National Association of Community Based Children s Services NSW Branch by d183fx


									      Productivity Agenda Working Group –
      Education, Skills, Training and
      Early Childhood Development

                           Submission form for
                    A national quality framework for
                   early childhood education and care
This document contains a standard written submission form, inviting you to provide information in response to the
issues raised in the discussion paper A national quality framework for early childhood education and care.

You are welcome to use the standard form, or to provide a submission in your own words, addressing any or all
of the issues raised in the discussion paper. Comment boxes have been sized to fit the pages of this document.
Your comments should not be restricted by the space made available on this form. If you are providing a
submission in an electronic format, please feel free to expand the space made available here. If you are
providing a submission in non-electronic format, please feel free to attach additional pages, indicating which
question(s) you are addressing.

Please send your completed submission to:
Fax: 02 6212 9383
Mail: Productivity Agenda Working Group
      (National Quality Framework for Early Childhood Education and Care)
      c/- Early Childhood Quality and Care Group
      Department of Education, Employment and Workplace Relations
      Level 4, Juliana House
      10 Bowes St
      WODEN ACT 2606
      (Attn: Mr Philip Brown)

For more information on the national quality framework for early childhood education and care, please see the
information on the internet site at, or telephone 1800 220 425.

Written submissions should be provided by Friday, 19 September 2008 so that they can be considered by the
Working Group in developing an exposure draft of the National Quality Standards, which will be made available
for public consultation later in 2008.

Public consultation forums
If you would like more information on the public consultation forums, please see the information on the internet at, or telephone 1800 220 425.
Please Note: Email attachments should be provided in Microsoft Word, Adobe PDF or a common PC-based
image or text format. Internet and email are not secure mediums to transfer information. If you have concerns
about using this form or if your submission is sensitive, please use the mail address provided, allowing sufficient
time for the submission to be received, in Canberra, by Friday, 19 September 2008.

The information you provide to the Productivity Agenda Working Party will be used for the purposes of the
national quality framework for early childhood education and care consultation process only. This includes all
activities in relation to this process. Some or all of this information may be provided to the relevant
Commonwealth, State and/or Territory agencies assisting with this process. Submissions will not be published or
otherwise made public.
Form for written submissions (optional)

Information about the submission
Please provide your details below. Consider providing your name, your organisation (if relevant)
and your contact details. If you include your contact details you may receive correspondence in
relation to outcomes of the consultation process, the development of the reforms or future
consultation opportunities.

 Name                      Lisa Bryant

 Organisation              National Association of Community Based Services (NSW Branch)

 Address                   Post Office Box 221,
                           Summer Hill. NSW 2130

 Phone                     8922 6434


You may remain anonymous if you choose, and your submission will still be considered.

Your interest
Please outline the nature of your interest in the early childhood education and care sector. For
example, you might be a child care provider, a member of a family using long day care or family
day care, or an academic with an interest in early childhood education and care issues.
If you choose to remain anonymous you may still wish to provide some details around the nature
of your interest in the early childhood education and care sector, as this may assist in
understanding your comments.

NACBCS (NSW Branch) advocates for community owned children‟s services. We lobby for the
maintenance and extension of not for profit community owned children‟s services.

As the peak organisation for community owned services, NACBCS NSW is a politically independent
lobby group for not-for-profit, community owned children‟s services, and advocates for the delivery of
quality children‟s services programs underpinned by the rights of children, staff and families.

• Advocates and assists the development of community owned children‟s services;
• Initiates public action to promote and defend community owned children‟s services; and
• Acts on behalf of community owned children‟s services in relation to governments and other bodies.

NACBCS‟ members are services (staff/management and children) of community based long day care
services, preschools and Out of School Care Services as well as parents and interested individuals.

N.B. Where others in the children‟s services sector have more eloquently expressed our viewpoint on
certain issues we have appropriated their words in this submission, particularly the Centre for
Community Child Health, Policy Brief No12: Towards an Early Years Learning Framework and Pam
Cahir , CEO of Early Childhood Australia, A charter for Childcare (August 2007) and Frances Press‟s
What About the Kids? 2007

Consultation questions – National Quality Framework

NQF1 - Strong quality standards
   What do you consider to be key drivers of quality that should be included in the standards? Do
    you agree with those listed in section 5.2 of this paper? (Leadership and management,
    Relationships between staff and children, Family and community partnerships, Differentiated
    play-based curriculum, Physical environment, Staffing requirements and arrangements) Can
    you suggest others?
   How should the increased focus on early childhood education and care and outcomes for
    children be reflected in the new standards?
   Given that preschool can be delivered across a range of settings, what is the best way of
    monitoring and reporting on preschool delivery for four year olds (that is, in the year before
    formal school)?

NACBCS NSW believes that National Quality Standards:

       Must be research based and evidenced.

         Must embody the key drivers of quality; ratios, group size and staff qualifications. If these
          elements are correct, all other determinants of quality tend to fall into place.

         Must have at their core those elements of quality that allow meaningful relationships between
          children and carers/educators to develop and allow child focused pedagogical content.

         Must include the Early Years Learning Framework.

   What are the considerations in applying an integrated set of standards across all service
    types, including family day care, outside school hours care, Indigenous services, etc? Possible
    considerations: health and safety, physical environment and staffing standards in different
    settings, integrating preschool and child care.
   Would a core set of standards supplemented by service-specific standards overcome these
    barriers? For example, a modular approach which sets out a common core set of principles,
    supplemented by specific modules for each service type.
   What other options are there for an integrated set of quality standards?
   How could the standards take account of the age of children?

NACBCS NSW believes that:

       it is vital that a core set of standards supplemented by specific modules are implemented for
        all service types – there is no way that an integrated set of standards can effectively cover the
        differences in each care/education setting and the differences in the requirements of settings
        catering for different age groups.

       it is vital that the Commonwealth Government understands that its intention to deliver
        universal access to a preschool program for all 4 year olds is praiseworthy, but that this
        commitment to children in the year before formal schooling should not be the driver for the
        quality standards, nor should the need for a positive transition to formal schooling. Early
        learning for 0-3 year olds is an important goal in and of itself. Quality standards should not just
        be driven by school transition requirements.

       it is vital that the quality standards are not developed to the lowest common denominator of
        existing state standards/regulations. Children need and deserve the highest possible quality of
        care available. The standards must be developed from evidence-based research.

       it is vital that the quality standards are enshrined in legislation. If the standards are left as
        recommended standards only, not all states will ensure their application in practice. Because
        the existing standards are significantly under NSW‟s existing Regulation, the standards are
        inherently irrelevant in NSW.

   What are the potential impacts of the introduction of a new set of quality standards on early
    childhood education and care services? Possible considerations: workforce, financial viability,
    implementation arrangements, service provision.
   What are the particular issues with changes to the „iron triangle‟ structural indicators of quality:
    staff qualifications, child-to-staff ratios, and group size? Possible considerations: workforce,
    training, relative costs and benefits of each indicator.

NACBCS NSW believes that:

         Quality costs money. We cannot sacrifice what research tells us will provide children‟s
          services because it would be too costly, impossible to deliver because of skilled labour force
          shortages or result in decreased service provision. We must provide what children need
          despite the cost or barriers.

         For too long the needs of children have been made subsidiary to the realities of
          implementation of quality early childhood education and care provision. The needs of the child
          must be paramount at all times.

         For too long children have suffered under inadequate staff ratios, large groups sizes and
          inadequately qualified staff because of concerns about the economic costs of implementing
          the changes to these drivers of quality.

         For too long costs have been the determinants to implementing quality benefits. Children
          need quality early and middle childhood services regardless of the cost.

         The needs of children should be made central and foremost. The fact that children‟s services
          enable parent to participate in the paid workforce is secondary.

NACBCS NSW believes that:

         A solution to worries about implementing standards requiring higher staff qualifications could
          be found in a commitment and well thought our program to up skilling the existing workforce‟s
          qualifications and supporting opportunities to increase qualifications of all staff to a minimum
          of Certificate III and an early childhood teacher for each group of children in centre based

         A simple solution to worries about the cost of implementing standards requiring better ratios
          and group sizes is changing the way we currently fund early education and care. If we funded
          services as opposed to parents through CCB, funding rates could be linked to ratios and group
          size. The higher the ratio and group size offered, the higher the funding.

Transitions to a new system
   What transition arrangements do you consider appropriate for implementing the proposed
    changes? What timeframe might be required to fully implement all changes? What supports
    for the early childhood education and care sector do you think would assist these transition
    arrangements? Possible consideration: professional support program.

NACBCS NSW believes that:

       The sector needs time to allow for adequate consultation of the new standards once drafted.

       The sector needs for our comments to be taken into account in the redrafting of the

       The sector needs extensive funded support delivered through a range of appropriate
        professional support agencies to enable a thorough understanding of and familiarity with the
        new standards.

       The sector needs to be supported to understand not just what the new standards are but their

       The sector needs a staged implementation process for example the supply of teachers in the
        sector is currently insufficient.

NQF2 - A quality rating system
   What do you think should be the objectives of a rating system? Do you agree with the
    objectives listed in section 6.1.2 (Indicator of service quality, Continuous improvement in the
    early childhood education and care sector, Information for families and communities)?
   Which objective is the most important? For example, is informing parental choice of service
    the primary objective?

   NACBCS NSW believes that the three objectives of the proposed rating system (Indicator of
    service quality, Continuous improvement in the early childhood education and care sector,
    Information for families and communities) are reasonable objectives but believes the most
    important objective is to make services exemplary and responsive places for children as
    measured by evidence based research and practitioner wisdom.

   NACBCS NSW therefore believes that the most important objectives of any rating system
    should be :
                to make children‟s services exemplary places for children
                To guide continuous improvement and to reward services that are continually
                 improving and responsive to their community.

   NACBCS NSW believes that our current accreditation systems have five major flaws:
            Any system which expects accreditation rates of almost 100% is not an effective
             quality measurement system
            Any system that is designed around what makes a good „system‟ is not examining
             what makes a difference for children.
            Any system that does not assess those things that we know make high quality
             services (i.e. ratios, group sizes, staff qualifications) and reward those services that
             have evidence-based ratios, small group sizes and highly qualified staff is not a
             quality assurance system
            Any system that demands that focus is taken away from quality service delivery to
             provision of documentation to meet a system is not as good system.
            Any system that is continually changed makes it harder for services to work with.

Design issues
   What principles do you think should underpin the design of the rating system?
   How should services be rated against standards? What should the rating system look like in
    order to achieve its objectives? Possible considerations: measurement, attainment or other
    approaches, how the rating system will link to the standards, accreditation and licensing.
   What kind of information should the rating system provide to parents and others in the sector?
    Possible considerations: grades of quality at each level e.g. A-E, incentives for continuous
   What potential risks are there in introducing a rating system? How could potential negative
    implications be minimised?

   Who should carry out the rating process and why ?

NACBCS NSW believes that the most important aspects of introducing a rating system are that:
   the system must be supported by greater investment and incentives to enable all services to work
    towards the highest level of the scale.
   there must be real sanctions for services that are not delivering quality services
   It should be co-ordinated by a national body rather than state based bodies
   The body charged with carrying out the new rating process should not duplicate the inherent
    problems of NCAC especially:
        o Insularity and lack of accountability to the field
        o Lack of role clarity – NCAC sets the standards, then assesses services performance
            against these standards then resources the sector to meet these standards– these roles
            lead to conflicts of interests.
        o Concentrating more on system coherence than what is best for children
        o Suppressing innovation and practice based on good professional judgement in the sector


   Should the rating system include all services in the early childhood education and care sector
    e.g. long day care, preschool, family day care, outside school hours care, Indigenous services,
    etc? What are the implications of bringing all service types under one rating system?

         NACBCS NSW believes that a rating system should cover all services BUT it should not be an
          integrated system.
         We believe that there could be an integrated rating system with some overarching core
          principles across service types but that there must be specific principles and indicators that
          take into account differences in settings and in age groups.
         Families tend to want to compare services within service types rather than across service

   What are the potential impacts on early childhood education and care services? Possible
    considerations: workforce, financial viability, implementation arrangements, service provision.

NACBCS NSW believes that children‟s services are suffering changing accreditation system fatigue.
Many services have been accredited under a different system each time they have been accredited.
Any change should be bought in on a slow time frame with adequate time for consultation and learning
about the new system.

Transitions to a new system
   What transition arrangements do you consider appropriate to implement the proposed
    changes? What supports for the early childhood education and care sector do you think would
    assist these transitions?
   What timeframes are required to allow services to transition to a new rating system?

NACBCS NSW believes that the sector needs extensive funded support delivered through a range of
appropriate professional support agencies to enable a thorough understanding of and familiarity with
any new rating system.
This support/professional development should be funded and delivered at a service based level to
enable all staff to understand and participate in the new system.

NQF3 - Streamlined and/or integrated licensing and accreditation arrangements
Streamlining and/or integration
   What are the current issues or problems with the existing regulation, licensing and quality
    assurance system?
   What changes to the structure of the quality assurance system would you suggest to increase
    consistency, effectiveness and efficiency across service types and/or jurisdictions? How might
    these changes affect you or your service? Possible considerations: administration,
    governance and delivery arrangements, reducing administrative duplication.

Current issues/problems with the existing regulation/licensing and quality assurance system include:
        Duplication across systems leading to more time being spent on compliance issues at the
         expense of time spent planning and delivering a program. Children‟s services in NSW are currently
         subject to over 92 different pieces of legislation/regulation.
        Lack of evidence based regulation/accreditation. The fact that current Quality Assurance systems,
         especially for LDC services, do not measure those things research tells us make a quality services
         such as ratios, group sizes and qualifications of staff. We need to incorporate standards which are
         known to positively influence quality into the different elements of a licensing/accreditation system.
         The fact that existing NCAC trends reports shows that the majority reason why services are
         receiving non-accredited decisions are for minor issues such as not sourcing policies is a worrying
         indication that existing processes are not truly judging evidence-based quality.
        Lack of coherency across Australia and across service types. Some services are
         unregulated/unlicensed in some states. Some services such as state funded preschools and MACS
         are not under QA systems. Children get a better or worse deal in important elements of regulation
         such as ratios, depending on which state they are attending a service in. “The imperative of quality
         applies to all early childhood services, therefore all must be regulated and accredited for quality,
         regardless of type of jurisdiction.” (Fran Press - What About the Kids? 2007)
        Lack of universal access to high quality services. NACBCS NSW believes that in addition to
         integrating licensing and accreditation, the Commonwealth Government must investigate integrating
         existing systems to create a more affordable, equitable and integrated system of early and middle
         childhood services. In NSW we have a poorly funded preschool system which means that children
         in NSW have poorer participation rates in preschool than those in other states and parents pay
         higher fees. There is excessive duplication between bureaucracies and frameworks for the state
         funded preschool system and the Commonwealth government support approved child care service
         system. A single example of this is the systems that have developed to support children with
         additional needs to access ECEC. NSW families using state funded services access the SCAN
         program (funded and administered by the NSW State Government) whilst those families accessing
         long day care access the Inclusion Support Program. Many families access both preschool and long
         day care and face two different systems to enable their children to have equitable access to a
         service where they can receive early education and care. This duplication is madness. Families in
         NSW who access preschools are disadvantaged over those who access long day care because the
         choice to have their child use a sessional preschool means they are not eligible for the Child Care
         Tax Rebate or the Child Care Benefit. This too, is madness. Families must have the right to access
         the type of care they believe is most suited for their child‟s and family‟s needs without worrying
         which level of government administers and funds it.
        Lack of understanding by families of the systems in place to ensure children‟s services is quality
         care – confusion about licensing and can a service that has breached state
         based regulations be deemed a high quality service under the Commonwealth Quality Assurance

         NACBCS NSW believes we should move towards an integrated system of licensing/accreditation
         that is managed by the Commonwealth Government. This system should have three layers: national
         regulations, quality assurance and continuous improvement. A different body should be responsible
         for determining the required quality requirements with another body responsible for monitoring
         quality. Services must meet the regulatory system at start up must be working on quality provision
         from start up and after a number of years of operation can apply as a centre of excellence in a
         certain area of operation.

Transitions to a new system
   What would be the issues for you in moving to a streamlined or integrated system? What
    supports for the early childhood education and care sector do you think would assist these
    transitions? How much time should be allowed for the sector to make the transition to the new
    system? Possible considerations: implementation arrangements, service provision.

NACBCS NSW believes that the transition issues will be:
       Ensuring that each state agrees to the integration without it becoming lowest common
        denominator agreement. NSW is proud that we have a requirement for early childhood
        teachers in all centre based early childhood services above 29 places and would like to see
        this extended nationally to a teacher in all groups including those in smaller services, not
        removed to appease the states without this requirement.
       Ensuring that the workforce is adequately trained in the new systems and that centres are
        funded, resourced and supported through the change
       Ensuring that there is sufficient grandfathering clauses to allow service stability
       Ensuring that a reasonable timetable is developed to enable staff to be confident in change, a
        planned and staged approach, to allow upskilling for services not yet covered by quality
        improvement systems and services that are geographically and professionally isolated
       Ensuring that the integrated system is based on research
       Ensuring that the new integrated system will bring stability to the sector and the compliance
        requirements required of it.
       Ensuring that the system demands simple streamlined reporting that is recorded in a national
        If the data is not being used to improve anyone‟s practice and if it is not transparent as to who
        it is being used by, what is it being used for and how useful it is it should not be collected.
       Ensuring that it does not ask services for things that cannot be achieved such as training by
        allied health professionals which is a requirement currently under the QIAS system that cannot
        be met because of shortages in the allied health profession.
       Ensuring that services have certainty around what level of funding they will receive and the
        accountability requirements of that funding including regulation/licensing/national framework
        and quality improvement.

NQF4 - Workforce
   How could the status and recognition of the early childhood education and care workforce be
   What could be done to address limited advancement options and career paths?
   What possible approaches could be used to improve retention strategies?
   What strategies could be adopted to increase the numbers of Indigenous child care workers
    and teachers?
   What is the likely impact of any suggestions on the price of and demand for services?
   What possible approaches could be used to address shortages of early childhood teachers in
    regional and remote areas, long day care services and community preschools?

NACBCS NSW believes that:

     Unless we pay early childhood teachers in an equitable way with teachers in primary and
      secondary education the status and standing of the early childhood education and care
      workforce cannot be raised. There needs to be pay equity between workers with the same
      qualifications within the sector regardless of which service type they are working in. This pay
      equity does however need to account for factors such as shift work, holidays etc.
     Unless we pay qualified people appropriately we will not have the sustained relationships and
      intentional interactions with children which are at heart of their development.
     Unless we pay people appropriately we will continue to have a very unstable workforce in
      children's services.
     Unless we ensure that early childhood teachers have a professional registration body to allow
      for professional recognition and accountability so that they have parity with other degree
      qualified teachers and other professions.
     The major factors that would increase retention in the sector are: a workforce with higher
      qualifications, improved staff child ratios, a more coherent ECEC system with less focus for
      senior staff on administration and compliance issues, increased remuneration and increased
      status for children in our society. If children were truly valued and the role of the ECEC
      profession in nurturing and educating children was truly understood, articulated and affirmed,
      retention of staff in the sector would be increased.
     There should be no untrained staff in children‟s services. The lowest qualification should be a
      Certificate III qualification with workers encouraged to increase their qualification to a diploma or
      4 Year Teaching degree. Every service should be required to employ at least one teacher per
     Existing staff should be given the option of having recognition of prior learning and should be
      assisted to obtain a 2 year qualification within the next five years at no cost.
     If Registered Training organisations are to be allowed to issue qualifications within the ECEC
      sector there needs to be minimum training times and minimum practicum times attached to
      those qualifications.
     A more highly skilled and a more highly paid workforce will result in increased costs of service
      provision. This cost must be borne by the Commonwealth Government, not parents or services.
     The Commonwealth Government should subsidise the cost of employing well paid teachers in
      services by direct operational subsidy to services.
     ECEC staff should be able to access ongoing professional development and in-service training
      with funding that covers the cost of professional development and the cost of additional staff.
     To increase the number of trained Indigenous workers training needs to be culturally relevant,
      funded and delivered in local communities.
     As well as increasing the pay rate and professional standing of teachers, in order to solve the
      shortage of teachers in regional and remote areas a pay loading/tax rebate should be given for
      teachers working in regional and remote services as per exist for the medical profession .
     To increase the number of early childhood teachers, specific early childhood (0-5) teaching
      degrees should be implemented.
     ECEC staff access to professional support and development matters to allow us to reflect,
      rethink and improve our practice with children.

Consultation questions – National Early Years Learning Framework

EYLF1 - Purpose of the framework
   What philosophy would you want an Australian framework to use? (eg. would it focus on ages
    and stages of development; a socio cultural approach; or domains of learning eg physical,
    social, emotional and cognitive?)
   What form or format should the Early Years Learning Framework take that would be most
    useful to you in guiding your programming for young children?
   How prescriptive do you think the Early Years Learning Framework needs to be? Do you have
    a preference for the actual length of the Framework?
   What type of supporting documents/resources would be most valuable for parents and others
    working with young children (e.g. family day carers, playgroups)? Do you have any views on
    the format and size of such documents?
   Do you see any issues with the implementation of the Early Years Learning Framework in all
    education and care settings from July 2009? What suggestions would you offer to overcome
    these issues?
NACBCS NSW believes that a National Early Years Learning Framework:
       should guide practitioners and not be prescriptive
       should be concrete and not consist of motherhood statements
       should be built on research and knowledge about child development and children‟s
        learning while acknowledging diverse learning styles in different families and
       should be strengths based not built on a deficit model of child development.
       should be inclusive of a range of additional needs
       should be play-based, interest-based and based on the development of relationships
       should include a philosophy and different approaches to curriculum, including a
        range of approaches that educators can draw on in different contexts
       should be outcomes based not content based.
       should be based upon a partnership with families.

We believe it:

       should not be prescriptive
       should not be a push down school curriculum
       should not be content based

We believe the focus:

       should be on translating research into practice so that all that we know about
        children‟s development can be encapsulated in the experiences we provide them in
        an ECEC setting.
       should be on all children 0-5, not just 4 year olds.

We believe it:

       should be written for four year teacher trained staff.
       should be interpreted for parents and community members and other early
        childhood staff so that there is an understanding of early and middle childhood
        educators‟ practice and how it differs from school based educators practice. Families
        need to be taught the value of play, why pushing down the school curriculum (erg
        literacy and numeracy) is inappropriate and what the rationale to the content of a
        child‟s day in a service is.

EYLF2 - Questions relating to research findings
   Is the analysis of the trends in the literature accurate and comprehensive? Are there any
    issues in the research relevant to the development of the framework?
   Do you support a focus on language and communication development, social development
    and play-based learning in the framework ?
   How would you define the roles of the educator and the child in the learning process in the

NACBCS NSW believes that the research supports:
        The need for a national early years learning framework that applies to all children from
         birth to five years and to all early childhood service settings.
        The need to understand that the irreducible core of early experience is relationships.
        The need to develop a framework that contains concise statements of the overall aims
         and outcomes of early childhood services, the principles on which service delivery should
         be based, the educational outcomes to be expected, and the aspects of children‟s
         development and learning that are to be covered.
        The need to avoid a framework that includes specific curriculum guidelines as to what
         should be covered (curriculum content) or how it should be implemented (care and
         teaching practices).
        The need to ensure that a national early years learning framework influences practice, it
         must be acceptable to and taken up by practitioners.
        The need to blend the traditionally separate early childhood care and education functions
         into a seamless service.
        The need to articulate the most effective ways of supporting the learning and
         development of infants and toddlers.
        The need to frame the early years learning framework in a way that will allow it to grow
         and evolve as our knowledge and views change.
(Centre for Community Child Health, Policy Brief No12: Towards an Early Years Learning Framework)

EYLF3 - Foundations for the framework
   What would you want included in the framework‟s vision for early learning and children?
   Would you support the values and rights proposed to underpin the framework?
   What other values and rights would you want included and why?

NACBCS believe that the vision that the framework should be based on should articulate that
children are capable and competent learners who should be given the optimum conditions in
ECEC settings to learn and develop regardless of their cultural background, location or additional

EYLF4 - Building the framework
   How should the curriculum framework provide guidance and strategies to meet the various
    learning and development needs of the children including those with special needs, English as
    a second language and/or challenging behaviours?
   Is it appropriate for children‟s learning to be assessed? If yes, how should children‟s learning
    and development outcomes be assessed?
   How would you ensure the curriculum framework is appropriate for all educators, regardless of
   What kind of professional development will need to be provided in order to support educators
    in using an Early Years Learning Framework?


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