing Policies, Forms and Technical Assistance index, snapshot 13 June 2026. Confirms "Professional Development Policy" is still a currently published EEC policy. https://www.mass.gov/lists/licensing-policies-for-family-child-care-providers-0 (via web.archive.org snapshot 3 September 2025) — EEC's index of Licensing Policies for Family Child Care Providers.

Full page text extracted and searched: the string "orientation" appears ZERO times. The 2012 Orientation to Early Education and Care policy is no longer listed among the policies EEC publishes for family child care, although its /doc/ file still resolves. The page does list "EEC Policy Advisory - Field Operations 9 - EEC Essentials Training Policy", "EEC Essentials FAQ", "CPR and First Aid Training and Certification", "EEC Safe Sleep Policy 2023", "Choking Hazard Training" and "Use of Regular Assistants in Family Child Care Homes". DEAD-LINK MEASUREMENTS, taken 26 August 2026, each cited inside the field text: http://www.eec.state.ma.us/docs1/Workforce_Dev/SIDS%20revised%20self-study.pps — HTTP 503 http://www.eec.state.ma.us/docs1/Workforce_Dev/20120502-look-before-lock.pps — HTTP 503 http://www.eec.state.ma.us/docs1/regs_policies/FiveRightsMedAdmin/The5RightsofMedicationAdminis.htm — HTTP 503 http://www.eec.state.ma.us/docs1/regs_policies/FCCAssistOrient/FCCAssistantOrient.htm — HTTP 503 http://www.eec.state.ma.us/ProfessionalDevelopment/WebFindTraining.aspx — HTTP 503 http://www.mass.gov/edu/docs/eec/20101015-fcc-expansion-training.ppt — HTTP 403 (The first five are every training URL the operative 2012 orientation policy instructs a family child care applicant to use; the sixth is the capacity-expansion module for 7-10 children.) CONTRADICTIONS OF THE LOT 7 BRIEF, WITH THE TEXT IN HAND: 1. The brief asks whether "le transfert d'EEC annonce sous l'Executive Office of Education a change l'autorite qui delivre".

It has NOT. 606 CMR 7.00 names the Department of Early Education and Care as licensing authority throughout; 606 CMR 7.02 provides "Department - When used alone shall mean the Department of Early Education and Care"; the regulatory authority line is still M.G.L. c. 15D; EEC's own live portal is masthead-headed "DEPARTMENT OF EARLY EDUCATION AND CARE" with a 2026 copyright. What moved is the professional development web estate (strongstart.eoe.mass.gov, now 301 to childcare.mass.gov/educators). Reporting an authority change would be false. 2. The brief frames MA as "distinction family child care <= 6 + 2 d'age scolaire vs large family (10)". THERE IS NO SECOND LICENCE CATEGORY. 606 CMR 7.02 defines family child care as one thing, "no more than ten children younger than 14 years old". What varies is licensed CAPACITY and the qualification tier that unlocks it: 7.09(15)(b)1 for six or fewer, 7.09(15)(b)2 for seven or eight, 7.09(15)(b)3 for nine or ten. The "six plus two school age" figure is a RATIO row, 606 CMR 7.10(4)(e), which permits seven or eight children with ONE educator only where "All children over capacity of six must be school age"; 7.10(4)(g) requires TWO educators for seven to ten in the general case.

Massachusetts uses no "large family child care home" licence. 3. The brief's framing of a mandated topic list (SIDS/safe sleep, shaken baby, medication administration, mandated reporter) is not satisfied by 606 CMR 7.00. The chapter imposes the underlying duties (7.11(13)(e) back sleeping, 7.11(4)(d) mandated reporter status, 7.11(1) medication administration training) but enumerates NO course in SIDS, shaken baby or mandated reporting. The topic list exists only in the policy layer, as the thirteen modules of EEC Essentials 2.0 under Policy Advisory Field Operations 2024-9, which the FAQ says replaces "the mandatory 51A training". Anyone deriving the topic list from the Code of Massachusetts Regulations alone will get it wrong in both directions. 4. Method rule 1 applied and it mattered: the Secretary of the Commonwealth's 606 CMR 7.00 file is dated December 2021 and would have confirmed itself. It was cross-checked against the codified amendment notes (Register Issues 1452 and 1459, eff. 9/1/2021) before being relied on, and 606 CMR 7.09(20) was found in both, which is what makes the 2021 file the text in effect rather than a stale artefact.

FIELD-SPECIFIC NOTE (preservice_training): the single most consequential finding is that the pre-service gate has moved OUT of the 2012 orientation policy (delisted, all six of its training URLs dead) and INTO EEC Essentials 2.0 under Policy Advisory Field Operations 2024-9, which the FAQ states in terms must be completed "prior to licensure" for family child care providers and assistants. Everything published before May 2024 that describes the Massachusetts pre-service requirement as "a five-hour orientation plus a SIDS PowerPoint" is describing a world that no longer exists on the servers. UNVERIFIED: the current hour count and current approved vendor for the "pre-service training approved by the Department" required by 606 CMR 7.09(15)(b)2 for a licence to care for seven or eight children. The regulation names no number for that tier (unlike 7.09(15)(b)3, which says "a five hour pre-service training"), and the only policy that ever named a course for the 7-10 capacity increase, the 2012 orientation policy's "Maintaining Quality While Expanding Your Capacity", points at a mass.gov URL returning HTTP 403 with no successor named on any EEC page reachable from here.

The field text tells the applicant to obtain written confirmation from the regional licensor rather than asserting a number. UNVERIFIED: whether EEC still runs a separate, mandatory "Potential Provider Meeting" / "Potential Educator Meeting" as a precondition to applying. Both StrongStart item pages that described it now 301 to a login-gated portal, and no live EEC page reachable from this machine restates the requirement. It is therefore not asserted in the field text. UNVERIFIED: the current family child care licence application fee amount. 606 CMR 7.03(1)(c) requires "the required license application fee" without stating it; the fee schedule lives on mass.gov, which returns 403 here. UNVERIFIED: whether the new StrongStart LMS at childcare.mass.gov preserves learning history migrated from the previous SSPDS. The portal page is login-gated behind MyMassGov; the field text advises printing certificates rather than asserting either way. [program] https://www.mass.gov/lists/eec-laws-and-regulations - EEC's index of licensing regulations in effect, read 26 August 2026; the entry point used instead of any pinned rule PDF.

Serves 606 CMR 7 undated and 606 CMR 3 with an explicit "Effective November 17, 2026" label, which is what proves the index does publish forward-dated versions when they exist. https://www.mass.gov/doc/family-group-school-age-child-care-programs-606-cmr-7-0/download - full 54-page text of 606 CMR 7.00 as the index serves it today, read end to end. Source of every regulatory quotation in the entry: 7.02 definitions of Approved Activity Space, Certified Assistant, Child, Family Child Care, Infant, Kindergarten Child, Large Group and School Age Child Care, Licensed Capacity, Medical Emergency, Multi-age Grouping, Preschooler, Private Residence, Regular Assistant, School Age Child, Small Group and School Age Child Care, Toddler; 7.03(1)(b)-(c), 7.03(2), 7.03(3), 7.03(4)(b), 7.03(5)(a)-(f), 7.03(6)(b)1-2; 7.04(15) and 7.04(16); 7.07(2)-(4), 7.07(7), 7.07(8)(a), 7.07(15)(b)-(c); 7.08(8)(c); 7.09(7), 7.09(9), 7.09(11), 7.09(13), 7.09(15)(a)-(g); 7.10(3)(b), 7.10(4)(d)-(h), 7.10(5)(a), 7.10(6), 7.10(7)(a)-(d), 7.10(8)(c); 7.11(17)(a)-(d); 7.14(3). Version stamp inside the text: "(Mass. Register #1459 12/24/21)". https://www.sec.state.ma.us/reg_pub/pdf/600/606007.pdf - Secretary of the Commonwealth's numbered copy of 606 CMR 7.00, reached by navigating the Secretary's regulation-by-number listing rather than by a remembered link; same 54 pages, published 2021-12-24. Independent confirmation that the text above is the operative version. https://www.mass.gov/info-details/early-education-care-eec-proposed-amendments-to-regulations - read 26 August 2026; "Department of Early Education & Care does not have any proposed amendments to its regulations at this time."

No 606 CMR 7 rewrite is pending. https://malegislature.gov/Laws/GeneralLaws/PartI/TitleII/Chapter15D/Section1A - full definitions section of M.G.L. c. 15D. Source of the statutory "Family child care home" definition capped at 6 including participating children living in the residence, the "Large family child care home" definition requiring "at least 1 approved assistant when the total number of children participating in child care exceeds 6", "Family child care system", "Child care center" and "School-aged child care program".

This is the statutory two-tier scheme the regulation no longer mirrors. https://malegislature.gov/Laws/GeneralLaws/PartI/TitleII/Chapter15D/Section7 - Section 7(a), (b) and (d), including the provisional licence power for a "family child care home or large family child care home" that the regulation does not implement for family child care. https://malegislature.gov/Laws/GeneralLaws/PartI/TitleII/Chapter15D/Section8 - Section 8(c) verbatim, the statutory large-family prerequisite of "at least 3 years of experience in licensed family child care and ... at least 5 hours of specialized training before licensure as a large family child care provider and at least 10 hours of training each subsequent year", against which 606 CMR 7.09(15)(b)3 is measured in the entry. https://malegislature.gov/Laws/GeneralLaws/PartI/TitleII/Chapter15D/Section6 - Section 6(a) licence requirement; https://malegislature.gov/Laws/GeneralLaws/PartI/TitleII/Chapter15D/Section2 - Section 2(c) duty to license family child care homes and large family child care homes. https://malegislature.gov/Laws/SessionLaws/Acts/2026/Chapter163 - full enrolled text of the PROTECT Act, approved 5 August 2026. SECTION 3 adds M.G.L. c. 15D, Section 23;

subsections (c) and (e) quoted in the entry; SECTION 19 sets the deadline "not later than September 1, 2026 or the first day of the 2026-2027 school year, whichever is earlier" for every licensed family child care home to have the policy in effect. https://malegislature.gov/Laws/GeneralLaws/PartI/TitleII/Chapter15D/Section23 - returns 404 on 26 August 2026. The codified chapter does not yet contain Section 23; the session law is the only source. https://www.mass.gov/doc/eecfo-26-01emergency-preparednessadvisory/download - EEC Policy Advisory FO-26-01, "Emergency Preparedness in Child Care Programs", released 21 August 2026, effective 1 September 2026; model policy, attestation route, 4 September 2026 LEAD "Protect Act" upload category, 1 November 2026 LEAD Section 11 integration. https://www.mass.gov/doc/eec-essentials-20-training-requirements/download - EEC policy FO-26-04, "EEC Essentials 2.0 Training Requirements", Policy Number FO-26-04, Release Date May 6, 2026, Effective Date July 1, 2026, Applicability "All EEC-licensed Child Care and Funded Programs".

Source of the verbatim policy statement covering FCC licensees, certified assistants and regular assistants, the 13-course / ~12 hour early-childhood package, the pre-employment timing, the annual refresher due "on or before June 30th each year", the professional-development credit limitation, the First Aid/CPR disclaimer, and the compliance-monitoring start date of 1 July 2026. https://www.mass.gov/doc/eecfo-26-03temporary-closureadvisory/download - EEC policy FO-26-03, "Temporary Closures", released and effective 6 May 2026; its footnote establishes that the LEAD Temporary Closure transaction is for group and funded programs while "FCC programs needing to close temporarily may enter Inactive Status, as allowed for by 606 CMR 7.03(5)(d)". https://www.mass.gov/doc/use-of-regular-assistants-in-family-child-care-homes/download - EEC family child care policy statement (document code FCCRegularAssistants20120626). Source of the per-home aggregation rule ("no matter how many assistants he/she uses"), the per-home-not-per-person reciprocal rule, and "Regular assistants may work with a provider or Certified Assistant for any length of time when the provider or Certified Assistant is on the child care premises." https://www.mass.gov/doc/informal-cooperative-arrangement-and-occasional-care/download - EEC family child care policy statement (document code FCCInformalCooperative20040929). Source of "Child care must be either licensed/licensable (license required) or exempt (no license required).

Exempt care cannot be combined with licensed care", the "regular basis" test, the occasional-care thresholds, and the three informal-cooperative categories. https://www.mass.gov/lists/licensing-policies-for-family-child-care-providers - EEC's current family child care policy list, read 26 August 2026;

establishes which policies are live, including "Dual Licensure: Group Child Care and Family Child Care", "Inactive Policy for Family Child Care", "Freezing or Reducing Enrollment", "EEC Inspections and Visits Policy" and "Process for Contesting Findings from Visits and Investigations". https://www.mass.gov/info-details/learn-about-family-child-care - EEC's public description of the three capacity tiers and of the two assistant grades, quoted verbatim in the entry. https://www.mass.gov/guide/become-a-family-child-care-provider and its six steps at https://www.mass.gov/info-details/1-check-if-you-meet-fcc-licensing-requirements, /2-complete-fcc-program-trainings, /3-submit-your-fcc-license-application, /4-complete-your-fcc-background-record-check, /5-prepare-your-home-for-child-care, /6-complete-your-fcc-pre-licensing-visit - all read 26 August 2026. Source of the PQ number and StrongStart account sequence, the 1.5-hour Potential Provider Training (PPT 1 and PPT 2) and the 3-hour in-person Potential Educator Meeting held at a regional office, the "You have 90 days to complete the process" instruction, the LEAD Document Library upload list, the pre-licensing visit description ("your home should look exactly as it will on your first day of operation", "usually takes 1-2 hours"), the named documents checked at that visit, and the follow-up rule ("You must complete any follow-up items within 2 weeks of your visit. Corrective action plans must include notes and images of corrections."). https://www.mass.gov/doc/opening-a-family-child-care-fcc-program-initial-considerations/download - EEC handout, read 26 August 2026;

independently confirms the 150 / 225 / 35 square foot indoor thresholds and the 75 square foot outdoor threshold, and is the source of the "EEC teacher, lead teacher or director certification" wording that differs from 606 CMR 7.09(15)(b)1.e. https://www.mass.gov/child-care-program-licensing - read 26 August 2026; confirms the separate application routes for family child care, small group and school age, large group and school age, and family child care assistant.

CONTRADICTION OF THE BRIEF, STATED EXPLICITLY AS METHOD REQUIRES. The brief instructed me to treat the Massachusetts distinction as "family child care <= 6 + 2 d'age scolaire vs large family (10)". The official text contradicts the second half. There is no "large family child care" licence in 606 CMR 7.00. The string "large family" appears zero times in the 54-page regulation as both mass.gov and the Secretary of the Commonwealth serve it on 26 August 2026. The regulation defines one class, "Family Child Care ... for no more than ten children", and the ceiling of ten is reached inside that single class by adding an approved assistant under the multi-age grouping table at 606 CMR 7.10(4)(d)-(h) and by qualifying under the tiered prerequisites of 606 CMR 7.09(15)(b)1-3. The statutory term survives in M.G.L. c. 15D Sections 1A, 2(c), 6(a), 7 and 8(c), and in Section 9(b)'s inspection mandate for "large family day care homes", but it is not a licence you can apply for. The brief was right about the 6-plus-2 structure: 7.10(4)(e) does permit seven or eight children with one educator provided "All children over capacity of six must be school age", and 7.09(15)(b)2 requires that at least two of the seven or eight "must be school age".

The brief was also right that the assistant regime is the historic Massachusetts trap, though the trap is the 25-hours-per-year and 8-hours-per-seven-days solo ceiling on regular assistants, not the headcount. UNVERIFIED: the amount of the family child care licence application fee. 606 CMR 7.03(1)(c) and 7.03(3) both require payment of a fee; 102 CMR 1.03(5) says only that "A fee schedule may be obtained from the Office." No fee schedule appears on any EEC page read on 26 August 2026 and EEC's six-step provider guide never mentions one. The entry says a fee is required by rule and states no amount. UNVERIFIED: whether EEC in practice issues provisional licences to family child care applicants. M.G.L. c. 15D, Section 7(d) authorises it; 606 CMR 7.03(5) contains no provisional provision, and the provisional text appears only in the group-programme subsection 7.03(6)(b)1. The entry reports the conflict and advises against relying on a provisional family child care licence, rather than asserting either that they exist or that they do not. UNVERIFIED: how EEC reconciles the statutory three-year experience prerequisite in M.G.L. c. 15D, Section 8(c) with the one-year-plus-substitutions route in 606 CMR 7.09(15)(b)3 for a nine-or-ten-child licence.

Both texts are quoted; no EEC policy resolving the tension was found. The entry tells the applicant to get the regional office's position in writing. UNVERIFIED: the content of the "Dual Licensure: Group Child Care and Family Child Care" policy. It is listed on EEC's current family child care policy index and is cited by name only; the document itself was not read, and no substantive claim about its terms is made in the entry. NOTE ON ACCESS: www.mass.gov returned HTTP 403 to direct requests from this machine and www.sec.state.ma.us is behind an Incapsula challenge; all mass.gov, Secretary of the Commonwealth and malegislature.gov documents above were retrieved through the r.jina.ai reader proxy, which returns the target page's own text. Every regulation and policy was reached by navigating EEC's current index or the Secretary's current listing; no dated URL was re-downloaded to confirm itself. [ratios] https://www.mass.gov/lists/eec-laws-and-regulations — EEC's own index of licensing regulations in effect, opened today (via r.jina.ai; mass.gov returns HTTP 403 to direct fetches from this machine, Incapsula).

This is the index-of-rules-in-effect check required by method rule 1: the page serves exactly one family child care rule document, "Family, group & school age child care programs (606 CMR 7)", 376.41 KB, with no effective-date label, while the neighbouring residential rule is labelled "Effective November 17, 2026- Residential programs serving children and teen parents (606 CMR 3)". No newer 606 CMR 7 file is offered. https://www.sec.state.ma.us/reg_pub/pdf/600/606007.pdf — 606 CMR 7.00 as the Secretary of the Commonwealth's regulations database serves it today; fetched directly (HTTP 200, 368,061 bytes, 54 pages) and converted to text. The URL is the database's stable address for the chapter, not a dated snapshot.

Source of every 606 CMR quotation in this field: 7.10 preamble; 7.10(1); 7.10(2)(a)-(c); 7.10(3)(a) and (b); 7.10(4) preamble and (a); the five Multi-age Grouping rows 7.10(4)(d) through (h) with their Group Size, Minimum Number of Educators Present and Limits on Ages of Children columns; 7.10(5) and (5)(a)-(f), (i), (j), (k); 7.10(6)(a)1.-4. and (6)(b); 7.10(7)(a)-(d); 7.10(8) heading and (8)(b)1. and (8)(c); the 7.10(9)(b) fixed-age and 7.10(9)(c) mixed-age tables; 7.02 definitions of Certified Assistant, Regular Assistant, Multi-age Grouping, Infant, Toddler, School Age Child, Kindergarten Child, Educator, Licensed Capacity, Evening Care; 7.09(15)(a), (b)1.-3., (c)1.a.-b. and (c)2.a.-b.; 7.04(13)(a)2.; 7.07(9); 7.11(14) and 7.11(15)(a)1. and 3.; 7.13(1), (2), (3)(i), (4)(a) and (4)(f); the closing line "REGULATORY AUTHORITY 606 CMR 7.00: M.G.L. c. 15D." https://www.mass.gov/doc/family-group-school-age-child-care-programs-606-cmr-7-0/download — the licensing agency's own copy of 606 CMR 7.00, retrieved today through r.jina.ai (54 pages, 147,399 characters after normalisation). Cross-checked mechanically against the Secretary's PDF on six probe strings including "All children over capacity of six must be school age", "A regular assistant may be alone on the premises with up to six children" and "nine or ten children": all present in both.

The regulator and the Secretary serve the same text today, so no stale-copy divergence exists on this chapter. https://www.mass.gov/info-details/early-education-care-eec-proposed-amendments-to-regulations — EEC's proposed-rulemaking notice page, opened today. Establishes the sentence quoted at the end of the field: "Department of Early Education & Care does not have any proposed amendments to its regulations at this time." No pending amendment to 606 CMR 7.10. https://www.mass.gov/doc/use-of-regular-assistants-in-family-child-care-homes/download — EEC Family Child Care Licensing policy statement, internal code FCCRegularAssistants20120626, read in full today. Source of the "no matter how many assistants he/she uses" sentence, the per-home rather than per-person reading of the 8-hours/7-days and 25-hours/year limits, and the closing sentence "Regular assistants may work with a provider or Certified Assistant for any length of time when the provider or Certified Assistant is on the child care premises." https://www.mass.gov/doc/volunteers-student-interns-and-ratios/download — EEC Family Child Care Licensing policy statement, internal code FCCVolunteer2012.04.26, read in full today.

Source of the rule that a volunteer or intern must "apply and be approved/certified as a Family Child Care Approved Assistant" before being counted in family child care staff-to-child ratios. https://www.mass.gov/info-details/learn-about-family-child-care — EEC's public description of the three family child care tiers, opened today. Source of the quoted agency wording "Up to 8 children: A licensed Family Child Care provider may enroll up to 8 children in their program without an assistant if at least 2 of the children are school age" and "Up to 10 children: ... if there is an approved assistant working with them". https://www.mass.gov/info-details/learn-about-family-child-care-assistant-requirements — EEC's assistant eligibility page, opened today. Corroborates the two assistant tiers and the 25-hours/12-months and 6-children-alone limits, and states the certificates are valid for three years. Also carries the page attribution "Department of Early Education and Care / Executive Office of Education". https://malegislature.gov/Laws/GeneralLaws/PartI/TitleII/Chapter15D/Section1A — M.G.L. c. 15D, § 1A as the General Court serves it today (via r.jina.ai).

Source of the verbatim "Large family child care home" definition, including the sentence "A large family child care home shall have at least 1 approved assistant when the total number of children participating in child care exceeds 6", and of the "Family child care home" definition with its six-child sentence. https://malegislature.gov/Laws/GeneralLaws/PartI/TitleII/Chapter15D/Section2 — M.G.L. c. 15D, § 2, opened today. Source of "There shall be in the executive office of education a department of early education and care" and of § 2(c), the duty to "license or approve child care centers, school-aged child care programs, family child care homes and large family child care homes". https://malegislature.gov/Laws/GeneralLaws/PartI/TitleII/Chapter15D/Section6 and .../Section8 — opened today. § 6(a) establishes that the licensing authority is the department itself; § 8(c) establishes the statutory content of the large-family-home standards, including "at least 3 years of experience in licensed family child care and have completed at least 5 hours of specialized training before licensure as a large family child care provider and at least 10 hours of training each subsequent year", which is the statutory shadow of 606 CMR 7.09(15)(b)3. CONTRADICTION OF THE BRIEF, POINT ONE.

The Lot 7 brief said to verify "si le transfert d'EEC annoncé sous l'Executive Office of Education a changé l'autorité qui délivre". It has not, and there is no transfer to find. M.G.L. c. 15D, § 2 has read "There shall be in the executive office of education a department of early education and care" since the department was created in 2005; EEC has always sat inside EOE, and § 2(c) and § 6(a) still vest licensure in EEC itself. 606 CMR 7.00 still closes "REGULATORY AUTHORITY 606 CMR 7.00: M.G.L. c. 15D." Nothing resembling the Illinois DCFS-to-IDEC recodification has happened in Massachusetts. The lead is denied. CONTRADICTION OF THE BRIEF, POINT TWO. The brief framed the distinction as "family child care ≤ 6 + 2 d'âge scolaire vs large family (10)". That is the statute's vocabulary, not the regulation's, and the two do not line up. The phrase "large family child care home" appears nowhere in 606 CMR 7.00 — a case-insensitive search of the full 54-page text returns zero hits for "large family". There is one licence type, family child care, defined at 606 CMR 7.02 as care "for no more than ten children", and three capacities EEC may write on it (six, seven-or-eight, nine-or-ten), each unlocked by the licensee's own experience under 606 CMR 7.09(15)(b), not by hiring an assistant.

Presenting "large family child care" as a separate tier an applicant applies for is the stale 102 CMR 8.00 vocabulary. CONTRADICTION OF THE BRIEF, POINT THREE, AND THE REAL TRAP. The brief said "Le régime des assistants et le plafond réel avec assistant approuvé sont le piège historique du MA", and it is right that this is the trap, but the trap is not what the phrasing implies. The real ceiling with an EEC-approved assistant is ten, not more; and, critically, an assistant is not what unlocks eight. 606 CMR 7.10(4)(e) permits "seven or eight children" with "one educator" provided "All children over capacity of six must be school age", and 606 CMR 7.09(15)(b)2. licenses that tier on experience and pre-service training with no mention of an assistant. Against that, M.G.L. c. 15D, § 1A states that a large family child care home "shall have at least 1 approved assistant when the total number of children participating in child care exceeds 6". The statute and the regulation therefore disagree about whether an assistant is required at seven children. Both texts were read today and the conflict is real in the law as served.

The field states which one governs an applicant in practice (the licence and the regulation's table) and names the disagreement rather than hiding it. UNVERIFIED: the promulgation and last-amendment date of 606 CMR 7.00. The Secretary's PDF carries no effective-date line in its extractable text (the page footers that normally carry the register date did not survive text extraction, and the PDF's own creation timestamp, 24 December 2021, is a file property, not a legal date). The chapter's internal transition clause at 606 CMR 7.14(3) dates the regime to 22 January 2010. The Massachusetts Register cumulative table sits behind the Secretary's subscription login at sec.state.ma.us/reg_pub/login.aspx and could not be searched from here, so I cannot state when 606 CMR 7.10 was last amended — only that both the Secretary and EEC serve identical text today and that EEC has nothing pending. UNVERIFIED: whether EEC has issued any licensing policy statement, after the 2012 policies quoted here, that modifies how assistants count toward the two-educator rows. The family child care policy list was read in full today and contains no capacity or ratio policy beyond the two quoted; but EEC also distributes guidance through the LEAD provider portal, which requires a login.

UNVERIFIED: how EEC reconciles M.G.L. c. 15D, § 1A's assistant-above-six sentence with 606 CMR 7.10(4)(e). No policy statement, licensing procedure or advisory addressing the conflict was found. The field reports both texts and does not invent a reconciliation. NETWORK NOTE: www.mass.gov refuses direct requests from this machine with HTTP 403 (Incapsula) for both HTML pages and /doc/.../download PDFs. Every mass.gov item above was retrieved through the r.jina.ai text proxy against those exact URLs and returned mass.gov's own page furniture. www.sec.state.ma.us and malegislature.gov served their PDFs directly; malegislature.gov HTML was taken through the same proxy. [required_forms] MA / required_forms — sources actually opened, 26 August 2026 https://www.mass.gov/lists/eec-laws-and-regulations — EEC's live index of regulations in effect. Established what EEC serves TODAY as its licensing regulations: "Family, group & school age child care programs (606 CMR 7)", "Enforcement standards and definitions for licensure or approval (102 CMR 1)", "EEC BRC Regulations (606 CMR 14)", 606 CMR 3, 5, 10, 15. Method rule 1 applied: started from this index rather than from a pinned dated PDF. https://www.sec.state.ma.us/reg_pub/pdf/600/606007.pdf — Secretary of the Commonwealth's published text of 606 CMR 7.00. Full text extracted (253 KB).

Established the exact title: "606 CMR 7.00: STANDARDS FOR THE LICENSURE OR APPROVAL OF FAMILY CHILD CARE; SMALL GROUP AND SCHOOL AGE AND LARGE GROUP AND SCHOOL AGE CHILD CARE PROGRAMS". Regulatory authority stated at the end of the chapter: "606 CMR 7.00: M.G.L. c. 15D." Source of every regulation quotation in the 18 elements: 7.03(1)(c) application documents; 7.03(3) renewal 30 days; 7.03(5)(a)-(f) FCC-specific documents, three-year licence, capacity counting, location of care, one-licence rule; 7.04(2) unauthorised activities and likeness; 7.04(4) record requirements and five-year retention; 7.04(7) children's records; 7.04(8) record exceptions; 7.04(9) annual update and one-year consents; 7.04(12) confidentiality and release log; 7.04(14) required postings; 7.04(15) notifications to the Department; 7.04(16) FCC household/firearm/system notifications; 7.08(5),(6),(8),(9) family involvement and written information for parents; 7.09(10)-(15) educator health, qualifications, assistants, orientation, professional development; 7.10(4)-(7) ratios and FCC supervision; 7.11(2),(3),(5),(7),(17) medication table, IHCP, injury/incident record, emergency preparedness and drills, FCC-specific health and safety; 7.13(1)-(4) transportation. https://www.mass.gov/info-details/early-education-care-eec-proposed-amendments-to-regulations — checked for pending amendments.

Established, verbatim: "Department of Early Education & Care does not have any proposed amendments to its regulations at this time." No 2026 rewrite of 606 CMR 7.00 is pending; the text above is the operative text. https://malegislature.gov/Laws/GeneralLaws/PartI/TitleII/Chapter15d — cited by EEC as the enabling law (M.G.L. c. 15D). Linked from the EEC laws index; consulted only as the authority citation. https://www.mass.gov/doc/eec-brc-regulations-606-cmr-14/download — EEC's posted copy of 606 CMR 14.00: Criminal Offender and Other Background Record Checks. Established 14.04 definition of "Family Child Care Candidate", 14.05(2) candidate categories, 14.07(2),(7),(8) consent form submission and annual re-certification, 14.09(2)(a)-(c) final suitability determination required before EEC will issue a licence or an assistant certificate, 14.09(3) frequency exceptions. https://www.mass.gov/info-details/1-check-if-you-meet-fcc-licensing-requirements — EEC step 1. Established the plain-language BRC reach: "All household members and frequent visitors 15 years or older must also complete a BRC", including anyone who "Frequently and predictably visits your home.

This can include a family member, house cleaner, or friend." https://www.mass.gov/info-details/3-submit-your-fcc-license-application — EEC step 3. Established that the application is a LEAD transaction, "You have 90 days to complete the process", the LEAD Document Library upload list, and that the tax certification statement and the BRC consent form arrive by email after submission, with each household member and visitor 15+ getting their own consent form. https://www.mass.gov/info-details/4-complete-your-fcc-background-record-check — established the fingerprint-based CORI / DCF 51B / SORI state checks plus FBI national check, NSOR, and out-of-state checks for anyone living outside Massachusetts in the past five years. https://www.mass.gov/info-details/5-prepare-your-home-for-child-care — established that the pre-licensing preparation instrument is a self-guided checklist ("Opening a Family Child Care (FCC) Program – Before the Licensing Visit"), not a filed form. https://www.mass.gov/info-details/eec-licensing-policies-forms-and-technical-assistance — the parent hub. Established that FCC forms live at a separate list from the cross-programme list, which is why applicants report the forms "do not exist". https://www.mass.gov/lists/eec-licensing-forms-across-program-types — enumerated in full.

Established that the cross-programme forms library today contains ONLY the Child Care Provider Safe Sleep Pledge Form 2023 (with 11 translations), two Safe Sleep parent non-compliance letters, and the Application Fee Schedule. No application form, no BRC form, no child record form. https://www.mass.gov/lists/licensing-forms-for-family-child-care-providers — enumerated in full. The complete FCC forms library as served today: Family Child Care Application Payment Instructions (PDF and DOCX); Upgrade Application Payment Instructions; Certified Assistant Application Payment Instructions; Parent Handbook; Family Child Care Enrollment Packet; Family Child Care Sample Forms Packet; Notice to Parents Regarding Supervision of Children Involving Transportation; Children's Record Checklist and Instructions; Child Care Record Chart; Self Assessment Tool; Family Child Care Assistant Record; Assistants Documentation Checklist; Family Child Care Medical Form (PDF and DOCX). Thirteen titles. Each element in this field was checked against this list. https://www.mass.gov/lists/licensing-policies-for-family-child-care-providers — enumerated in full (41 FCC policies).

Established that the Individual Health Care Plan form and the EEC Sample Transportation Log are published inside the POLICIES list, not the forms list. https://www.mass.gov/doc/family-child-care-enrollment-packet/download — full text read. Internal marker FCCEnrollmentPacket20110406. Established the face sheet fields, the "on or before the first day your child begins care" deadline, the transportation plan / authorised pick-up page, the Written Acknowledgement of Receipt of Parent Handbook, the Parental Visit Notice, the school-age records certification, and the four-page developmental history. https://www.mass.gov/doc/family-child-care-sample-forms-packet/download — full text read. Internal marker FCCSampleFormPacket20100203. Established the ten sample forms it contains: Annual Update Form; Changes in Household Composition; Evacuation/Smoke Detector Log; Indirect Supervision Form; Outdoor Play with Periodic Supervision; Parental Permission for Medication and Record of Medication Administration; Record of Observations; Special Excursion (Field Trip); Permission for Use of On-Site Swimming Pool; Family Child Care Incident Report.

Also established the incident report's immediate-notification list and the 48-hour mailing rule. https://www.mass.gov/doc/parent-handbook-1/download — full text read. Established the EEC Family Child Care Parent Handbook template's structure and the fact that it still directs parents to two dead URLs (mass.gov/Eeoe/docs/EEC/regs_policies/20090122_606_cmr.pdf and eec.state.ma.us/docs1/20101124_eec_privacy_policy.pdf). https://www.mass.gov/doc/childrens-record-checklist-and-instructions/download — full text read. Marker FCCRecordChecklist/Instructions20150427. Established the twenty checklist rows and the rule "A copy of the current checklist must be submitted to the licensor on the day of the licensing study" and that a blank space "will indicate that the information is not on file". https://www.mass.gov/doc/family-child-care-medical-form/download — full text read. Marker FCCMedicalForm20101021. Established the clinician-addressed fields and the immunisation/exemption block. https://www.mass.gov/doc/family-child-care-assistant-record/download — full text read. Marker FCCAssistantRecord20100326. Established the documentation list, the orientation list, the assistant attendance-log requirement, and the miscitation "Regulation 7.09(15)(3)(f)". https://www.mass.gov/doc/assistants-documentation-checklist-0/download — opened.

Only the heading "ASSISTANTS DOCUMENTATION CHECKLIST" is extractable; the body did not render as text. Not relied on for any assertion. https://www.mass.gov/doc/individual-health-care-plan-policy-and-form/download — full text read. Policy "Effective Date: October 29, 2010 / Updated: June 30, 2022", plus the attached "EEC Individual Health Care Plan Form" and its acceptance of equivalent physician forms. https://www.mass.gov/doc/use-of-regular-assistants-in-family-child-care-homes/download — full text read. Marker FCCRegularAssistants20120626. Established that the 8-hour/25-hour caps are cumulative across all regular assistants used by one provider, and per-home rather than per-assistant. https://www.mass.gov/doc/notice-to-parents-regarding-supervision-of-children-involving-transportation-0/download — full text read. Marker FCCParentNoticeTransSupervision20100202. Established the six first-person conditions, the 50-foot limit, the school-bus-stop carve-out, and the under-six-months bar. https://www.mass.gov/doc/application-fee-schedule-1/download — full text read. Marker EECLicensingApplicationFeeSchedule20100217. Established FCC provider $100 new and renewal, Certified FCC Assistant $75, Upgrade $25, Change of Address $100, and the cheque/money-order instruction. https://www.mass.gov/doc/family-child-care-application-payment-instructions/download and https://www.mass.gov/doc/certified-assistant-application-payment-instructions-0/download — full text read.

Established the $100 and $75 amounts and the blank-template mailing address "Department of Early Education and Care, Regional Office Address, City, MA Zip Code". https://www.mass.gov/doc/child-care-provider-safe-sleep-pledge-form-2023/download — full text read, "Revised September 2023". Established that this is the only signed form in the cross-programme library and that it is a compliance instrument signed by "Licensee or Designee". WHERE THIS CONTRADICTS THE BRIEF AND THE TASK LIST 1. The brief flagged "whether the announced transfer of EEC under the Executive Office of Education has changed the issuing authority". It has not, on the text. 606 CMR 7.00 is still promulgated by the Department of Early Education and Care under M.G.L. c. 15D, EEC still appears on mass.gov as its own organisation ("offered by Department of Early Education and Care"), and EEC still issues the licence. The only visible EOE artefact is the mass.gov search scope ("search in Executive Office of Education") and the StrongStart domain strongstart.eoe.mass.gov. No change of licensing authority is asserted in this field. 2. The task list assumed a discrete "licensing application" form.

There is none. EEC publishes no downloadable FCC licence application; the application is a LEAD transaction with a 90-day clock. Any product telling a Massachusetts applicant to "download and complete the application form" is describing a world that no longer exists. 3. The task list assumed "background record check forms for each household member and assistant". The correct reach is wider and is set by 606 CMR 14.04 and 14.05(2): licensee, assistants, ALL household members 15 or older regardless of presence during child care hours, AND all persons regularly on the premises 15 or older including volunteers and other regular visitors. And the consent form is not a downloadable form: EEC emails an individual online consent form to each candidate. 4. The task list assumed a "photograph/media release" form. EEC publishes none. The duty is created by 606 CMR 7.04(2)(a) and (b) and must be satisfied by a consent the provider drafts; the enrolment packet's photograph field is an optional identification photograph under 7.04(7)(a)1.e, not a release. 5. The task list assumed an "assistant approval request" form.

No EEC form bears that name. What exists is a Certified Assistant application transaction with a $75 fee, the Family Child Care Assistant Record kept on site, the Assistants Documentation Checklist, and a BRC that must reach a final suitability determination before EEC will issue a certificate (606 CMR 14.09(2)(c)). 6. The task list assumed standalone forms for the medication log, the incident/injury report, the attendance record and the fire evacuation drill log. Only the medication permission/log, the incident report and the evacuation/smoke detector log exist as EEC documents, and all three are pages inside the Family Child Care Sample Forms Packet, not separately downloadable. No attendance form is published at all; the provider builds it to 606 CMR 7.04(4)(a). 7. The brief's method note warned that a codified regulation may cite a repealed chapter. Checked and DISPROVED here: 606 CMR 7.03(1)(c)1 cross-references 102 CMR 1.05(1), which looks stale but is not — EEC still serves 102 CMR 1, "Enforcement standards and definitions for licensure or approval", from its live regulations index.

Recorded so no later writer "corrects" it away. UNVERIFIED: the version dates carried inside the EEC forms (FCCEnrollmentPacket20110406, FCCSampleFormPacket20100203, FCCMedicalForm20101021, FCCAssistantRecord20100326, FCCRecordChecklist/Instructions20150427, FCCParentNoticeTransSupervision20100202, FCCRegularAssistants20120626, EECLicensingApplicationFeeSchedule20100217) are internal document markers, not proof that EEC has not silently re-issued the file; I could not confirm a last-revised date from EEC. The Application Fee Schedule's cheque-and-money-order instruction could not be reconciled against the current LEAD payment channel — EEC's step-3 page never mentions how the $100 is paid, and I could not open a LEAD session to see. The body of the Assistants Documentation Checklist did not render and its contents are unknown. The "Self Assessment Tool" and "Child Care Record Chart" were listed but not opened, and the English-language "Child Care Record Chart" appears on the list only in Khmer, Portuguese and Spanish versions — whether an English version has been retired is unconfirmed.

The exact current text of 102 CMR 1.05(1) was not read. Whether the effective date of the served 606 CMR 7.00 text predates or postdates any 2025-2026 Massachusetts Register amendment could not be confirmed: the Secretary of the Commonwealth's CMR index at sec.state.ma.us is behind an Incapsula anti-bot wall that refused every request, so the operative-version check rests on EEC's own live regulations index plus the confirmed absence of pending amendments. mass.gov itself returns HTTP 403 to direct requests; every mass.gov page and PDF above was read through a text-extraction proxy (r.jina.ai) rather than fetched directly, so rendering artefacts in tables (notably the 606 CMR 7.11(2)(l) medication table, which was instead read from the Secretary of the Commonwealth's PDF) are possible. [required_postings] MASSACHUSETTS — required_postings — sources actually opened, 26 August 2026. Access note: www.mass.gov returns HTTP 403 to direct fetches from this environment (WAF). Every mass.gov document below was read through the r.jina.ai text proxy against the live mass.gov URL, so the bytes are the ones mass.gov served on 26/08/2026, not a cached mirror.

No pinned/dated URL was re-downloaded; every document was reached by walking the live index (Method rule 1). https://www.mass.gov/regulations/606-CMR-700-standards-for-the-licensure-or-approval-of-family-child-care-small-group-and-school-age-and-large-group-and-school-age-child-care-programs — this "606 CMR 7.00" URL does NOT serve the regulation; it renders EEC's "EEC Laws and Regulations" index page. That index is the entry point that must be used, because it is the only place that names the file currently in force. Today it serves 606 CMR 7 as "Family, group & school age child care programs (606 CMR 7)" at /doc/family-group-school-age-child-care-programs-606-cmr-7-0/download — a different document slug from the two 606 CMR 7 slugs that search engines return.

It also shows 606 CMR 3 in an "Effective November 17, 2026" version, i.e. EEC is actively republishing this shelf. https://www.mass.gov/doc/family-group-school-age-child-care-programs-606-cmr-7-0/download — the full current text of 606 CMR 7.00, 54 pages, sections 7.01 through 7.14. Established: 7.04(14) "Required Postings" and its four items (a) 911 reminder + program telephone, address and location in the facility, (b) Poison Control Center number + emergency back-up person, (c) privacy-protected medication list and allergy list, (d) the current license or approval; 7.04(4)(a)3 and (b)-(d) record-keeping for evacuation drills and attendance; 7.03(2) licensed capacity, 7.03(3) timely-renewal continuation, 7.03(1)(c)4 and 7 packet and volunteer plan; 7.04(16) family-child-care additional requirements (no postings); 7.04(17)(p) group-only postings (health care policy location, consultant name/address/phone, first aid kit location, emergency and evacuation procedures next to each exit); 7.04(17)(o) staffing documentation kept not posted; 7.05(8)(a) corporal punishment prohibition and absence of any posted discipline rule;

7.08(6)(a)-(n) the fourteen written-information-before-enrollment items, including (h) guidance plan, (i) illness exclusion criteria, (l) mandated reporter notice, (m) EEC licensure notice with regional office telephone and address, (n) compliance-history statement; 7.08(8)(k) menu-deviation notice; 7.08(9)(a) firearm notice in FCC; 7.10(8)(b)2 posted staff work schedule, group-only; 7.10(6)-(7) FCC additional supervision rules with no posting; 7.11(5)(d) items that must accompany children off premises; 7.11(7)(e) exit signs posted, all programs; 7.11(7)(f)-(i) written emergency plan content, monthly drills and drill documentation; 7.11(9) exclusion policy in conformance with DPH; 7.11(13)(d) daily-schedule rest period; 7.11(17)(b) FCC ten-minute emergency caregiver; 7.11(18)(b) escape-route diagram posted conspicuously at each means of egress, group-only; 7.11(18)(c)1 diapering plan posted in diapering areas, group-only; 7.11(19)(a)-(b) written health care policy and health care consultant, LARGE group only; 7.12(7)(f)-(g) menus available to parents on request and kept on file one year;

7.14(3) prior licenses under 102 CMR 7.00/8.00 and the 22 January 2010 date; REGULATORY AUTHORITY 606 CMR 7.00: M.G.L. c. 15D. https://www.mass.gov/doc/enforcement-standards-and-definitions-for-licensure-or-approval-102-cmr-1/download — 102 CMR 1.00, still served today from the same EEC index.

Established the two posting duties that are NOT in 606 CMR 7.00: 1.03(8) "Posting of License. The provider shall post conspicuously any license issued by the Office," and 1.09(2)(a) "Every licensee shall post in a conspicuous place any current license or approval issued by the Office and any notice of hearing, notice of sanction, order, or decision issued by the Office... in an area easily viewed by visitors and employees." Also 1.03(6) Availability of Regulations (copy on premises, available to any person upon request — NOT posted), 1.09(2)(b)-(e) notice-to-parents and parent-list powers, 1.06(1)-(2) right to visit and complaint investigations. Currency warning recorded in element 07: this chapter is written for "the Office of Child Care Services," abolished in 2005, its stated authority is M.G.L. c. 28A rather than c. 15D, and its stated effective date is 1 May 1997 — yet EEC serves it as live law and relies on 1.06 in its own 2020 inspections policy. https://www.mass.gov/info-details/early-education-care-eec-proposed-amendments-to-regulations — read to test currency of the regulation text.

States today: "Department of Early Education & Care does not have any proposed amendments to its regulations at this time." So the 606 CMR 7.00 text above is not about to be superseded; the movement in this field is in POLICY, not regulation. https://www.mass.gov/doc/emergency-preparedness-in-child-care-programs-0/download — EEC policy FO-26-01, "Emergency Preparedness in Child Care Programs," release date 21 August 2026, effective date 1 September 2026, 22 pages. THE headline finding for this field: under "Posting and Notification," all programs must "Post their emergency preparedness plan in plain view next to the program's EEC child care license."

Also established the eleven mandatory plan topics, the two-relocation-site rule, staff training and log duties, the FCC solo-educator annual verbal attestation, the drill-log rule "retain the above log in a secure location and provide it to EEC staff upon request," LEAD submission by 1 September 2026, the COMPLIANCE list of what a visit reviews, and the OBSOLETE list which kills the 2014 and 2019 contingency-plan policies AND the March 2026 version of this same policy. https://www.mass.gov/doc/eecfo-26-01emergency-preparednessadvisory/download — Policy Advisory for FO-26-01. Established the implementation calendar: c. 15D § 23(b) "goes into effect September 1, 2026, regardless of whether a child care program has adopted a policy reflecting this provision"; LEAD upload of the Interactions with Civil Law Enforcement policy or Attestation opens 4 September 2026; the full Section 11 requirement lands in LEAD by 1 November 2026. https://malegislature.gov/Laws/SessionLaws/Acts/2026/Chapter163 — Acts of 2026, c. 163 (the PROTECT Act), an emergency law, "Approved, August 5, 2026." SECTION 3 adds M.G.L. c. 15D § 23; § 23(b) bars civil-law-enforcement arrests on licensed or department-funded child care premises without a judicial warrant or order; § 23(c) requires every licensed child care center, family child care home, school-aged program and group care facility to adopt an interactions policy with a designated contact person, documentation procedures and staff procedures; § 23(e) makes (b) and (c) apply whether or not the policy is adopted.

SECTION 19 fixes the deadline at "not later than September 1, 2026 or the first day of the 2026-2027 school year, whichever is earlier." https://malegislature.gov/Laws/GeneralLaws/PartI/TitleII/Chapter15d — the codified General Laws index for chapter 15D as served today ENDS AT SECTION 22. The new § 23 is not yet in the codified index even though the session law creating it was approved 5 August 2026 and its operative date is 1 September 2026. Textbook Method rule 2: the session law is the current law and the codification is the stale one. Do not verify § 23 against the General Laws index. https://www.mass.gov/doc/self-assessment-tool-0/download — EEC Family Child Care Self-Assessment Tool (internal file id FCCSelfAssessmentTool20130403, i.e. dated 2013 but served today). It is explicitly the licensor's visit instrument: "This checklist will assist you in preparing for the licensor's visit to your home. The expectation is that this assessment is completed and reviewed during the visit." Established that the posted set a licensor reads aloud includes "A current EEC License and, if applicable, Assistant Certificates or Approvals" — the assistant certificate posting is not in 606 CMR 7.04(14) — and the cell-phone caveat: "if you are utilizing a cell phone, 911 does not connect you with local authorities.

Please plan an alternative method of compliance."

Also the exit-sign, diapering-separation and first-aid-kit questions cited in elements 08, 11 and 12. https://www.mass.gov/doc/exits-and-evacuations-in-family-child-care-programs-policy/download — EEC policy, effective 29 January 2013, updated 8 May 2024. Established the FCC exit-sign standard that is STRICTER than 606 CMR 7.11(7)(e): all exits "clearly marked with visible exit signs posted above the approved exit," plus the definition of two separate exits, the bulkhead/garage conditions, the elevator exclusion, the apartment rule and the converted-attic/basement certificate-of-occupancy carve-out. https://www.mass.gov/doc/individual-health-care-plan-policy-and-form/download — EEC Individualized Health Care Plans policy, effective 29 October 2010, updated 30 June 2022, citing 606 CMR 7.11(3). Established the contrast used in element 05: the IHCP "must be maintained in the child's file," "must be kept confidential and should be shared only with those program staff who might need to deal with an emergency" — a record, expressly NOT a posting, unlike the 7.04(14)(c) medication and allergy lists. https://www.mass.gov/doc/eec-inspections-and-visits-policy/download — EEC Inspections and Visits policy, updated 4 April 2020. Established what a monitoring visit is: authority under 102 CMR 1.06(1)-(2);

"at least one pre-licensing visit... to determine, at a minimum, compliance with health, safety, and fire standards" and "at least one annual unannounced visit... to ensure compliance with all EEC regulations"; differential monitoring; content drawn from 45 CFR 98.41. https://www.mass.gov/lists/licensing-policies-for-family-child-care-providers — the live FCC policy index; used to find which policies EEC serves today and to confirm there is no separate "required postings" policy for family child care. https://www.mass.gov/lists/eec-policy-transmittals — EEC's advisory list; confirmed FO-26-01 is the current emergency-preparedness advisory and that the 2026 shelf is dominated by PROTECT Act implementation. https://www.mass.gov/doc/complaints-referral-notification-and-corrective-action/download — EEC Child Care Licensing Policy Statement P-EEC-09. Establishes CCR&R/VMA complaint referral duties and that "EEC will investigate all allegations against licensed providers of non-compliance with licensing standards."

It imposes NO posting of a complaint procedure on the provider. https://www.mass.gov/doc/family-child-care-sample-forms-packet/download — EEC FCC Sample Forms Packet (internal id FCCSampleFormPacket20100203). Read to check whether EEC supplies a posting template; it does not. It contains consents, annual update and incident report forms only. https://www.mass.gov/child-care-program-licensing — live EEC licensing hub; confirms the LEAD portal is the licensing channel and that the only complaint form EEC publishes as a top task is the Unlicensed Child Care Complaint Form at childcare.mass.gov/reportunlicensedcare. WHERE I CONTRADICT THE BRIEF AND THE FIELD ASSIGNMENT 1. The assignment listed "the daily schedule" as a posting. It is not one. Nothing in 606 CMR 7.00 requires a daily schedule to be displayed. The only schedule required to be posted is the staff work schedule at 606 CMR 7.10(8)(b)2, and that subsection is headed "Additional Provisions for Small Group and School Age and Large Group and School Age Child Care" — it does not bind family child care at all. 2. The assignment listed "the current menu where meals are served" as a posting. 606 CMR 7.12(7)(f) says the licensee must "make available to parents on request written menus, including snacks, for each week."

Available on request, not posted. The enforceable half is 7.12(7)(g), keeping previous menus on file for one year. 3. The assignment listed "the parent complaint procedure and EEC's contact for filing a complaint," "the mandated reporter notice," "the discipline policy" and "the illness exclusion policy" as postings. All four are written-information-before-enrollment items under 606 CMR 7.08(6)(l), (m), (n), (h) and (i). There is no posting duty for any of them, and no "parent complaint procedure" posting exists in Massachusetts at all. 4. The assignment listed "the fire drill log." Massachusetts has no fire-drill posting. 606 CMR 7.11(7)(h) and 7.04(4)(a)3 require monthly EVACUATION drills to be documented and kept, and FO-26-01 requires the log to be "retain[ed]... in a secure location and provide[d] to EEC staff upon request." 5. The assignment listed "the EEC licensing regulations themselves being available to parents." Correct in substance but the citation is not in 606 CMR 7.00 — it is 102 CMR 1.03(6), it is on-premises-and-on-request rather than posted, and it runs to "any person," not only parents. 6. The assignment listed "the emergency evacuation plan and floor diagram."

Split it. The escape-route DIAGRAM at each means of egress (606 CMR 7.11(18)(b)) and the emergency and evacuation PROCEDURES next to each exit (606 CMR 7.04(17)(p)4) are group and school age requirements only — a family child care home owes neither. What every program now owes, from 1 September 2026 and by policy rather than regulation, is the emergency preparedness PLAN posted in plain view next to the license (FO-26-01). 7. The DEEP-BRIEF's MA lead says to verify whether "the transfer of EEC announced under the Executive Office of Education has changed the authority that issues." On the text served today it has not. 606 CMR 7.00 is still promulgated by the Department of Early Education and Care under M.G.L. c. 15D; the mass.gov search scope offers both "Department of Early Education and Care" and "Executive Office of Education," and EEC's letterhead on FO-26-01 is its own (50 Milk Street, 14th Floor, Boston, MA 02109). Nothing in the licensing chain has moved to EOE. 8. The brief's warning that the regulation is the stale layer holds here in an unusual shape: 606 CMR 7.00 is current and stable (EEC has no proposed amendments), but the POSTING list in 606 CMR 7.04(14) is now incomplete on its face, because a policy issued five days ago adds a posting the regulation does not mention.

UNVERIFIED: the actual telephone number of the Poison Control Center serving Massachusetts — 606 CMR 7.04(14)(b) requires the number to be posted but does not print it, and I did not open a Department of Public Health page that states it, so no number is asserted in any element. Also unverified: whether EEC's LEAD licensing checklist or licensor visit form contains posting line-items beyond those in the 2013 Family Child Care Self-Assessment Tool (LEAD is behind a provider login); whether a Massachusetts fire-code posting (e.g. 527 CMR / local fire department requirements) imposes any child-care posting beyond 606 CMR 7.11(7)(e), since 606 CMR 7.07(3) only requires the licensee to "submit evidence of compliance with applicable fire codes" and I did not open 527 CMR; and the precise regional-office telephone numbers a program must give parents under 606 CMR 7.08(6)(m), which came from a search-result summary rather than a page I opened, and which are therefore not asserted in any element.

Verified 2026-08-26. General information, not legal advice and not a guarantee of licensure — confirm with your state’s licensing agency before applying.