Submission form for

							                                          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:
Email: ECECQualityReformSubmissions@deewr.gov.au
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 www.deewr.gov.au/COAGdiscussionpaper, 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 www.deewr.gov.au/COAGforums, 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)


                                                                                                          1
         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                            Helen Broderick


    Organisation                    Hume City Council


    Address                         1079 Pascoe Vale Rd
                                    Broadmeadows 3047
    Phone                           *****


    Email                           *****




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.




    We welcome the opportunity to submit comments to the national quality framework for early childhood
    education and care.

    Our interest is as a planner /provider and advocate of Early Year Services in Hume City, to maximise
    opportunities for all children. We also welcome the opportunity to share our experience of the implementation of
    Hume Early Learning Essentials framework, which acknowledges the importance of children’s development
    (birth to 6 years), the central role of parents in their child’s learning, and the significant partnership role early
    childhood professionals have with the children and their parents.

    The framework has been developed for the Preschool and Child Care sector within Hume Family and
    Children’s services (F&CS) and has been guided by the Victorian Essential Learning Standards (VELS) to
    provide a seamless link and continuity between the Early Years and Primary Education system.

    Implementation of the framework is currently a work in progress being trialled across four (4) Long Day care
    centre and twenty four (24) Preschool centres across Hume City.
    The framework embraces play as the essential vehicle for learning and is used as a guide to encourage a
    consistent, high quality approach to program design.

    The framework embraces the quality assurance principles and has the capacity to grow and evolve to support
    our families within a growing municipality, as our knowledge and experience develops.




                                                                                                                       2
     NQF1 - Strong quality standards
     Content
          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)?


STRONG QUALITY STANDARDS
We endorse the key drivers of quality as listed in Section 5.2
The new standards should be an amalgamation /revision of the NCAC quality standards, to provide quality
experiences and positive outcomes for all children to improve the quality of child care and accredit services that
meet the standards.
The new standards need to reflect internationally recognised best practice, however whilst a four year
qualification may be a prerequisite for achieving policy goals the new standards must also address realistic
education qualifications in the short term. Qualifications could be a blend of Certificate, Diploma and Degree
and evidence based professional development opportunities, to ensure that we are able to offer and deliver a
quality education and care package. All staff working in early childhood services must have a basic
qualification, at least at Certificate 3 level.
The standards need to acknowledge that reasonable time allocations are required for staff to attend to the
fundamental written requirements, a crucial tenet of a quality program. (Currently there is an anomaly in this
time allocation within long day care). Parity across early childhood services for planning time will be a critical
success factor.
Improved child /staff ratio/ regulations consistent nationally – not different in each of the states.
The standards should be reflective of stronger engagement and collaborative relationships between
professionals, families and their communities to ensure that children are provided with quality programs to
support positive learning outcomes and child wellbeing.
The standards also need to consider how we engage with vulnerable families and those who have difficulty with
formal engagement with services. This is to ensure that we do not present more of a burden for these families.
There needs to be increased pathways to resource the capacity of referrals for children and their families for
early intervention. Increased appropriate professional referral services availability and links across external
networks providers to support the provision of referrals.
The standards should have an application and provision for a stronger engagement and relationship with the
Maternal and Child Heath service to resource the capacity of early childhood teams.


Monitoring and reporting:


        Monitoring and reporting on preschool delivery for four year olds should be supported by adequate
         Early Years support staff who work collaboratively with staff to ensure process is maintained to report
         on potential learning outcomes for all children on at least a bi-monthly visit basis.

        This support structure needs to be adequately funded to support successful school transition
         arrangements and consistence within the community sector.




                                                                                                                     3
       Staff need to be trained in requirements of monitoring and evaluation

       Monitoring and reporting needs to be consistent across all settings and not differentiated between LDC
        and Preschool

       Formal consistent collaborative relationships are established with Primary schools to support transition
        to school programs with clear guidelines, expectations of what early childhood outcomes should be
        reported. Currently there is inconsistency related to school transition processes from School to School-
        this need to be formally addressed.



Coverage
1. 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.
There are massive implications in industrial conditions/different award structures/wage parity/non- contact time
– same expectations of all staff regardless of setting.
Considerations would also need to address the uniqueness of families e.g. Low Socio- economic families
/CALD /ATSIC /different types of services
2. 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.
More specifically, the focus needs to be on consistency to achieve improved potential outcomes for children
and their families
Consideration could also be given to a competency based approach.
3. How could the standards take account of the age of children?

The core standards would be underpinned by broad developmental age appropriate based outcomes for
children. These standards also need to reflect differences in opportunities for children,e.g the opportunities that
children get at different ages, e.g. Out of School Hours




                                                                                                                  4
 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.
 IMPACTS
 Research demonstrates that the prime structural indicators of the quality of formal care are staff qualifications,
 child-to-staff ratios and group size. The required changes to these indicators would directly impact on:
    Financial costs to Government, Service providers and ultimately parents. Rise in early years care and
     education costs/ increased costs to providers – Costs include increased staff ratios/support staff/relevant
     professional development opportunities.
    Will Governments subsidise the cost increases for upgrading of qualifications?
    Education costs/time to ensure appropriate qualifications
    Workforce issues in recruitment and retention. as a ( Staggered qualifications/ RPL/validating professionals
     in the field/Mentoring support)
    Increased cost will have a flow on effect to families/impacting on accessibility
    The capacity to resource staff in early Childhood Services to not only implement standards but to reinforce
     quality of services
    Supporting the formalised parent relationship would require an additional impact and more involvement of
     staff roles and administration.
 Consideration would need to be given to monitoring the universal access of 15 hours per week access to
 quality early childhood education and care.
 What provision is there for these hours to be achieved through LCD? This would impact on the qualifications of
 staff in LDC settings – (an anomaly that currently exists where a preschool teacher is employed in a LDC
 program for 10 hours and then deployed in the LDC setting at a different salary rate.) A transition arrangement
 could be to upgrade and train all Diploma staff in 3-5year programs to a four-year qualification.


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.

 Whilst a National Quality Framework System is a huge undertaking, our experience in implementing changes
 (on a small scale) has provided some insights regarding transition arrangements around establishing change
 and supporting quality programs.

 Transition arrangements for the implementation of Hume Early Learning Essentials have occurred over a two
 year period. The total process has been monitored and evaluated by staff and parents.

 Whilst still a work in progress, transition arrangements for our early years framework has included extensive
 professional development training and support sessions, questionnaires and mentoring through clusters, staff
 meetings and team leader support.
 All Preschool and long day care staff will have participated in a trial of the framework over a nine-month period,
 to be ready for full implementation in 2009.

 Whilst we can comment on our transition experience in implementation of a consistent approach to program
 planning across (24 preschools and 4 LDC centres), we feel that transition arrangements for a major project of
 the size of the proposed National Early Years Learning Framework would have a greater complexity – but
 perhaps need a maximum timeframe of at least 18 months – 3years for aspects of the framework and a further
 5 years for consolidation across Australia- possibly a conservative answer!



                                                                                                                      5
 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?

 We endorse the suggestions in 6.1.2 to drive improvements in the quality of early childhood care and
 education.
 The assessment against a standards approach would be able to grade results against an agreed set of quality
 standards, which would be reflective of the three proposed objectives. This type of rating system will ultimately
 benefit staff, families and service providers. Particularly beneficial for parents in the provision of relevant
 education information, including child development expectations and outcomes and what to expect of a quality
 service. Improvement to the quality of the care and education are more likely from a staff perspective when a
 benchmark is provided.


 We endorse the possible principles for a rating System in Box 6.1
 There are challenges in introducing a rating system for both families and services, however obvious benefits
 would raise the awareness and quality of child care and education for families.
DESIGN ISSUES
 What principles do you think should underpin the design of the rating system?
 Consideration given to the NCAC Standards as a benchmark/ utilised with modifications from the focus groups
 and feedback submissions which then becomes the framework for the quality framework nationally.
 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.
 Considerations must also :
     provide a public information campaign for providers and parents
     determine how regulatory compliance will be defined and measured
     determine the quality indicators including child development outcomes
     determine guidelines/policy /procedures for measuring compliance with each quality indicator
     provide reasonable support structures(financial/time release)to help support programs to improve
        quality
     provide an evaluative framework to measure the effectiveness of the quality rating system


 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
 improvement.


 The rating system should focus on the foundations of quality assurance ensuring quality indicators and be
 linked to the standards. A ranking system to meet the needs of the audience (parents) would be beneficial e.g.
 numbers system, 1-10< similarly letters A-E as suggested, keeping the assessment simple e.g.
        Proficient
        Not yet proficient (Commitment to proficiency)
        Not proficient
 The rating system
    What potential risks are there in introducing a rating system? How could potential negative
     implications be minimised?




                                                                                                                     6
    There are risks to those centre that fail to meet the standards financially, but there are more benefits for all,
     families/children/staff where services offer a quality service.

    One risk could be for those services that only achieve a satisfactory rating and continue to do so, with no
     imposed penalties and currently there are no requirements for advancement in increasing their standard.

    New centres may not be able to attract clients due to not meeting the rating standards in their initial set up
     periods- impacting on their viability in the market place.

    Another consideration might be to have a voluntary system, (as seen internationally) where services submit
     their centres for a rating to show they are committed to providing quality early years services and
     continually working to improve their quality.



Coverage

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?

The implications are stated clearly in section 6.1.5.

One rating system would have built in flexibility/adaptability to cater for all early childhood services. The
accreditation system of the NCAC has raised the level, expectations and understanding of quality for both staff
and families and has the ability to work across all levels of early childhood.



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

 Potential impacts are clearly identified in 6.1.5.


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?
      Support for staff/service management/ families.
      Strategies to ensure Parents value and recognise their roles in quality standards.
      Adequate and timely marketing/consultations with parents/communities/early year’s teams/management
      Clear quality standards/expectation /timelines
      Governance and delivery arrangements with reasonable timelines to establish basic to high           quality
      ratings during the transition phase, to prevent duplication the framework could work in clusters (where there re
      many centres in a region) to develop their accreditation documents, rather than centre by centre.
      A staggered approach through the year would prevent all services having to be all registered on the on the
      same date each year.




                                                                                                                         7
    What timeframes are required to allow services to transition to a new rating system?
    Initially Eighteen months – 3 years transition and up to five to ten years for consolidation – not all services
    coming up for accreditation at once.




         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?


Inconsistent standards/child/staff ratios across Australia
Inconsistent regulations and interpretation occurring with current NCAC field validators.
Inconsistent response times for information/results/ feedback to the services of the QA outcomes.
Not all centres are accredited in Australia


    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.

     The Governance and delivery inclusions on page 22, address a clear regulatory approach improvement. New
        compliance mechanisms, will promote a greater accountability against the standards. W e endorse the listed
        possible considerations examples

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.

    Transitions to a new system


    The same as for the rating system - Eighteen months – 3 years transition and up to ten years for consolidation
    – not all services coming up for accreditation at once.




    NQF4 - Workforce
    Workforce
           How could the status and recognition of the early childhood education and care workforce be
    raised?
    Provision of funded consistent relevant training/ongoing
    Funded support structure/training for volunteer early childhood workers
    Funded support staff to mentor, monitor and support staff in early year’s services




                                                                                                                      8
    Wage parity (LDC (four year qualified)/preschool teachers with early year’s primary teachers). Support all
early years’ staff (not only preschool staff) to attain self-validation and have the opportunity to reach an
accomplished /exemplary standard.
       What could be done to address limited advancement options and career paths?
            Ease of access to training. Develop a training relationship with local TAFE to support
undergraduate training e.g. all pre-school assistants and also to support ongoing early childhood training for
appropriate evidenced based professional development.
       What possible approaches could be used to improve retention strategies?
      Governments to develop funded pathways which support career advancement within family and
children’s services/management.
       Provision of financial support to encourage career advancement – HECS subsidy



    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?)

   There are benefits in each of these approaches; however to underpin the framework, a philosophy
   would need to be responsive to the community, incorporating social inclusion and diversity. It would
   also need to promote a collaborative program design with services working together with children and
   families and one that would promote play experiences as the best vehicle for learning for children 0-6
   years.

   The philosophy would also embrace parents as the child’s first teachers and one which provided
   further support to their knowledge and understanding of play and the play experiences that are
   relevant to the child (in relation to his/her individual, family and community strengths, needs, and
   experiences).


   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?

   The Hume Early Learning Essentials format has adopted domains of learning linked to the Victorian
   Essential Learning Standards (VELS),(contained within three core and interrelated strands) to
   underpin its framework. These strands have a number of distinct domains of interrelated areas of
   knowledge, skills and behaviour of children, considered essential in their education and development.

   This framework embraces play as the essential vehicle to support these domains, with a strengths
   based approach to planning and is used as a guide to encourage a consistent, high quality approach
   to program design.

   The framework acknowledges the importance of children’s development (birth to 6 years) and
   ensures families can be confident that a framework exists which promotes opportunity for learning
   and development in all of our early childhood centres.

   The framework format for program-planning has five pages, which addresses a practical approach to
   provide a clear link between observation, objectives and strategies to promote the learning
   objectives of the children through play experiences, and the evaluation.

   It is not prescriptive, but follows a format process to allow for individuality, complexity, consistency
   and at the same time meeting the program planning objectives.




                                                                                                                 9
What type of supporting documents/resources would be most valuable for parents and others
working with young children (e.g. family day carers, playgroups)?

The Hume framework provides a booklet, which explains the philosophy, underpinning values and
VELS strands /domains. This is handed out to parents at the beginning of the year in both preschool
and Long day care. Parent partnerships are both formally and informally encouraged with each
parent provided with an example of the objectives and Program Plan for their child each term and
asked to provide written comment and contribute suggestion/ideas to support their child’s potential
learning outcomes.
Translated letters/interpreter services are also provided for some CALD families.

Portfolios are also linked to the Framework to further supported potential learning outcomes and aim
to provide a summary of learning outcomes at the end of each year and to support school transition.

Do you have any views on the format and size of such documents

Whist the Hume format continues to be evaluated, the current format of 5 pages has provided
consistency, continuity, has contributed to a more streamlined approach to this application and well
embraced by staff.

Do you see any issues with the implementation of the Early Years Learning Framework in all
education and care settings from July 2009?

A great deal of work would be required to do this from July 2009 across Victoria, however from our
experience with the implementation of the Hume Early Essentials, we would be in a good position to
implement the Early Years Learning Framework in all education and care settings from July 2009 and
we welcome the opportunity to participate in a pilot study and also to share our journey and data from
our own experience of implementation of the Hume Early Learning Essentials framework
A roll out of this size would need provision of funded relevant training, support materials/mentoring
/support/monitoring/ staff and other resources.
At both local and state levels there would need to be an extensive advertising/marketing campaign
through the early years sectors, which not only promoted and reflected this vision for learning, but
also to inform parents about the importance of brain research, the benefits of early learning on brain
development and the important role that parents play in their child’s learning.

As mentioned earlier we implemented the Hume Learning Essentials over an 18month period;
however there is still much professional development to further support and resource the staff.

 What suggestions would you offer to overcome these issues?

Ongoing staff support, extra time for planning, increased funding for support staff and increased
resources eg People/equipment –computers/paper/photocopier. Practical resources to support the
implementation of expected observation/objectives.




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

Current research findings/analysis is accurate and comprehensive into the insights of contemporary
early childhood education. It not only reflects the multidisciplinary nature of the early childhood field,
but also the relationships between educators and children, including their families. It demonstrates
the importance of children’s wellbeing when in care, the quality of the social interactions between a
child /other children and carer and the importance of building secure attachments with the carer in
supportive environments.

Do you support a focus on language and communication development, social development


                                                                                                             10
 and play-based learning in the framework?


 Yes. The research on offering language, literacy and social opportunities through real-life
 experiences is extensive, particularly the importance of the early years in the child’s development
 and future success. The evidence provides us all with ways to extend the way we think about our
 practices, our early childhood philosophies/concepts/theories etc and also the way in which we can
 work with families to support the learning outcomes for their children.

 The focus on early communication/language development/early literacy begins at birth and needs to
 be a strong focus of the framework through Maternal and Child Health services to support families.
 The MCH service could also be underpinned by the Early Years Learning Framework standards to
 support communication development, social development and play-based learning from birth.
 How would you define the roles of the educator and the child in the learning process in the framework?
 The roles of the educator and the child within the learning process should be one of respect of the
 child, active participation and engagement with the child and a positive relationship with the parent to
 facilitate the learning process.




EYLF3 - Foundations for the framework

 What would you want included in the framework’s vision for early learning and children?
 A philosophy that has a belief in children’s learning, that places value on the parent’s role as the
 child’s first teacher and that values the teacher to facilitate the two.

 Would you support the values and rights proposed to underpin the framework?

 We endorse the inclusions in 11.3

 What other values and rights would you want included and why?
 Extending and building positive community networks, increased parent support and partnerships and
 consistent transition to school approaches between preschool, LDC and local primary schools.




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?
 Additional staffing support and funded professional development to support examples of best
 practice
 Additional resource materials in other languages particularly for CALD families and access to
 resources
 Funded additional support structures / strategies to increase CALD parent participation in particular
 demographic areas. This would need to include additional administration costs to provide
 interpreters/translated information/ translation of policies and procedures.
 Is it appropriate for children are learning to be assessed? If yes, how should children’s
 learning and development outcomes be assessed?
 We believe a summary of the child’s learning outcomes is more appropriate and this can be achieved
 and communicated through documentation in the Port Folio. This summary of learning can be
 generated both through the parents contribution to the portfolio and the teacher’s observations and it


                                                                                                            11
can also be a conduit of communication from the parent to the school.
How would you ensure the curriculum framework is appropriate for all educators, regardless
of qualifications?
The curriculum framework would need to be very clear about its objectives to address the importance
of the early years to all providers of early years care and education. Given that 39% of the current
early childhood workforce in long day care has no formal childcare qualifications, we need to ensure
that the framework is flexible enough to meet the standards requirements, has the capacity to
support all carers of children and has the ability to evolve as qualifications are increased.

What kind of professional development will need to be provided in order to support educators
in using an Early Years Learning Framework?
Additional staffing support, including a mentor support network during implementation of the
framework and adequate meeting and professional support.




                                                                                                       12