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September 22, 2026 Zachary Schubert, Authorized Agent True Light Christian School PO Box 751 601 E College Dr Marshall, MN 56258 License Number: 1057030 (Child Care Center) Program Location: 601 E College Dr, Marshall, MN 56258 Dear Zachary Schubert: On November 7, 2025, the Minnesota Department of Human Services (DHS), Division of Licensing, received your request for reconsideration regarding Citations 6, 7, and 9 in the Correction Order issued to you on November 4, 2025. You did not request reconsideration of any other citations; therefore, they are not under review. Reconsideration Determination Citation 6: The program did not comply with cardiopulmonary resuscitation (CPR) training requirements. Documentation was not available on site to show that 1 of 3 (SP4) individuals (director, staff persons, substitutes, or unsupervised volunteers) had satisfactorily completed the required pediatric CPR training including the treatment of obstructed airways and a hands-on skill assessment before unsupervised contact with a child (SP4). Your Request for Reconsideration. You stated, “Staff person completed required training prior to first date of contact. Documentation for this date was incorrect. First date of contact was 11-25-24 but documentation originally said 10-25-24. CPR training was completed 11-21-24 Documentation has been now corrected.” Applicable Law. The director, staff persons, substitutes, and unsupervised volunteers must satisfactorily complete pediatric first cardiopulmonary resuscitation (CPR) prior to having unsupervised direct contact with a child, but not to exceed the first 90 days of employment. Pediatric CPR training must be repeated at least every second calendar year. Pediatric CPR under this subdivision must be provided by an individual approved as a pediatric CPR instructor and must not be used to meet in-service training requirements under subdivision 9. Minnesota Statutes, section 142B.65, subdivision 5 The license holder must ensure that a personnel record for each staff person is maintained at the center. The personnel record for each staff person must contain documentation, when applicable, that the staff person has completed the first aid and CPR training required in part 9503.0035 , subparts 2 and 3. Minnesota Rules, part 9503.0120, subpart D. The commissioner must be given access to documents and records, including records maintained in electronic format without prior notice and as often as the commissioner considers necessary if the commissioner is investigating alleged maltreatment, conducting a licensing inspection, or investigating an alleged violation of applicable laws or rules. Minnesota Statutes, section 142B.10, subdivision 12 (emphasis added). Reconsideration Determination. The Licensor noted that SP4’s Personnel Information Form (PIF) listed first unsupervised contact with children was October 25, 2024, and SP4 completed Heartsaver Pediatric First Aid CPR AED training on November 21, 2024, after SP4’s first unsupervised contact with children. The director, staff persons, substitutes, and unsupervised volunteers must satisfactorily complete pediatric first cardiopulmonary resuscitation (CPR) prior to having unsupervised direct contact with a child, but not to exceed the first 90 days of employment. Pediatric CPR training must be repeated at least every second calendar year. You stated that SP4’s listed first unsupervised contact date on his/her PIF of October 25, 2024, was incorrect. You stated that the documentation has been corrected. However the documentation that was available to the Licensor during the site visit indicated that SP4’s first unsupervised contact with children was October 25, 2024, not (emphasis added) November 25, 2024. SP4’s documentation indicated that SP4 had unsupervised contact with children on October 25, 2024, before SP4 completed Heartsaver Pediatric First Aid CPR AED training on November 21, 2024, therefore Citation 6 is affirmed. Citation 7: The program did not comply with first aid training requirements. Documentation was not available on site to show that 1 of 3 (SP4) individuals (director, staff persons, substitutes, or unsupervised volunteers) completed pediatric first aid training before unsupervised direct contact with a child (SP4). Your Request for Reconsideration. You stated, “Staff person completed required training prior to first date of contact. Documentation for this date was incorrect. First date of contact was 11-25-24 but documentation originally said 10-25-24. CPR training was completed 11-21-24 Documentation has been now corrected.” Applicable Law. The director, staff persons, substitutes, and unsupervised volunteers must satisfactorily complete pediatric first aid prior to having unsupervised direct contact with a child, but not to exceed the first 90 days of employment. Pediatric first aid training must be repeated at least every second calendar year. Pediatric first aid training under this subdivision must be provided by an individual approved as a first aid instructor and must not be used to meet in-service training requirements under subdivision 9. Minnesota Statutes, section 142B.65, subdivision 4. The license holder must ensure that a personnel record for each staff person is maintained at the center. The personnel record for each staff person must contain documentation, when applicable, that the staff person has completed the first aid and CPR training required in part 9503.0035 , subparts 2 and 3. Minnesota Rules, part 9503.0120, subpart D. Reconsideration Determination. The Licensor noted that SP4’s Personnel Information Form (PIF) listed first unsupervised contact with children was October 25, 2024, and SP4 completed Heartsaver Pediatric First Aid CPR AED training on November 21, 2024, after SP4’s first unsupervised contact with children. The director, staff persons, substitutes, and unsupervised volunteers must satisfactorily complete pediatric first prior to having unsupervised direct contact with a child, but not to exceed the first 90 days of employment. Pediatric CPR training must be repeated at least every second calendar year. You stated that SP4’s listed first unsupervised contact date on his/her PIF of October 25, 2024, was incorrect. You stated that the documentation has been corrected. However the documentation that was available to the Licensor during the site visit indicated that SP4’s first unsupervised contact with children was October 25, 2024, not (emphasis added) November 25, 2024. SP4’s documentation indicated that SP4 had unsupervised contact with children on October 25, 2024, before SP4 completed Heartsaver Pediatric First Aid CPR AED training on November 21, 2024, therefore Citation 7 is affirmed. Citation 9: 1 of 3 (C3) children's files reviewed did not contain a current immunization record, a signed notarized statement of parental objection to the immunization, or a medical exemption. Your Request for Reconsideration. You stated, “Child’s immunization record was on file. The DCYF licensor failed to see the proper documentation. I have included them on page 2-3. Please note top left proves they were printed and on file 8-19-25.” Applicable Law. At the time of enrollment in the center, the license holder must ensure that a record is maintained on each child. The record must contain the health form and immunization information required by part 9503.0140. Minnesota Rules, part 9503.0125, item G. When a child is enrolled in the center, the license holder must obtain documentation of current immunization according to Minnesota Statutes, section 121A.15, a signed notarized statement of parental objection to the immunization, or a medical exemption. Minnesota Rules, part 9503.0140, subpart 5. Reconsideration Determination. The Licensor noted that Child’s, C3’s, files did not contain a current immunization record, a signed notarized statement of parental objection to the immunization, or a medical exemption. At the time of enrollment in the center, the license holder must ensure that a record is maintained on each child. The record must contain the health form, immunization information, and documentation of current immunization of a signed notarized statement of parental objection to the immunization, or a medical exemption. During the site visit, the director was in ratio, therefore the Licensor gave the director an opportunity after the exit interview to locate the missing documents. After the exit interview, the Licensor gave the director 15 minutes to locate, and provide C3’s current immunization record, a signed notarized statement of parental objection to the immunization, or a medical exemption to the Licensor. The Licensor did not receive C3’s missing documentation. C3’s file was missing C3’s health form, immunization information, and documentation of current immunization of a signed notarized statement of parental objection to the immunization, or a medical exemption. Therefore, Citation 9 is affirmed. Disposition The Commissioner has reviewed the relevant laws and all the information you submitted in response to the Correction Order. Citations 6, 7, and 9 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
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