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July 1, 2026
Molly O'Shaughnessy, Authorized Agent Cornerstone Montessori School 1611 Ames Ave
Saint Paul, MN 55106
License Number: 1051310 (Child Care Center) Program Location: 1611 Ames Ave, Saint Paul, MN 55106-2903
Dear Molly O'Shaughnessy:
On October 9, 2025, the Minnesota Department of Human Services (DHS), Division of Licensing, received your request for reconsideration regarding Citations 2, 5, 7, and 8 through 11 in the Correction Order issued to you on September 24, 2025. You did not request reconsideration of any other citations; therefor, they are not under review.
Reconsideration Determination
Citation 2: Products to control diaper rash were not labeled with the child's first and last name. There was one container of diaper wipes in the Toddler Community that was not labeled with first and last name. There was one container of diaper wipes in the Children's House 2 classroom that was not labeled with first and last name. (Toddler Community Classroom: Toddler classroom and Children House Classroom: Children House 2)
Your Request for Reconsideration. You stated that the unlabeled wipes are communal wipes for staff to use for all children. You asserted that staff were gloves when taking wipes out to prevent cross-contamination. Finally, you stated that the applicable rules do not require that communal wipes need to be labeled.
Applicable Law. A product to control or prevent diaper rash, including premoistened commercial wipes that cannot be dispensed in a manner that prevents cross contamination of the product and container as determined by the health consultant, must be labeled with the child's name and used only for the individual child whose name is written on the label. Minnesota Rules, part 9503.0140, subpart 7, item D.
Reconsideration Determination. The Licensor observed a package of diaper wipes that were not labeled in the Toddler Classroom and a package of diaper wipes that were not labeled in Children House 2 Classroom. You stated that staff used the unlabeled diaper wipes for all children, and that the wipes were communal. Wipes must be labeled with the child's name and used only for the individual child whose name is written on the label. If you have wipes for communal use, then you must label the wipes as the center’s wipes. Citation 2 is affirmed.
Citation 5: Areas used by the children were not in good repair. The door handle in the Children's House 2 classroom, exiting towards the playground, was missing. The laminate on the peninsula sink, in the Children's House 2 classroom, was not securely attached to the surface. (Children's House 2 Classroom: Preschool/SA classroom)
Your Request for Reconsideration. You stated that the door handle had been removed that afternoon for repair because a child put a wood chip in the lock. You did not request consideration of the laminate on the peninsula sink was not securely attached not the surface.
Applicable Law. The areas used by children must be in good repair. Minnesota Rules, part 9503.0140, subpart 20.
Reconsideration Determination. The Licensor observed a missing door handle and laminate on the peninsula sink was not securely attached in the Children’s House 2 classroom. You stated that the door handle had been removed that afternoon for repair because a child put a wood chip in the lock. You did not dispute that the door handle was not in good repair. Citation 5 is affirmed regarding the door handle that was not in good repair.
You did dispute that the laminate on the peninsula sink, in the Children's House 2 classroom, was not securely attached to the surface. Citation 5 is affirmed regarding the laminate on the peninsula sink that was not in good repair.
Citation 7: Electrical outlets were not tamper-proof or shielded.
An electrical outlet was not shielded in the Children House 1 classroom. (Children's House 1 Classroom: Preschool/SA classroom)
Your Request for Reconsideration. You stated that, “A shield was visible on the shelf next to the outlet. All outlets have guards – when we see an outlet is unguarded, we replace the shield.”
Applicable Law. Except in a center that serves only school-age children, electrical outlets must be tamper proof or shielded when not in use. Minnesota Rules, part 9503.0155, subpart 11.
Reconsideration Determination. The Licensor observed an electrical outlet was not shielded in the Children House 1 classroom. You stated that, “A shield was visible on the shelf next to the outlet. All outlets have guards – when we see an outlet is unguarded, we replace the shield.” You did not dispute that the outlet was unshielded, but instead agreed that the outlet was unshielded, and the shield was on a shelf next to the outlet. You must ensure that electrical outlets must be tamper proof or shielded when not in use. Citation 7 is affirmed.
Citation 8: Documentation was not available on site to verify that before starting assigned duties 2 of 2 (SP4 and SP6) individuals (director, staff persons, substitutes, or unsupervised volunteers) received orientation training on:
· the risk of abusive head trauma that was at least one half hour in length as required in Minnesota Statutes, section 142B.65, subdivision 7 (SP4 and SP6);
· allergy prevention and response as required by Minnesota Statutes, 142B.66, subdivision 1 (SP4);
· behavior guidance policy standards in Minnesota Rules, part 9503.0055 (SP4 and SP6);
· the child care program plan and center's philosophy (SP4 and SP6);
· emergency preparedness as required by Minnesota Statutes, 142B.66, subdivision 3. (SP4 and SP6);
· handling emergencies and accidents according to Minnesota rules, part 9503.0110 (SP4 and SP6);
· procedures for maintaining health and safety according to Minnesota Rules, part 9503.0140 (SP4);
· a child's individual child care program plan as required under Minnesota Rules, part 9503.0065, subpart 3 (SP4 and SP6);
· specific job responsibilities (SP4 and SP6);
· program's drug and alcohol policy under section 142B.10, subdivision 1, paragraph (c) (SP4 and SP6); and
· program's risk reduction plan as required under section 142B.54, subdivision 2 (SP4 and SP6).
Your Request for Reconsideration. You stated that all staff received required training before working with children. The director did not have time between the September 2-training and the September 4-DCYF visit to complete orientation/training records for all staff, and have them signed.
Applicable Law. The license holder shall provide training to program staff related to their duties in implementing the program's policies and procedures. Minnesota Statutes, section 142B.10, subdivision 21, paragraph (b), clause (1).
The child care center license holder must ensure that the director, staff persons, substitutes, and unsupervised volunteers are given orientation training and successfully complete the training before starting assigned duties. The orientation training must include information about: (1) the center's philosophy, child care program, and procedures for maintaining health and safety according to section 142B.66 and Minnesota Rules, part 9503.0140, and handling emergencies and accidents according to Minnesota Rules, part 9503.0110; (2) specific job responsibilities; (3) the behavior guidance standards in Minnesota Rules, part 9503.0055; (4) the reporting responsibilities in chapter 260E and Minnesota Rules, part 9503.0130; (5) the center's drug and alcohol policy under section 142B.10, subdivision 1, paragraph (c); (6) the center's risk reduction plan as required under section 142B.54, subdivision 2; (7) at least one-half hour of training on the standards under section 142B.46 and on reducing the risk of sudden unexpected infant death as required in subdivision 6, if applicable; (8) at least one-half hour of training on the risk of abusive head trauma as required for the director and staff under subdivision 7, if applicable; and (9) training required by a child's individual child care program plan as required under Minnesota Rules, part 9503.0065, subpart 3, if applicable. (b) In addition to paragraph (a), before having unsupervised direct contact with a child, the director and staff persons within the first 90 days of employment, and substitutes and unsupervised volunteers within 90 days after the first date of direct contact with a child, must complete: (1) pediatric first aid, in accordance with subdivision 4; and (2) pediatric cardiopulmonary resuscitation, in accordance with subdivision 5. (c) In addition to paragraph (b), the director and staff persons within the first 90 days of employment, and substitutes and unsupervised volunteers within 90 days from the first date of direct contact with a child, must complete training in child development, in accordance with subdivision 3. (d) The license holder must ensure that documentation, as required in subdivision 10, identifies the number of hours completed for each topic with a minimum training time identified, if applicable, and that all required content is included. (e) Training in this subdivision must not be used to meet in-service training requirements in subdivision 9. (f) Training completed within the previous 12 months under paragraphs (a), clauses (7) and (8), and (c) are transferable to another child care center. Minnesota Statutes, section 142B.65, subdivision 1. Reconsideration Determination. The Licensor noted that you did not have the required documentation to show that SP4 and SP6 completed the required training before starting their assigned duties. You admitted that the director did not have time between the September 2-training and the September 4-DCYF visit to complete orientation/training records for all staff, and have them signed. Citation 8 is affirmed because you did not have the required documentation to show that SP4 and SP6 completed the required training before starting their assigned duties. Citation 9: The required in-service training had not been completed for 1 of 4 (SP5) individuals (director, staff persons, substitutes, or unsupervised volunteers) for the previous concluded calendar year. In-service training did not include: · the required number of in-service training hours for the previous concluded calendar year (SP5);
· training on abusive head trauma that was at least one half hour in length as required by Minnesota Statutes, section 142B.65, subdivision 7 (SP5);
· training on allergy prevention and response as required by Minnesota Statutes, section 142B.66, subdivision 1 (SP5);
· training on emergency preparedness as required by Minnesota Statutes, section 142B.66, subdivision 3 (SP5);
· training on handling and disposal of bodily fluids as required by Minnesota Statutes, section 142B.66, subdivision 2 (SP5);
· training on handling emergencies and accidents as required by Minnesota Rules, part 9503.0110, subpart 1 (SP5);
· training on health policies as required by Minnesota Rules, part 9503.0140, subpart 1 (SP5);
· training on reporting responsibilities as required by Minnesota Statutes, chapter 260E and Minnesota Rules, part 9503.0130 (SP5);
· training on the risk reduction plan as required by Minnesota Statutes, section 142B.54, subdivision 2 (SP5);
· training on individual child care program plan as required by Minnesota Rules, part 9503.0065, subpart 3 (SP5);
· training on sudden unexpected infant death that was at least one half hour in length as required by Minnesota Statutes, section 142B.65, subdivision 6 (SP5);
· training on cultural dynamics every two years as required by Minnesota Statutes, section 142B.65, subdivision 9, paragraph (f), clause (4) (SP5); and
· training on disabilities every two years as required by Minnesota Statutes, section 142B.65, subdivision 9, paragraph (f), clause (5) (SP5).
Your Request for Reconsideration. You stated that all staff received required training before working with children. The director did not have time between the September 2-training and the September 4-DCYF visit to complete orientation/training records for all staff, and have them signed.
Applicable Law. A license holder must ensure that the center director, staff persons, substitutes, and unsupervised volunteers complete in-service training each calendar year. Minnesota Statutes, section 142B.65, subdivision 9.
Reconsideration Determination. The Licensor noted that you did not have the required documentation to show that SP5 completed the required in-service training before starting his/her assigned duties. You admitted that the director did not have time between the September 2-training and the September 4-DCYF visit to complete orientation/training records for all staff, and have them signed. Citation 9 is affirmed because you did not have the required documentation to show that SP5 completed the required in-service training before starting his/her assigned duties.
Citation 10: The program did not comply with abusive head trauma training requirements. The training on abusive head trauma for 3 of 6 (SP4, SP5 and SP6) individuals (director, staff persons, substitutes, or unsupervised volunteers) was not completed before caring for children under school age.
Your Request for Reconsideration. You stated that all staff received required training before working with children. The director did not have time between the September 2-training and the September 4-DCYF visit to complete orientation/training records for all staff, and have them signed.
Applicable Law. Before caring for children under school age, the director, staff persons, substitutes, and unsupervised volunteers must receive training on the risk of abusive head trauma during orientation and each calendar year thereafter. Minnesota Statutes, section 142B.65, subdivision 7, paragraph (a).
Reconsideration Determination. The Licensor noted that you did not have the required documentation to show that SP4, SP5 and SP6 completed the required abusive head trauma training before starting their assigned duties. You admitted that the director did not have time between the September 2-training and the September 4-DCYF visit to complete orientation/training records for all staff, and have them signed. Citation 10 is affirmed because you did not have the required documentation to show that SP4, SP5 and SP6 completed the required abusive head trauma training before starting their assigned duties.
Citation 11: The program did not comply with child development and learning training requirements. Documentation was not available on site to show that 2 of 4 (SP5 and SP7) individuals (director, staff persons, substitutes, or unsupervised volunteers): · completed training that was at least two hours in length (SP5 and SP7); and
· completed training at least every second calendar year (SP5).
Your Request for Reconsideration. You stated that all staff received required training before working with children. The director did not have time between the September 2-training and the September 4-DCYF visit to complete orientation/training records for all staff, and have them signed.
Applicable Law. Before caring for children under school age, the director, staff persons, substitutes, and unsupervised volunteers must receive training on the risk of abusive head trauma during orientation and each calendar year thereafter. Minnesota Statutes, section 142B.65, subdivision 3
Reconsideration Determination. The Licensor noted that you did not have the required documentation to show that SP5 and SP7 completed the required child development and learning training requirements. You admitted that the director did not have time between the September 2-training and the September 4-DCYF visit to complete orientation/training records for all staff, and have them signed. Citation 11 is affirmed because you did not have the required documentation to show that SP5 and SP7 completed the required child development and learning training requirements.
Disposition
The Commissioner has reviewed the relevant laws and all of the information you submitted in response to the Correction Order. Citations 2, 5, 7, and 8 through 11 are affirmed. This is a final agency decision.
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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