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November 17, 2025
Gina Anderson, Authorized Agent Start Childcare and Learning Center Woodbury
12655 Arcola Trl N
Stillwater, MN 55082
License Number: 2000106 (Child Care Ctr) Program Location:6255 Upper Afton Rd, Woodbury, MN 55152
Dear Gina Anderson:
The Minnesota Department of Human Services (DHS), Division of Licensing, received your request for reconsideration regarding Citations 1 through 8 in the Correction Order (enclosed) issued to you on July 25, 2025.
Reconsideration Determination
Citation 1 Violation. The 36-month range in age allowed for a group that mixes different age categories was exceeded. Through conversations with staff persons, it was determined that the preschool and school age children were combined. While they were combined, the oldest child was eight years old and the youngest child was three years old, which exceed the 36-month range in age allowed when combining age categories. (Summer Camp Classroom: School Age classroom)
Applicable Law. During the center’s regular hours of operation, children in different age categories may be mixed within a group if there is no more than a 36-month range in age among children in the group. Minnesota Rules, part 9503.0040, subpart 3, item B, (2). Your Response. First, you stated that you were preoccupied with the CCAP representative at the unannounced visit, and you were asked to bring the CCAP representative to the licensors in another part of the building. “Had [you] not been asked to do this by the CCAP rep, [you] would have remained with the school agers.
Second, you stated that the school age group and preschool group were in the gym because of the heavy rain.
Third, you stated that you “collaborated with the preschool teacher to separate the groups, and within minutes, the school age children left the gym.
Finally, you requested “clarification on what constitutes a reasonable timeframe to identify, address, and resolve such situations before a citation is issued” and that you “would have immediately acknowledged [your] understanding of the 36 month age grouping and explained [your] immediate response and resolution.”
Reconsideration Determination. The licensing violation was issued due to the greater than 36-month age difference between the children grouped together in the gym. You stated that the school age group and preschool age group were in the gym because of the heavy rain that day. During the center’s regular hours of operation, children in different age categories may be mixed within a group if there is no more than a 36-month range in age among children in the group. The licensor observed the youngest child to be three years old and the oldest child was eight years old. While the Commissioner’s appreciates your prompt correction of the violation when brought to your attention, there was more than a 36-month age gap between the youngest and oldest children in the gym. Therefore, Citation 1 is affirmed.
Citation 2 Violation. The program did not comply with cleanliness requirements; the indoor space was not clean (Toddler 2 Classroom, Pre-K Classroom and Infant 2 Classroom). The full length mirror was visibly dirty with streaks. (Toddler 2 Classroom: Toddler classroom)
There was a visibly large spider web on the shelves near the easel. (Pre-K Classroom: Preschool classroom) The grey rug was visible dirty with white flakes. (Infant 2 Classroom: Infant classroom)
As defined in Minnesota Rules, part 9503.0005, subpart 9, clean means 'free from dirt or other contaminants that can be detected by sight, smell, or touch.'
Applicable Law. The license holder must ensure that the indoor and outdoor space and equipment of the center must be clean. Minnesota Rules, part 9503.0140, subpart 9.
"Clean" means free from dirt or other contaminants that can be detected by sight, smell, or touch. Minnesota Rules, part 9503.0005, subpart 9.
Your Response. First, you stated that “[a]t the time of the visit, Transition 1, Transition 2, Toddler 2, and Pre-K classrooms were inactive.” Second, you did not dispute that the mirror was dirty with streaks. Third, you did not dispute that there was a large spider web on the shelves near the easel in the Pre-K Classroom. Fourth, you stated that the program director was “engaged in a sensory activity with Infant 2 involving edible materials when licensing arrived” and “temporarily paused the activity to meet with the licensors and was cited for incomplete clean-up.” You noted that “there were no children in the classroom with the mess. The clean-up was completed immediately upon his/her return.” Finally, you requested “guidance on what is considered a reasonable timeframe to conduct and clean up developmentally appropriate activities during unannounced visits, balancing regulatory expectations with the value of sensory learning.” Reconsideration Determination. The program has Transition 1, Transition 2, Toddler 2, and Pre-K classrooms licensed for child care. The items identified in the citation were in licensed classrooms. The program must ensure that the licensed spaces are clean and free from dirt or other contaminants that can be detected by sight, smell, or touch.
Citation 2 is affirmed as to the dirty mirror and spider web because they were visibly dirty, and you did not dispute that they were dirty.
Regarding the rug in the Infant 2 classroom: while you stated that the program director was engaged in a sensory activity with a child involving edible materials when licensing arrived and paused the activity to meet with the licensors prior to being cited, the licensor noted that the program director was in the office when licensing arrived. The program director left debris (white flakes) on the rug. The Commissioner acknowledges that the program director was in the middle of a sensory activity, which resulted in dirt left on the rug. However, the rug was not clean, as it was not free from dirt or other contaminants that can be detected by sight, smell, or touch. The license holder must ensure that the indoor space is clean. Therefore, Citation 2 is affirmed.
Citation 3 Violation. Children did not have access to facial tissue (Transition 2 Classroom and Transition 1 Classroom). Applicable Law. The license holder shall provide the following supplies and make them accessible to children: toilet paper, liquid hand soap, facial tissues, and single use paper towels or warm air hand dryers. Minnesota Rules, part 9503.0140, subpart 15.
Your Response. First, you stated, “Transition 1 and Transition 2 have never been opened or occupied by children. We maintain ample supplies, including tissues, near all classrooms, and have replenished them as needed. These classrooms were previously approved with required equipment accessible.” Second, you stated that you “offered to show available tissue supplies to the licensor, but this offer was declined.” You also stated that not having facial tissue in the Transition 2 Classroom and Transition 1 Classroom amounted to “minor concerns,” has been resolved on site during past visits, and is unrelated to child safety. Finally, you requested “clarification on why this citation could not have been resolved by placing additional tissues in the unopened classrooms.”
Reconsideration Determination. The program has Transition 1, Transition 2, Toddler 2, and Pre-K classrooms licensed for child care. The program must ensure that the four licensed spaces have the required supplies including facial tissues and that the facial tissues are accessible to children. Transition 1 and Transition 2 classrooms lacked the necessary facial tissues. The licensor noted that there were no extra facial tissues in the cupboards of Transition 1 and Transition 2 class rooms. Citation 3 is affirmed.
Citation 4 Violation. Equipment and furniture were not in good repair. A play faucet was not securely attached to the dramatic play kitchen. (Summer Camp Classroom: School Age classroom)
A dramatic play kitchen was missing the faucet and sprayer attachments. Another dramatic play kitchen was missing a basin. (Young Preschool Classroom: Preschool classroom)
Applicable Law. The license holder must ensure that equipment and furniture must be durable, in good repair, structurally sound and stable following assembly and installation. Equipment must be free of sharp edges, dangerous protrusions, points where a child's extremities could be pinched or crushed, and openings or angles that could trap part of a child's body. Minnesota Rules, part 9503.0140, subpart 19.
Your Response. You stated, “[t]he faucet and basin on the play kitchens are designed to be removable to encourage imaginative play. They passed previous inspections.”
You also requested “guidance on whether licensing prefers these parts to be permanently secured to avoid future citations.”
Reconsideration Determination. First, the faucet in one dramatic play kitchen in the school age room was not in good repair. The faucet was detached and disassembled from the sink leading to an open hole. A child could get their fingers stuck in the hole.
Second, another dramatic play kitchen in the young preschool room was missing the faucet, sprayer and basin. While you stated that faucet, sprayer and basin on the play kitchens are designed to be removable to encourage imaginative play, these missing items were not present in the respective rooms during the licensing review.
The program did not ensure that the equipment was in good repair and functional for its intended use, therefore Citation 4 is affirmed.
Citation 5 Violation. The DCYF licensor observed that hazardous objects were accessible to children.
There were sharp metal plates placed on the ledge by playground door, accessible to children (Toddler 2 Classroom)
A vent cover near the big blocks, was not secured and posed a tripping hazard. (Summer Camp Classroom: School Age classroom)
Applicable Law. Child care centers must develop a risk reduction plan that minimizes that prohibit the accessibility of hazardous items to children. Minnesota Statutes, section 142B.54, subdivision 2, paragraph (e).
The license holder must ensure that sharp objects must be stored out of reach of children. Minnesota Rules, part 9503.0140, subpart 17.
Your Response. First, you stated, “[t]he “metal plates” are rounded outdoor garbage lids that pose no sharp edges. They were promptly replaced on the bins.”
Second, you stated, “[t]he vent sits adjacent to a wall and shelf with no space to walk between, thus no realistic tripping hazard exists.”
Finally, you seek guidance on how “subjective interpretation of hazards, especially when the physical environment makes the risk unlikely” are evaluated.
Reconsideration Determination. The licensor observed metal plates with sharp edges on a low standing ledge near the playground door, accessible to children. The metal plates with sharp edges are a hazard, and the children may get cut from the sharp edges. The program must ensure that all hazardous items including the metal plates are inaccessible to children. Citation 5 is affirmed as to the metal plates.
The licensor observed a vent in the middle of the Summer Camp, school age room that was raised and not flush with the carpet. The vent located near the big blocks section was partially covered by a toy shelf, however, three-quarters of the vent was in an open area accessible to children. In fact, one of the licensors tripped on the protruding vent. The protruding vent was a tripping hazard to that licensor.
The licensor tried to push the vent down into the carpet so that the vent was not protruding out from the carpet but was not able to push the vent flush into the carpet. Citation 6 is affirmed as to the vent.
Citation 6 Violation. Areas used by the children were not in good repair. The wall near the lower cabinets had peeling paint. (Infant 2 Classroom: Infant classroom)
Applicable Law. The license holder must ensure that areas used by children must be free from debris, loose flaking, peeling, or chipped paint, loose wallpaper, or crumbling plaster, litter, and holes in the walls, floors, and ceilings. Minnesota Rules, part 9503.0140, subpart 20.
Your Response. You stated, “[t]he scratches were caused by contact with garbage bins.” The garbage bins have been moved to another location, and the program scheduled repairs for a week from the unannounced site visit.
Reconsideration Determination. The licensor observed that the walls near the lower cabinets, accessible to children, had peeling paint. The program must ensure that the areas accessible to children is free from peeling paint. Citation 6 is affirmed.
Citation 7 Violation. Outside doors and windows used for ventilation were not screened. There was one screen that had one hole and one tear. (Toddler 2 Classroom: Toddler classroom)
Applicable Law. The license holder must ensure that outside doors and windows used for ventilation must be screened to provide protection from insects. Minnesota Rules, part 9503.0155, subpart 17.
Your Response. You stated, “[t]he windows are kept closed and the screen in question is in a classroom that is not in use. During past visits we were instructed that since the windows are not open, the screens are sufficient.” You stated the screen have been repaired.
Reconsideration Determination. The licensor observed one hole and one tear in the window screen in the Toddler 2 class room. The Toddler 2 classroom is part of the licensed space, and subject to licensing regulations. The program must ensure that the windows used for ventilation have screens intact to provide protection from insects. There was one hole and one tear the window screen that did not protect against insects. Therefore Citation 7 is affirmed.
Disposition
The Commissioner has reviewed the relevant laws and all the information you submitted in response to the Correction Order. Citations 1 through 8 are affirmed. This is a final agency decision.
If you have specific questions regarding ongoing compliance with licensing regulations, please contact your licensor.
Previously Ordered Corrective Action. In the original Correction Order, you were ordered to correct the violation(s) cited, and submit documentation of such action to your licensor. A request for reconsideration does not stay any provisions or requirements of the correction order. Minnesota Statutes, 142B.16, subdivision 2, paragraph (a). If you have not done so already, please immediately comply with the previously ordered corrective actions for all uncontested and affirmed violations.
The Commissioner appreciates your response and encourages you to continue to work cooperatively with your licensor to ensure the safety and well-being of the children you serve.
Sincerely,

Hlee Vang, Attorney Legal Counsel’s Office Office of Inspector General
PO Box 64242 • Saint Paul, Minnesota • 55164-0242 • An Equal Opportunity and Veteran Friendly Employer https://mn.gov/dhs/general-public/licensing/
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