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` THE DEPARTMENT OF HUMAN SERVICES Committee on Education and Workforce Development Wednesday, 22 October 2025 SENATOR KURT VIALET, CHAIRMAN Virgin Islands Department of Human Services “Working Together To Make A Difference” 1 Testimony of the Virgin Islands Department of Human Services on Bill No. 36-0069: An Act amending Title 17, Virgin Islands Code, Chapter 9, Subchapter I, Section 82(a) by changing the age a child begins kindergarten from five years of age to four years of age Wednesday, October 22, 2025 Good afternoon Chairman Vialet, Senators of the Committee on Education and Workforce Development, invited testifiers, and fellow Virgin Islanders. My name is Carla Benjamin, Assistant Commissioner of the Virgin Islands Department of Human Services, and I appear before you today on behalf of Commissioner Averil George, who is unable to attend this hearing due to a previously scheduled engagement. I am joined in the well today by Ms. Masikia Lewis, Administrator of the Office of Head Start, who oversees the daily operations of our federally funded early childhood education program. Together, we thank you for the opportunity to provide testimony on Bill No. 36-0069, which proposes to lower the starting education age from five years to four, thereby requiring kindergarten attendance by age four. The Department of Human Services plays a critical role in early childhood education through our administration of the federally funded Office of Child Care and Regulatory Services, which licenses, monitors, and provides quality improvement and training opportunities for all early childhood education programs in the Territory, and the Head Start Program, which serves children ages three to five across St. Thomas, St. Croix, and St. John. As such, any change to the statutory age for kindergarten entry intersects with the services we deliver, the federal regulations that govern Head Start, and the broader childcare and education landscape of the Virgin Islands. The Value of Early Education We begin by recognizing the intent of the legislation. Research confirms that the earliest years of a child’s life are critical to cognitive development, language acquisition, and social-emotional growth. Starting schooling earlier can, under the right conditions, increase access to structured learning, smooth transitions from preschool, and help narrow disparities among children from different socioeconomic backgrounds. We also acknowledge that the bill’s sponsor is correct in pointing to the international trend: many jurisdictions have adopted policies that allow younger children to enter formal schooling earlier, often with positive results where strong supports are in place. Developmental and Operational Concerns At the same time, the Department must raise several critical concerns. First, not all four-year-olds are developmentally prepared for the structure and expectations of a kindergarten classroom. According to the National Association for the Education of Young Children (NAEYC), readiness for kindergarten varies widely among children, and policies that mandate earlier entry without accounting for developmental differences can create unnecessary stress and learning gaps. (NAEYC, Developmentally Appropriate Practice, 4th Edition, 2020) While some children may thrive, others may struggle socially, emotionally, or academically, and pushing Virgin Islands Department of Human Services “Working Together To Make A Difference” 2 children into formal schooling before they are ready may risk creating frustration for both students and teachers. The Harvard Center on the Developing Child emphasizes that strong social-emotional foundations—built through play-based early learning settings—are critical predictors of later academic success and self-regulation in school. (Center on the Developing Child, Harvard University, “Building the Brain’s Air Traffic Control System,” 2011) Four-year-olds who are not ready for assessments and evaluations related to the onset of formal schooling may be misdiagnosed and labeled with developmental delays and other potentially stigmatizing characterizations that they would likely not face had they been allowed another year of social, emotional, and intellectual preparation and growth. Parents and caregivers who determine that their preschool-aged child would benefit from a structured early childhood education setting may already access prekindergarten via the Virgin Islands Department of Education’s Granny Preschools, as well as through structured classroom settings in private and parochial schools. Additionally, Head Start exists precisely to provide a bridge for children during these formative years, offering individualized instruction, social-emotional development, health and nutrition supports, and family engagement in ways that are not replicated in the public school setting. Federal studies have shown that children who participate in Head Start programs demonstrate significant gains in vocabulary, early literacy, and social skills before kindergarten entry. (U.S. Department of Health & Human Services, Head Start Impact Study Final Report, 2010) If four-year-olds are shifted wholesale into kindergarten, Head Start’s enrollment of second-year students (four-year-olds) would decline significantly, and this in turn would affect the program’s federal funding allocation, which is based on enrollment levels. As of this month, the Virgin Islands Head Start Program is operating at 91.9% of its funded enrollment of 637 children, with 586 currently enrolled. Of that number, 53.4%—more than half—are four-year- olds. In the St. Thomas/St. John District, there are 249 children enrolled, of which 60.1% (151) are four- year-olds. In the St. Croix District, there are 337 children enrolled, of which 48% (162) are four-year- olds. The passage of this bill would therefore be very detrimental to the Head Start Program, as it would directly eliminate a majority of our current student population and destabilize the funding and staffing that sustain it. At this time, DHS is actively managing five major Head Start construction projects across the Virgin Islands. These projects are nearing completion at varying stages, with anticipated finish dates now ranging from December 2025 through January 2026. Specifically: St. Croix • Anna’s Hope: Estimated completion December 20, 2025 • Concordia: Estimated completion December 20, 2025 St. Thomas • Lindbergh: Estimated completion December 2025 • Minnetta Mitchell: Estimated completion December 2025 • Bolongo: Estimated completion January 2026 Virgin Islands Department of Human Services “Working Together To Make A Difference” 3 These facilities represent a transformative investment in early childhood education and are being purpose- built to serve three- to five-year-olds under the current Head Start model. Any statutory shift of four-year- olds into kindergarten would directly affect the utilization of these new centers and the federal funding tied to their enrollment. Additionally, the Virgin Islands Department of Education would need to absorb an entirely new cohort of students that require instruction from teachers with specialized early childhood competencies. This would require additional classrooms, early childhood education–credentialed teachers, and instructional materials. Given current teacher shortages, such an expansion would strain already scarce resources and potentially dilute instructional quality unless paired with significant investment in staffing and infrastructure. The Learning Policy Institute has found that early childhood classrooms require teachers trained in child development and differentiated instruction, and that expanding enrollment without adequate staffing support often leads to lower instructional quality. (Learning Policy Institute, “Understanding Teacher Shortages,” 2017) Parents, too, would be pressured to send their child to kindergarten earlier than they believe their child is ready, creating inequities between families who wish to follow the statutory mandate and those who feel strongly about keeping their child in a preschool or Head Start setting until age five. Private childcare centers and preschools, which often depend on four-year-olds for enrollment, may also be destabilized by such a shift, further reducing childcare options in an already limited market. Conclusion In conclusion, the Department of Human Services supports the overarching goal of expanding access to high-quality early education. We recognize the value of engaging children earlier, reducing disparities, and supporting their academic and social-emotional development from the start. However, we urge that any shift in kindergarten entry age be undertaken with careful coordination between the Department of Education, the Department of Human Services, and private childcare providers. Such a change should be accompanied by thorough analysis of its impact on Head Start and federal funding streams, and a realistic assessment of the resources required to ensure that our youngest learners thrive. We stand ready to collaborate with this body and with our education partners to ensure that the best interests of Virgin Islands children and families remain at the center of any reform References National Association for the Education of Young Children (NAEYC). Developmentally Appropriate Practice, 4th Edition. Washington, D.C.: NAEYC, 2020. Center on the Developing Child, Harvard University. Building the Brain’s “Air Traffic Control” System: How Early Experiences Shape the Development of Executive Function. Cambridge, MA: Harvard University, 2011. U.S. Department of Health and Human Services, Administration for Children and Families. Head Start Impact Study: Final Report. Washington, D.C.: HHS, 2010. Learning Policy Institute. Understanding Teacher Shortages: 2017 Update. Palo Alto, CA: Learning Policy Institute, 2017. Virgin Islands Department of Human Services “Working Together To Make A Difference” 4