UnitingCare children’s cervices submission to the 2014 Review of …€¦ · Executive Summary 2 The degree to which the agreed objectives and outcomes of the NP NQA have been achieved

UnitingCare Children’s Services Submission to the 2014 Review of the National Partnership Agreement on the National Quality Agenda for Early Childhood Education and Care

Nurturing confident and creative learners

We would like to thank UnitingCare Children Services staff who participated in consultations, responded to the UCCS staff survey and made other contributions as part of the preparation of this submission.

© 2014 UnitingCare Children’s Services

Submission prepared June 2014

Prepared by: Liz Barrett, Principal Policy Officer, Social Justice Unit, UnitingCare Children, Young People and Families With input from: Gabby Holden, Practice Manager Policy and Quality, UnitingCare Children’s Services

Contact Person: Trish Brown, Director UnitingCare Children’s Services PO Box 7137 Silverwater NSW 2128 Phone (02) 9768 6931 or 0418 589 125 Fax: (02) 9630 6043 Email: [email protected] Website: www.unitingcarechildrensservices.org.au

ii 2014 Review of the NQA on ECEC

UnitingCare Children Services – June 2014

C O N T E N T S

About UnitingCare Children’s Services 1

Executive Summary 2

The degree to which the agreed objectives and outcomes of the NP NQA have been achieved 6

Quality outcomes for children must remain front and centre of the Australian ECEC sector 6

Staff qualifications, ratios and groups sizes the building blocks of a quality system 7

UCCS impact and experience of implementing the NQF: How holistic reform has produced better educational and development outcomes for children 8

Efficiencies and costs: Significant sector investment should be protected 11

National Quality Standards, national regulations and the assessment and ratings process: Supporting quality outcomes and continuous improvement 12

Governance arrangements, national regulation, legislative requirements and funding 18

Effectiveness of governance arrangements for NQF including role, structure and effectiveness of ACECQA 18

Efficiency and Effectiveness of the Regulatory Authority 18

Feedback on the scope of services covered by the NQF 19

Application of the NQF to OSHC 20

Future arrangements for funding the NQA 20

Bibliography 22

1 2014 Review of the NQA on ECEC


About UnitingCare Children’s Services

UnitingCare Children’s Services (UCCS) is the third largest provider of children’s services in NSW, with 58 services in NSW and the ACT. We provide quality education and care to over 6,500 children and families each year. UCCS services include long day care, preschool, outside school hours care, occasional care and integrated child and family centres.

Our purpose is to provide an educative environment that nurtures resilient and confident children through inclusive services in partnership with families and community. UCCS aims to nurture the confidence and development of children, enabling them to have the best start in their critical formative years. We value and advocate for positive early childhood education and care experiences that lead to opportunities throughout life for all children.

UCCS is part of UnitingCare Children, Young People and Families, a service group of UnitingCare NSW.ACT. The Service Group is comprised of UnitingCare Burnside, UnitingCare Unifam Counselling and Mediation, UnitingCare Disability, UCCS and the Institute of Family Practice, a registered training organisation.

Together these organisations form one of the largest providers of services to support children and families in NSW. We represent over 100 years of experience providing innovative and quality programs and advocacy to break the cycle of disadvantage that affects vulnerable children, young people and families. UnitingCare CYPF provides services across the continuum, ranging from preventative programs such as supported playgroups; early intervention programs such as Brighter Futures; intensive family support programs; out-of-home care programs and aftercare programs.

UCCS is a part of the UnitingCare Australia network, which brings together a broad range of services supporting children, young people and families across Australia. Through UnitingCare Australia networks we contribute to national policy debates on key issues that impact on children including early childhood education and care. UnitingCare provides early childhood services in every state and territory including 30 per cent delivered in regional and remote parts of Australia. UnitingCare also provides a range of other services for vulnerable children, young people and families which interface with our early childhood work.



Executive Summary

UnitingCare Children’s Services (UCCS) welcomes the opportunity to contribute to the review of the National Partnership Agreement on the National Quality Agenda for Early Childhood Education and Care (the NQA).

Together UCCS and UnitingCare Children, Young People and Families have a long history of advocating on the importance of early childhood education and care (ECEC) to support children’s development and wellbeing. We have provided detailed feedback and submissions to studies and inquiries concerning the ECEC sector in Australia, including the following current reviews:

• Productivity Commission inquiry on childcare and early childhood learning

• Senate Education and Employment inquiry in to the immediate future of the childcare sector in Australia

• Senate Education and Employment inquiry into the delivery of quality and affordable early childhood education and care services.

UCCS provides 58 ECEC services in NSW, 56 of which are in-scope of the National Quality Framework (NQF) and include Long Day Care (LDC), preschools and Outside School Hours Care (OSHC) and Occasional Care. So far 27 of our services have been assessed and rated, with over 85 per cent receiving an exceeding or meeting rating.

In order to inform our response to this latest review, UCCS has conducted a survey and consultations with our network of services. Many of the responses are from services who have already undergone the assessment and rating processand provide valuable insights into the process.

There is overwhelming support across our network of services for the reforms undertaken as part of the NQA, with the NQF and the National Quality Standard (NQS) seen as vital elements of a quality system. UCCS strongly supports the continuing and full implementation of the NQF and NQS. We oppose any potential changes to the system that would impact upon quality or outcomes for children.



The NQA forms the cornerstone of comprehensive reform of the ECEC sector in Australia that has been implemented over a number of years. The guiding vision of this reform process was outlined in the document Investing in the Early Years:

“To ensure that by 2020 all children have the best start in life to create a better future for themselves and the nation”.

While we welcome the opportunity to provide feedback on system efficiencies, UCCS firmly believes that this vision should continue to be the central consideration for the ECEC sector and any review of it.

UCCS also welcomes the opportunity to provide comment on our experience of the impact on quality and outcomes of implementing the NQF and NQS. We note that the original reform process was informed by a robust evidence-base including international consensus on the drivers of quality outcomes for children. This evidence has not changed and must continue to be drawn on in order to construct the best possible outcomes for Australian children.

This review provides a further opportunity to build on the broad consensus amongst researchers and practitioners that quality ECEC delivers significant positive benefits for children and society. This includes increases in children’s outcomes across the social, emotional, physical and cognitive domains, higher long-term productivity, and savings created by avoiding more costly down-stream interventions and services.

After significant investment from the Commonwealth Government and early childhood services, the Australian ECEC sector is well on the way to fully implementing the NQF and NQS. Australian children are already starting to see the benefit of an improved and nationally consistent system with increases in educational results. We would be reluctant to see any changes to the current system that would render these investments and gains redundant.

However, there are significant adjustments to administrative processes that could be made to help the system function more effectively. In particular the assessment and ratings process has the potential to be amended to make ratings clearer for families, and the process function more efficiently for services.



In responding to the review, UCCS has tried to respond to each of the headline questions suggested by the discussion paper. Our feedback and recommendations to the review for each of these headings is as follows:

The degree to which the agreed objectives and outcomes of the NQA have been achieved

• Children need to remain front and centre of the ECEC sector • UCCS opposes any potential changes to the current system that

impact upon quality provision • Implementation of ratios and teacher qualifications (for services over 30

children) have matched NSW regulations so provided little challenge to services in NSW

• Timeframes for future ratio implementation have been more than adequate

• Regulations around access to Early Childhood Teachers (ECTs) for smaller services should be reviewed in order to increase equity of service quality

• UCCS recommends reassessing funding mechanisms in order to determine how to best support full-time ECTs in smaller services

• The qualifications framework is a major strength of the system, increasing skills, mentoring and professionalisation

• Commonwealth funding for professional development is welcome but should be available for all services under the NQF

• UCCS supports an assessment of the current funding mechanism in order to support professional wages for staff

• Given the level of sector investment in implementing ECEC reforms, there is no cost benefit or efficiencies to be derived from reducing standards.

National Quality Standards, national regulations and the assessment and ratings process: Supporting quality outcomes and continuous improvement

• No part of the NQS can be removed or amended without compromising the overall quality of the system

• Quality Improvement Plans (QIPs) are an excellent tool for fostering quality improvement in services



• There needs to be greater understanding between, and clarification of, national regulations, laws and concepts of administrative burden

• The Early Years Learning Framework (EYLF) is a useful tool for supporting services to develop and implement learning programs

• New assessment and ratings systems are a significant improvement on the previous processes

• Consistency of assessments could be improved through consultation and collaboration with Regulatory Authorities and regional jurisdications

• UCCS recommends that authorised officers hold an ECEC qualification and have experience specific to the service type they are assessing

• The ratings system could be refined to provide greater clarity to services and families through a service’s quality profile.

Governance arrangements, national regulation, legislative requirements and funding

• UCCS experience of the Australian Children’s Education and Care Quality Authority (ACECQA) has been positive especially in relation to their consultative approach and materials produced

• UCCS recommend the temporary waiver process be amended to allow for time extensions where the authorities seek additional information from services

• UCCS recommends bringing all regulated ECEC services inscope of the NQF with allowances made for service variations

• Current legislative requirements tailored to OSHC services under the NQF are sufficient

• OSHC services would benefit from having access to a qualified staff member to assist in guiding educational programs

• Funding for implementation of the NQA must continue to support quality reforms.



The degree to which the agreed objectives and outcomes of the NP NQA have been achieved

Quality outcomes for children must remain front and centre of the Australian ECEC sector

The National Quality Agenda for Early Childhood Education and Care (the NQA) contains a number of important initiatives for national reform of the ECEC sector. This includes the NQS, NQF, a new national regulatory system and new national body. The NQA is one of a number of historic agreements between State and Territory Governments that put quality outcomes for children at the centre of the ECEC system. As stated in the document Investing in the Early Years – A National Early Childhood Development Strategy (the Early Years Strategy), the vision driving these reforms is:

“To ensure that by 2020 all children have the best start in life to create a better future for themselves and the nation”. (Commonwealth Government, 2009:4)

The elements and key vision of the Early Years Strategy were adopted into the creation of the NQS and form a holistic functioning quality agenda. The NQS, NQF and other reforms under the NQA were informed by a strong evidence-base and lengthy consultations with the sector. Many of the reforms mirror initiatives that the sector had been advocating on for many years. Sector support for the reforms continues to be high with a 2013 report by ACECQA finding 92 per cent of the sector in favour of the NQF.

UCCS welcomes this review of the NQA, and the concurrent Productivity Commission inquiry into ECEC services, as an opportunity to evaluate and improve on the current system. However, UCCS believes that the original vision of the Strategy should remain central to the purpose of the ECEC system in Australia. The primary concern of the review should be on quality outcomes for children. Quite simply, children need to remain front and centre of the ECEC sector and of any considerations of evaluation or improvements to it.



UCCS notes with some disappointment, that the terms of reference for the Review does not include consideration of some of the original objectives and principles of the NQA. This includes b) to “improve educational and developmental outcomes for children attended ECEC and Outside School Hours Care (OSHC) services under the NQF” and g) “to build a highly skilled workforce”. While UCCS supports an efficient and cost-effective sector, these considerations should not take primacy over children’s needs and outcomes.

Staff qualifications, ratios and groups sizes the building blocks of a quality system

UCCS strongly supports the NQF as a system that produces positive outcomes for children and promotes quality in the sector.1 We recommend that implementation of the NQF continues in full. We see no benefit in, and strongly oppose, any potential changes to the current system that impact upon quality provision.

There has been international consensus on the structural drivers of quality outcomes in an early childhood setting for many years, namely: staff-to-child ratios, staff qualifications and group sizes (Snow & Van Hemmel, 2008). These elements and the evidence base behind them have all been integrated into the Framework, NQS and the EYLF and consistently reiterated by Government research (AIHW, 2012:6).

The provision of quality ECEC is universally recognised as producing positive impacts across the lifespan for children including increased education results (National Scientific Council on the Developing Child, 2007:2), behavioural and social outcomes (Sammons et al, 2008), higher rates of employment and better health outcomes (Reynolds et al, 2007; Campbell et al, 2008). Access to quality ECEC is also one of the most effective ways to reduce social inequality, with children from vulnerable and disadvantaged backgrounds having most to gain from engagement with an ECEC program (Biddle, 2011).

Benefits from a quality ECEC sector flow on to benefit society and the economy as a whole, increasing productivity of the nation and being much

1 For a more comprehensive overview of the evidence-base of quality outcomes as influenced by ratios and qualifications, please see the UCCS Submission to the Productivity Commission Inquiry on Childcare and Early Childhood Learning <http://bit.ly/1jqg5GG>

http://bit.ly/1jqg5GG



cheaper than more costly interventions and services down-stream (Reynolds et al, 2007; Kershaw et al, 2010).

National Assessment Program Literacy and Numeracy (NAPLAN) results released in October 2013 are already showing the benefits of improvements to the Australian ECEC sector from the implementation of the NQF, with increased literacy and numeracy scores for Year 3 students directly linked to these changes (Coulihan, 2013). If Australia remains committed to the NQF, benefits of the early childhood reforms in Australia are expected to flow on to better primary and high school results.

Any attempts to reconstruct an ECEC sector that does not prioritise the critical elements of ratios and staff qualifications, risks undermining the progress made by the sector so far. It would not likely deliver the raft of possible positive outcomes for children, families and the nation as a whole.

UCCS impact and experience of implementing the NQF: How holistic reform has produced better educational and development outcomes for children

The current ratios and ECT staffing requirements under the NQF have presented little challenge to services in NSW, as State regulation matched the current implementation phase of the NQF. As such, UCCS has not found any implementation “burden” in this area. UCCS has operated above mandated ratios wherever possible as we know from experience, backed by overwhelming evidence (Howes & Carollee, nd; Howes, Smith & Galinsky, 1995; OECD, 2013) that where there are higher staff-to-child ratios, staff can:

• better form attachment relationships • interact more positively with children • provide more time to address individual needs; and • provide a greater level of care and development to children.

UCCS looks forward to the next phase of ratio implementation on 1 January 2016, where nationally the educator to child ratio for children aged 25 to 35 months will change from 1:8 to 1:5. By the next phase of ratio implementation, services in NSW would have had a number of years to prepare for these changes. We have found these timeframes to be more than adequate. We also believe this ratio is more appropriate for producing quality outcomes, is



backed by a strong evidence base and brings the Australian ECEC sector more into line with other OECD nations.

The presence of a qualified Early Childhood Teacher (ECT) has consistently been found to be critical in delivering the environment and programs necessary for high quality outcomes (Sylva et al, 2005). In our experience university qualified ECTs are also vital for guiding educational programs, mentoring staff and creating a greater skills base in services.

From 1 January 2014 new standards came into effect for services with less than 30 children, requiring an ECT to be accessible or in attendance at the service for between 20 to 60 per cent of operating hours. We understand the difficulty for smaller services, and rural and remote services in particular, in engaging full-time staff. However, UCCS believes that all children should have access to a full-time ECT irrespective of service size. UCCS recommend reviewing this area of the NQF. We also recommend reassessing funding mechanisms in order to determine how to best support a full-time ECT presence in smaller services.

The greatest change for services operating in NSW, commencing in 2014, was the introduction of the minimum mandatory requirement for at least 50 per cent of educators to hold a Diploma or higher qualification, and the remaining to hold a Certificate III. As a best-practice service provider, prior to the NQF, UCCS had already implemented a policy of employing qualified staff wherever possible. We have subsequently felt little impact from the changing qualifications framework and have rarely experienced any difficulty in attracting qualified educators. We believe this is a product of our commitment to staff which leads us to be an employer of choice.

As well as promoting quality outcomes for children, minimum mandatory qualifications in the system have assisted in the understanding and implementation of the NQS. This is because formal training in the Certificate III and above helps staff engage with the philosophy of child development, education and care that underpins the NQS. As outlined in the Early Years Workforce Strategy, all professional ECEC courses must embed pedagogy and understanding of implementation of the NQF and NQS (Standing Council of School Education and Early Childhood, 2012:9).

It is unfortunate that this review does not seek to measure objective g) of the NQA: to build a highly skilled workforce. UCCS believe that this has been



achieved in many areas of the country, and continues to be supported by implementation of the qualifications framework. Staff reported that the qualifications framework was a definite strength of the new system. The NQF has created clear career pathways and opportunities for skills progression and mentoring, increased the attractiveness of the profession of early childhood educators and increased credibility of the sector with families.

State and Commonwealth Governments have provided significant support during the transition period in order to assist services to meet new qualifications requirements under the NQF. This includes allowances for people working towards the qualification to be counted as qualified where they can demonstrate they are actively working towards it. This initiative has been complimented by government funding for Recognition of Prior Learning (RPL) that has assisted workers to achieve formal qualifications and has made the process readily achievable. Since 2011 ECEC workers have been able to access rebates of up to 75 per cent of costs associated with the RPL process, with higher levels of subsidisation available for workers in regional and remote areas since the beginning of 2013. The NSW government has also assisted with a range of subsidised training.2

The new $200 million Long Day Care Professional Development Program (LDCPDP) will continue to provide assistance for services to address professional development needs over the next four years. The objectives of the Program are to assist providers to better meet the NQS and deliver the EYLF, and to assist with any costs associated with upskilling. UCCS welcomes this initiative. We particularly note the funds targeted towards rural and remote services and for additional training and support for LDCeducators working with vulnerable and disadvantaged children. However, UCCS would like to see equal availability and support for professional learning across services covered by the NQF, not just in LDC.

As qualified staff form one of three foundations for quality outcomes for children, it is essential that experience and skills are retained in the sector. Lack of professional wages continues to undermine progress and investments

2 In NSW staff were also assisted to upskill through the NSW Government’s initiatives New Skills: Quality Care and the Early Childhood Education and Care Training Strategy that provided subsidised training for the Certificate III or Diploma in Children’s Services to staff working in an ECEC service at the time of the announcement of the NQF. Contributions to costs of traineeships for employers also assisted with NQF preparedness with assistance available from both the NSW Government and the Commonwealth.



made by government in implementing the NQF. High turn-over and skill atrophy have been consistent issues in the Australian ECEC sector particularly amongst ECTs who are able to receive much higher wages (up to 20 per cent higher) in school teaching (Brethereton, 2010:10).

We note that the review asks what should be the future arrangements for funding of the NQA. UCCS supports an assessment of the current funding mechanisms in order to achieve higher wages for ECTs. As noted by Brethereton “employees who stay tend to maintain and fortify service quality, often at the expense of their own employment arrangements and quality of life” (2010:7). It is not acceptable for ECEC staff to continue to trade-off a decent living wage for their commitment to educating Australia’s children.

Efficiencies and costs: Significant sector investment should be protected

There has been substantial investment from both Commonwealth and NSW Governments in order to prepare the sector for the implementation of the NQF. This includes subsidies for qualifications and RPL programs outlined above, and also extends to the range of materials and resources the government have produced to assist services in meeting the NQS.

UCCS also recognises that some services have made significant investments in order to prepare for the NQF and NQS. Given the focus of the review on achieving cost efficiencies, we see no benefit in reducing the standards of the quality framework or changing the standards. At March 2014 of all assessed services, 61 per cent were meeting or exceeding the NQS, 39 per cent were working towards implementation and only 0.2 per cent required significant improvement (ACECQA, 2014:12). With the overwhelming majority of services meeting or working towards full implementation of the NQS, any reduction in the current regulatory environment would make those investments redundant. It would undermine progress made so far towards achieving a national quality ECEC system.



National Quality Standards, national regulations and the assessment and ratings process: Supporting quality outcomes and continuous improvement

The reforms agreed to in the NQA each contribute a critical foundation to a holistic functioning quality ECEC sector. The implementation of the EYLF has significantly improved intentional teaching and outcomes for children. The NQS Assessment and Rating system has promoted greater reflection and accountability across a wide range of quality areas. The role of “educational leader” has been instrumental in these improvements, as has theQIP.

UCCS has found the EYLF and NQS easy to understand, assisted by supporting materials funded by the Commonwealth Government. Professional training courses will continue to support the implementation of the NQS over the next four years (as previously noted). UCCS has not found the NQS to be onerous or a “burden”.

UCCS staff across our services felt that there was no element of the NQS that could be removed or amended without compromising the overall quality of the system. UCCS recommends maintaining the current standards. We suggest that reviewing what resources and supports are made available to services to meet the standards would be of more benefit than changing the standards themselves.

As one Director reflected:

“I think it’s fantastic that there are national standards as it helps give children the best possible chance. The NQS provides a national baseline for quality as opposed to the old State by State system with each State deciding what they think quality should look like. This national approach results in better outcomes for all children across the whole nation.”

UCCS supports the use of the QIP as a tool as it fosters continuous improvement in services. It is a living and evolving document so it allows flexibility whilst also remaining relevant to changing and advancing experience and knowledge. UCCS has found that the process of creating a QIP has encouraged critical reflection and self-evaluation against each element of the



NQS and assisted in planning for improvement. Services have also used it as a tool to engage families in programs and planning. Comments from staff members included:

“Working on the QIP gives all of the staff more of an understanding on how to keep improving our service.”

“The QIP is a great way for involving the whole service’s community in working towards improvements for the service. It allows everyone to take a step back, see what they would like to improve, set a goal and work together to achieve it”.

Feedback on national regulations: legal requirements must be distinguished from ideas of “administrative burden”

Many UCCS staff educators and Directors raised the importance of distinguishing between meeting legal regulatory requirements and conceived notions of administrative processes such as “red tape” or the “administrative burden”. National regulations and laws provide a legal minimum from which to operate and in many instances are driven by primary considerations of the health, safety and wellbeing of children. They are critical elements of a functioning system, and meeting them is an obligation of every service.

UCCS notes the extensive work ACECQA has done on identifying and measuring administrative burden in the ECEC sector. The Report on the National Quality Framework & Regulatory Burden released in December 2013 provides a comprehensive overview of issues faced by the sector based on an in-depth study. Modelling of financial costs associated with identified with burdens by Deloitte is also included in this report.

Overall the NQA and its various elements provide robust processes and consistency. However, there are aspects of the administrative process which could be refined to establish a more efficient system. UCCS has identified areas for further reform that could assist in reducing the administrative burden or in simplifying the current system including:

• increasing consistency of assessments • refinement of ratings process • refinement of the temporary waiver process • inclusion of state-regulated ECEC services in the scope of the NQF.

These recommendations are discussed in more detail below.



An aspect that may have been perceived as onerous at its introduction was online notifications and applications through the NQA IT System. This may have added to the perception of increased regulatory administration, when more aptly it was a process and systems change. These have become simplified as the sector has embedded processes and systems improvements have been made.

The Early Years Learning Framework supports improved learning experiences for children

During consultations with UCCS service Directors for the Productivity Commission inquiry, many commented on the positive role of the EYLF in supporting services to develop and implement learning programs. Many commented on how the EYLF was an example of a holistic functioning system, with regulations and standards under the NQF and NQS supporting practice within it. Other feedback on the EYLF included:

• that it gives clear guidelines about program planning and development and assists in building skills. Examples given include providing a deep understanding of, and room for, critical evaluation of teaching approaches

• there is a greater focus on building relationships and attachments • it integrates intentional teaching practices, contemporary pedagogy that

is evidence-based and reflective practice for continuous improvement • it provides a nationally consistent practice framework for the first time in

Australia.

Feedback from UCCS staff on the EYLF was positive, with a numbermentioning the link between the EYLF and improvements in quality. Responses included:

“The EYLF is a fantastic guide to approaching child development and writing observations and children's individual summaries. We love that it looks at the whole wellbeing of each child.”

“Using the NQS and EYLF we have transformed the service to a very high quality one, we have observed dramatically improved outcomes for children”.



Feedback on the Assessments and Ratings System: working towards consistency

UCCS believes the new system of assessment and ratings is a significant improvement on the previous one under the National Childcare Quality Improvement and Assurance System. The new assessment and rating system provides more flexibility to address and respond to local needs and provides an emphasis on community links.

Standards are set out in a way that are less prescriptive and allows services to demonstrate how they meet the Quality Areas in a variety of ways. In our experience, expectations and criteria are clear and supported by a range of other inputs into the system. This includes course content of professional qualifications. The new system embeds improvement processes and is part of the process that assists in developing a quality program.

The NQF gives a lot of guidance around the application of these types of aspects of the NQS. For instance, the Commonwealth-funded National Quality Standard Professional Learning Program (NQS PLP) developed by ECA supports early childhood educators to embed the EYLF in their practice and achieve other aspects of the NQS. The NQS PLP has produced a number of online resources for practitioners including e-learning videos, an online interactive forum and production of materials.3

While UCCS has no issue with what is being assessed, there is potential to improve consistency around how assessments are carried out. When asked what areas of the NQA could be improved, assessments- particularly in relation to consistency- was the number one issue amongst staff members. As a state-wide provider of ECEC services, UCCS notes that there has been variances in the approach of Authorised Officers between regions. Most commonly this appears to be around when the assessments take place (either a full day or two half days), the length of time an assessment takes, who the assessor speaks to in a service, and the length of time it takes between an assessment and receiving a rating (where difference between size of service is discounted).

3 See <http://www.earlychildhoodaustralia.org.au/nqsplp/> for a full range of resources available [accessed 23/1/2014]

http://www.earlychildhoodaustralia.org.au/nqsplp/



Under the previous Quality Improvement and Assurance system, validators had to have qualifications and experience specific to the service that was being validated. In our experience this was positive as it provided the validator with an in-depth understanding on practice and programming that was utilised during service assessment.

UCCS is concerned that this level of experience is not required for new Authorised Officers and that this will undermine attempts to improve consistency of assessment in the sector. Assessment training is helpful in attaining consistency, but depth of understanding of teaching practice and content will be lacking where experience in the profession is missing. UCCS recommends that previous experience and qualifications standards required for validators are applied to Authorised Officers.

UCCS also believe that regional inconsistencies could be addressed through specific consultation and collaboration with regional authorities. State-wide providers would be able to provide clarity around experiences of regional differentiation. UCCS would be happy to contribute to any further exploration or review of regional inconsistencies.

Overall ratings system could be refined

UCCS welcomes the review’s focus on the ratings system and the provision of an overall ratings system. We believe that the formula for the current ratings system is complex and causes confusion amongst parents. Currently families are given a report in order to understand the overall rating given to a service.

We believe greater clarity could be achieved by providing a quality profile for each service with an overall rating given in each of the seven Quality Areas. This could be provided to families in much the same way that reports are now so they are better able to assess the relative merits of a service.

Provision of guidance and support to services receiving a “working towards” or “not meeting” rating under any of the Quality Areas would be welcome and strengthen overall sector improvement. Currently, there is limited feedback to services about what they should be doing to improve their programs. If it was found that multiple services were struggling in a particular NQS area, the Regulatory Authority and the Australian Children’s Education and Care Quality Authority (ACEQA) could assist in the targeting of resources and materials.



A review 12 months after the initial assessment would provide a robust mechanism by which to ensure that services are implementing improvements towards meeting the Standards. It would also provide services with an opportunity to have their ratings reassessed. This would be of particular benefit to services that met or exceeded all but one of the standards and received a “working towards” or “not meeting” overall rating in one of the quality areas.



Governance arrangements, national regulation, legislative requirements and funding

Effectiveness of governance arrangements for NQF including role, structure and effectiveness of ACECQA

UCCS’ experience of ACECQA has been very positive. We note the range of areas that the Review is seeking feedback on, and believe that ACECQA have performed highly in each of the areas. In particular, ACECQA has been incredibly consultative and responsive to the sector. Not only have they undertaken a number of national forums and consultations, they have done these processes well. In our experience ACECQA has also been open and willing to engage with providers.

Another stand-out area has been the number and quality of materials that ACECQA has produced. This includes national reviews and surveys, parent newsletters, training materials and in-depth articles about specific areas under the NQS. We have found that materials have been well written and accessible for their relative audiences (whether it is parents or educators). Collectively we believe the material that ACECQA has produced has assisted services in their implementation of the NQF and helped educate the broader community about changes in the sector.

Efficiency and Effectiveness of the Regulatory Authority

UCCS recognise the recent amendments to the Education and Care Services National Regulations and congratulate the government on swiftly implementing changes following the first round of the Productivity Commission inquiry. These changes have assisted to streamline processes. In particular, one area of administrative burden raised by UCCS was the Certified Supervisor process, and we are pleased to see that this has now been rectified.

An area that is still in need of attention is the temporary waiver process, particularly the timeframes for approval where additional information is required. The temporary waiver provides a mechanism to reasonably manage



short-term situations where best endeavours have not yet yielded the requirements of the regulations. Providing allowances for short periods (in circumstances such as recruiting ECTs in rural and remote areas) can ensure monitored compliance.

Generally we have found the application timeframes for waivers appropriate. However, we have experienced times where the waiver is still being processed at the three month cut-off point. This means that the waiver application has been closed, and we have had to reapply and re-pay processing fees. On the few occasions we made applications, this has occurred where we have been asked for further information by the regulatory authority close to the processing deadline. UCCS recommends a process whereby extensions for the waiver process are granted where authorities seek additional information.

The temporary waiver process would also be assisted by a coordinated and clear communication strategy by the regulatory authorities and ACECQA. This would help minimise confusion and is especially important where there are state- and territory-specific requirements and transitions.

Feedback on the scope of services covered by the NQF

UCCS would like to see any ECEC service that is regulated by state or federal bodies made in-scope of the NQF. For instance, in NSW, services currently regulated by the state but not under the scope of the NQF include occasional care and mobile preschools. There is room to provide recognition of the unique service type under the NQF and make allowances for service diversity similar to the allowances applied to OSHC services.

This would reduce confusion within the sector, reduce fragmentation of services and increase service consistency within States and also nationally.

As noted by one UCCS educator:

“As we are an Occasional Care service we are not part of the NQF at present which causes confusion as to what rules apply to these services. Having a single body that covers all services makes sense”.

There is also potential to increase the quality of services provided in current out-of-scope services by bringing them under the NQF (after a decision has



been made on which aspects of the Framework would be relevant for the service). As noted by another UCCS Occasional Care educator:

“As Occasional Care is not covered under the NQF it is very difficult to apply the Framework in this environment. However having the Framework as a reference and a goal for the future in conjunction with the current regulations has improved the quality of the education and care provided.”

Application of the NQF to OSHC

We note that the review asks to what extent legislative requirements can or should be tailored to particular service types and settings, with OSHC being given as an example. In OSHC there are already different requirements under the NQF compared to other services such as LDC. Generally UCCS believes that alternate requirements of OSHC are suitable and reflective of the different type of service offered.

One area of improvement would be for OSHC services to have access to a qualified staff member (defined as a Certificate IV holder and above) to assist in guiding the educational program in OSHC services. Currently there are no qualifications requirements of staff in OSHC services; however OSHC services provide programs and activities that incorporate educational and developmental outcomes. Having input into the direction of these activities from a qualified person would assist in strengthening educational outcomes for children.

Future arrangements for funding the NQA

Funding for regulatory and administrative implementation of the NQA must continue to support the quality reforms and ensure that the current structure of co-investment by State and Commonwealth government is appropriate. However, NQA funding arrangements sit within a broader review of the funding of the entire ECEC sector. This is currently being considered by the Productivity Commission inquiry.

Achieving and sustaining the goals of improved access and affordability of early childhood services will require continued investment, with scope for better targeting to increase access for children from disadvantaged backgrounds. There is scope for Australia to increase its investment, particularly to bring us in-line with the investment of OECD counterparts



(Australia has generally lagged almost last of all OECD countries in ECEC investment on a GDP per capita basis) (Urbis, 2013:85).

Given the significance of early years programs for children’s learning and emotional outcomes, adequate investment in the early years is of critical importance.



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Documents

UnitingCare children’s cervices submission to the 2014 Review of …€¦ · Executive Summary 2 The degree to which the agreed objectives and outcomes of the NP NQA have been achieved