Consultation on a
Revised Early Years
Foundation Stage
(EYFS)
Consultation Response Form
The closing date for this consultation is: 30
September 2011
Your comments must reach us by that date.
THIS FORM IS NOT INTERACTIVE. If you wish to respond electronically
please use the online response facility available on the Department for
Education e-consultation website
(http://www.education.gov.uk/consultations).
Information provided in response to this consultation, including personal
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access to information regimes, primarily the Freedom of Information Act 2000
and the Data Protection Act 1998.
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Name
Organisation (if
applicable)
Address:
Carol Kimberley
Cornwall Council
Children, Schools and Families
Cornwall Council
West Wing, Floor 2, Council Offices, Dolcoath Avenue,
Camborne, TR14 8SX
If your enquiry is related to the policy content of the consultation you can
email: revisedeyfs.consultation@education.gsi.gov.uk
If you have a query relating to the consultation process you can contact the
Consultation Unit on:
Telephone: 0370 000 2288
e-mail: consultation.unit@education.gsi.gov.uk
The consultation questions are in four sections, following the format of the
revised draft EYFS framework. The four sections are:
1. The introduction to the EYFS, which describes its overall aims and
principles.
2. The learning and development requirements. This section explains what
all early years providers must do to support young children's learning and
development. It includes the early learning goals, which describe the things
that most children should be able to do at the end of the year in which they
turn five.
3. The assessment arrangements, which explain how providers
should observe, report and plan for children's progress.
4. The safeguarding and welfare requirements, which specify what providers
must do to keep children safe and healthy in early years provision.
Please tick one category that best describes you as a respondent.
Parent/Carer
Maintained
School
Childminder
Nursery
Early Years Sector
Representative
PreSchool/Playgroup
Play Sector
Independent School
Yes Local Authority
Breakfast/Afterschool
Club
SEN
Provision
Please Specify:
This response is based on a consultation held within Cornwall. Practitioners
in the PVI and maintained sectors were asked if they would like to contribute
their views, as were colleagues in the advisory service and early years
improvement team. Staff in the inclusion team, children centre teachers, and
childcare support assistants who specialise in supporting settings with
welfare requirements all responded.
Whilst most replies were received from Local Authority staff, the few schools
and settings that did give feedback shared largely similar views.
This response summarises those shared views.
Introduction
The introduction to the EYFS describes its overall aims and principles.
The Government agrees with the Tickell Review findings, that the aims
and principles should remain in place, but that the EYFS overall could
be simplified and shortened.
1 Is the introduction to the revised draft EYFS, and the explanation of its
principles, clear? If not, what changes would you suggest?
Yes
X No
Not Sure
Comments:
There was concern from every sector at the use of the term “school
Readiness”. It was felt that there was a lack of clarity with regard to the use
of this wording and that this had the potential to mislead practitioners in to
thinking a more formal, academic approach would be required when
preparing children for school. It was also felt that a focus on the term “school
readiness” would imply that the child’s earliest years, from birth to two, were
less significant.
A typical response from the PVI sector was as follows:
“I am very concerned about the term ‘school readiness’ and what this might
look like in practice. The principles are clear but need further explanation.
How are you going to ensure ‘quality and consistency across early years
settings’ given the disparity between settings?
I do not like the term ‘educational programme’ for pre-school children this will
confuse many parents and reinforce the myth that children need to be taking
part in academic activities such as reading and writing when they are not
ready to do so.”
The term “school readiness” could also be a term that would be particularly
inappropriate for children with individual needs who may not be “ready for
school”. Due regard should be given to the responsibility on schools to be
“child ready”. (DDA, NC inclusion statement, SEN Code of Practice).
One AST suggested that a more appropriate term to use would be “ready
for transition” or “ready for the next stage” which would be more inclusive
and could be applied throughout the EYFS.
It was also felt that the principles were quite different from the previous
framework e.g A positive environment’ (mainly related to emotional
environment repeating principle 2) rather than the preferred ‘enabling
environment.
We are very concerned that the proposed simplification will be insufficiently
supportive for new or inexperienced practitioners. Lack of clarity will mean
that increased training will be needed for practitioners and consistency of
practice could vary widely.
Section 1 - Learning and Development Requirements
This section of the EYFS explains what early years providers must do to
support young children's learning and development.
The Tickell Review recommended some changes to the EYFS areas of
learning and that these should be in two categories: three prime areas
which reflect the essential foundations all children need if they are to
develop further: and four specific areas in which the prime skills are
applied. The revised draft EYFS also suggests the broad areas of focus
for educational programmes in each area of learning.
The early learning goals describe what most children should be able to
do by the end of the year in which they turn 5. The Government agrees
with Dame Clare Tickell, that there are more goals than is necessary or
useful in assessing children's progress in the current EYFS.
Accordingly, the revised draft EYFS reduces the number of early
learning goals from 69 to 17.
The Tickell Review also suggested that the learning and development
requirements should not apply in full to settings where children spend
limited time, outside school hours - for example, holiday and
wraparound care. The revised draft EYFS suggests that where children
attend more than one setting that providers should work together, with
parents, to determine how they can most appropriately support that
child.
2 Do you agree with the proposals that there should be three prime areas of
learning and development? The three prime areas are: personal, social and
emotional development; physical development; and communication and
language (paragraph 1.3).
Yes
Not Sure
No
Partly
Comments:
There was support from all sectors and practitioners that these prime areas
have been suggested. It was felt that existing programmes such as the
CLLD programme and ECAT work had demonstrated the importance of
these areas of development and the impact of these prime areas on
improving outcomes for children.
However some concern has again been expressed at the formal,
educational use of the language in this section:
“Reads more like a 7-11, KS2 curriculum”
Practitioners will need more clarity and further explanation about the
relationship between the prime and specific areas.
3 Do you agree with the proposals that there should be four specific areas of
learning and development? The four specific areas are literacy; mathematics;
understanding the world; and expressive arts and design (paragraph 1.4).
Yes
Not Sure
No
Partly
Comments:
The majority of respondents felt this was a sensible move, however there
are some specific concerns over the vocabulary used.
A concern throughout is that the document is separating out provision for 0-2
year olds. Practitioners all welcomed a seamless document that had
examples related to all ages and stages of child development. Several
concerns have been raised that the document reads as if it is a “curriculum
and assessment tool” only and is losing the detailed guidance that had
helped raise standards so much within EYFS.
4 Paragraph 1.6 explains how learning in the prime and specific areas should
be supported. Is this a clear explanation? If you ticked no, or not sure, please
say how this could be clarified.
Yes
x No
Not Sure
Comments:
It is not clear at what stage and in what ways the educational programmes
change and how this relates to children’s development. Further clarification
and/or case studies need to be provided.
More focus on inclusion and adapting the curriculum and environment to
meet individual children’s needs would encourage a more inclusive ethos.
There should be an emphasis on the responsibility of the setting and
practitioner to meet individual children’s needs before asking for specialist
support.
The reference to talking to parents if there are concerns is welcomed,
however, talking to parents (and children in order to hear their views) needs
to be ongoing good practice throughout the child’s time in the EYFS. This
must be part of general good practice.
The continued emphasis on the prime areas where children’s progress is
causing concern has been welcomed.
Early Learning Goals
We are proposing to reduce the number of early learning goals from 69 to 17.
The 17 Goals are all covered by the 7 areas of learning and development (3
prime areas and 4 specific areas). Appendix 4 of the revised draft EYFS
describes the detailed content of the goals, which practitioners and teachers
would use to assess children's development and achievement.
For each of the 7 areas of learning and development listed below in 5 a) - g),
please say whether you agree with the early learning goals which relate to
them.
A. Prime Areas of Learning and Development
5 a) Personal, social and emotional development: Self-confidence and
self-awareness, Managing feelings and behaviour, Making relationships
Yes
No
Partly
Not Sure
Comments:
A general view has been that paperwork will not be reduced with the
proposed changes to ELGs.
The overall content of the proposed ELG’s has not been reduced in terms of
what needs to be assessed but has instead been amalgamated.
Practitioners will not find this helpful and it is felt that they will need to split
the ELG’s up into component parts when assessing children and find it
difficult to make a final judgement against an ELG.
The clarity regarding cultures and beliefs has been welcomed.
For children with poor speech and language skills consideration should be
given to the wording within this section. There is an emphasis on “talk” and
this could be changed to “communicate”.
Staff supporting children with individual needs feel strongly that some of the
descriptors need further qualifying statements. This could enable smaller
steps to be identified for children and hence greater achievement could be
identified for some children.
5 b) Physical Development: Moving and handling, Health and self-care
Yes
No
x Partly
Not Sure
Comments:
The terms “ gross and fine motor control” need to be separated. This will
help Y1 teachers to build on the children’s needs. The terms gross and fine
motor control are better descriptors of children physical skills than the word
“handling”.
Some children will not be able to use the toilet independently when they
reach the end of the EYFS due to a disability. This needs to be recognised.
5 c) Communication and Language: Listening and attention, Understanding,
Speaking
Yes
Not Sure
No
x Partly
Comments:
With regards to Speaking there appears to be inconsistency in progression
e.g. for the ELG ‘showing awareness of listeners needs’ but for exceeding
‘shows some awareness of the listener’.
Consideration should be given to clarity of speech /expressive skills ,
however for some children communication may be through different means
and so this should also be referenced.
B. Specific Areas of Learning and Development
5 d) Literacy: Reading, Writing
Yes
No
x Partly
Not Sure
Comments:
As before, the overall content of the proposed ELG’s has not been reduced
in terms of what needs to be assessed but has instead been amalgamated.
Practitioners will not find this helpful and may need to split the ELG’s up into
component parts when assessing children therefore finding it difficult to
make a final judgement against an ELG.
Local data suggests that the pitch of former ELG’s for writing is higher than
other ELG’s. This apparent difference in pitch has not been addressed.
Further exemplification and explanation is required for some parts of the
ELG e.g what constitutes a simple story?
Many practitioners commented on the lack of clarity with these proposals
and felt that the previous EYFS Effective Practice guidance was extremely
valuable in providing for a comprehensive understanding of the
developmental stages that children would go through prior to attaining ELGs.
It was felt that this type of guidance should not be lost.
5 e) Mathematics: Numbers, Shape, space and measures
x Yes
No
Partly
Not Sure
Comments
Using the title ‘mathematics’ will aid parents understanding of this area.
Absorbing calculating into numbers will ensure practitioners and parents
make links between these former strands. Introducing ‘time’ and ‘distance’
will help with transition into KS1.
5 f) Understanding the World: People and communities, the World,
Technology
Yes
No
x Partly
Not Sure
Comments:
The heading ‘People and Communities’ is a positive change. It is helpful that
the phase ‘cultures and beliefs’ has been replaced with families,
communities and traditions’.
The content under the heading The World has not been reduced.
It was felt that the language used should, where possible, reflect that of the
original EYFS documentation – for example in “Understanding the world” the
term “experiments” is used and this could be replaced by “investigations” as
per the original EYFS document.
5 g) Expressive Arts and Design: Exploring and using media and materials,
Being imaginative
Yes
No
Partly
x Not Sure
Comments:
The ELG’s in this area are too broad to accurately describe a child with
specific preferences or skills e,g a musically gifted and talented child. In
order for children’s individual areas of interest and skill to be noted and
planned for, some further qualifying statements need to be developed.
5 h) Do you agree that the early learning goals define clearly enough what
children should be able to do by the end of the school year in which they turn
5? If you ticked no, or not sure, please indicate which goal(s) you consider
unclear and suggest how the goal(s) could be clarified.
Yes
No
x Not Sure
Comments:
We preferred the previous ELG’s although more in number they were easier
for teachers to decide if they had been achieved or not.
The lack of practical examples/case studies for the ELGs and the broad
statements used, is likely to mean that assessments will not be sure and the
moderation of EYFS outcomes will be problematic. This may well result in
the need for increased training and support for teachers at LA level.
The Government is keen to ensure that the EYFS helps ensure children's
English language skills are sufficiently developed to allow them to take full
advantage of Key Stage 1 and the opportunities that schools offer. It also
recognises that bilingualism is an important asset conferring positive
advantages for children's learning and development. The revised draft EYFS
tries to strike a balance between supporting children's overall language
development, and ensuring appropriate opportunities are provided for children
to reach a good standard of English and be ready for school. It also seeks to
ensure that the assessment requirements appropriately measure children's
progress in English, taking due account of the needs of children who have not
had the appropriate time or support to develop their English language skills.
6 Does paragraph 1.7 of the revised draft EYFS get the balance right?
Yes
No
x Not Sure
Comments:
This is a vision for good practice however there is no guidance within this
for how providers will fulfil the requirement to develop and use child’s home
language and support their language development at home. Most providers
will find it difficult to meet this requirement.
The advantage of the former EYFS practice guidance was that it gave
practitioners additional effective practice guidance, support and resources.
The proposed new document is such a slimmed down proposal that in effect
it has become a statement of intent but lacks detail, definitions and any
depth of guidance for practitioners.
7 The EYFS requires providers to support children through planned,
purposeful play. The Tickell Review recommended that this requirement
should be explained more clearly. Do you agree that paragraphs 1.10 and
1.11 of the revised draft EYFS clearly outline expectations of the approach
practitioners should take to supporting children's learning?
Yes
x No
Not Sure
Comments:
The majority of responses seek further clarification about this, particularly
due use of the phrase ‘this will move increasingly towards adult-led learning
as children start to prepare for reception class. This is felt to reinforce the
notion that this document seeks to move to a more formal EYFS.
The statement below is typical of the responses from practitioners who are
seeking clarification:
“.. the part about moving towards more adult led activities as children near
school entry is worrying, how much will Ofsted inspectors expect to see and
is this appropriate?
‘Planned purposeful play’ is still a rather odd statement, we need to plan the
environment we cannot plan the play itself as it must come from the children.
Children learn at the highest level when they play but it cannot be forced
upon them and must be through their interests.”
8 a) Paragraphs 1.14 - 1.15 explain the learning and development
requirements for settings where children spend a limited amount of time,
outside school hours - for example, holiday and wraparound care. Do you
think these paragraphs contain appropriate requirements for wraparound and
holiday providers? Please explain.
Yes
No
x Not Sure
Comments:
There is broad agreement with this section with the proviso that EYFS
welfare requirements and staff ratios are considered for the youngest
children.
The reference to greater liaison between settings and other professionals
has been welcomed.
However, Ofsted will need strict criteria to inspect against in order to have a
consistent national response to this.
8 b) Are the requirements explained clearly?
Yes
x No
Not Sure
Comments:
See above
Section 2 - The Assessment Arrangements
There are two types of assessment in the EYFS. The first is formative
assessment which practitioners should use on an ongoing basis to
identify children's needs and plan activities to meet them and support
children's future progress. Careful observation is particularly important.
Many people who responded to the Tickell Review were in favour of
continuing to require this type of assessment, although some people
expressed concerns about the paperwork that was associated with it. It
appears that paperwork may often be a response to perceived
pressures, or reflect practitioners' own training needs, rather than the
requirements of the EYFS. The revised draft EYFS retains the
requirement that practitioners undertake on-going formative
assessment but aims to make clear that the paperwork associated with
assessment should be limited.
9 Paragraph 2.2 aims to discourage practitioners from completing excessive
levels of paperwork. Do you think these paragraphs would achieve this aim?
Please explain.
Yes
No
x Not Sure
Comments:
It would be helpful if the guidance gave exemplification for documenting
assessments. In addition there should be more emphasis on documenting
significant learning rather than information that practitioners already know
about children’s learning.
Practitioners find Cornwall’s local guidance helpful.
10 Do you have any further comments on paperwork associated with the
formative assessment of children's learning and development?
Yes
No
Not sure
Comments:
See above
The second type of assessment is summative assessment, in which
practitioners step back and record what children can do across all of the
areas of learning, to review their progress at a given point in time. This
includes an assessment of children's achievements, and the extent to
which progress is as expected, against benchmark standards. It is
useful for parents as well as early years practitioners in understanding a
child's level of development, and in supporting their future learning and
development.
Currently, the only summative assessment required by the EYFS is at
the end of the year in which children turn 5. It is called the EYFS
Profile. A significant number of people have raised concerns about the
EYFS Profile in its current form. Some respondents to the Tickell Review
felt that it was not challenging enough for more able children but was
too challenging for some other children - including children born
in June, July and August, who will be the youngest in their school
year. Many early years practitioners also highlighted that the EYFS
Profile is not always used by Year 1 teachers (teaching pupils aged 5-6
years), owing to the lack of connection between the content of the EYFS
Profile and the National Curriculum.
It is proposed that:
a. the EYFS Profile is slimmed down to reflect the proposed (reduced) 17
early learning goals;
b. ‘emerging' and ‘exceeding' bands are included in the assessment
measures, to help identify clearly where children are working towards or
have gone beyond the goal. This aims to provide clear information on
children's progress for parents and to help Year 1 teachers to support
very young children, gifted and talented children or children with
additional needs;
c. the wording of the goals is amended to fit more clearly with the goals
of the National Curriculum (and the wording of the National Curriculum
will be considered in relation to appropriate continuity with the EYFS).
11 Do you think the revised draft EYFS Profile would provide an improved
vehicle for capturing the essential information about a child's development at
the point at the end of the EYFS? Please explain.
Yes
Not Sure
x No
Partly
Comments:
The larger number of ELG’s in the current EYFS Profile gives a more precise
and in-depth profile of what a child can do, allowing Y1 teachers to plan a
more appropriate curriculum.
However for children with individual needs there is nowhere on the EYFS
profile to record the development of children below the 24 month level (other
than to tick the ‘emergent’ box). This would give no clear indication of the
level of development of a child with more complex needs
12 Do you agree with the content of the 'emerging' and 'exceeding' bands?
Please explain.
Yes
Not Sure
No
x Partly
Comments:
The emphasis on links to year 1 have been welcomed however, clear
guidance about the evidence to be provided and the moderation process will
be needed.
13 Do you agree that the terms 'emerging', 'expected' and 'exceeding'
appropriately describe levels of progress? Please explain.
X Yes
No
Partly
Not Sure
Comments:
The terminology was welcomed by all sectors.
14 The revised draft EYFS asks practitioners to supplement the Profile and
give Year 1 teachers a short commentary on each child's skills and abilities in
relation to the three characteristics of effective learning (paragraph 2.7). Do
you agree this is helpful? Please explain.
Yes
No
X Not Sure
Comments:
Greater clarification is needed about the commentary that should be
available for year 1 teachers.
15 Do you have any further comments on the proposed revised draft EYFS
Profile?
Yes
X No
Not Sure
Comments:
Early years settings have a duty to collect EYFS Profile data and provide
it annually to their local authorities. Local authorities need to provide
this annually to the Government. These duties will remain.
The Government has also considered the difficulties which can be
experienced by children if they need additional support and their needs
are not identified at an early stage. For many children, identifying their
needs at age 5 is not soon enough to help them catch up to be
successful learners in school. In response to this, building on Dame
Clare Tickell's advice, we propose that a summary of children's
development is provided to parents when their child is aged between 24
- 36 months. This must cover the prime areas of learning. Its purpose is
to identify where children may need some additional support and to help
practitioners work with parents and others to provide that tailored
support. It is for practitioners to decide what the summary might include
beyond the above requirements, reflecting the development needs of
each individual child, and to decide on the format for the report.
For the longer term the Government is exploring the feasibility of a
single integrated review at around age 2 (as recommended by Dame
Clare Tickell), in which health and early years providers jointly assess
children's progress, and work together, and with parents, to plan
tailored support as appropriate. This would build on and strengthen the
progress review we propose to introduce for September 2012 (as
outlined above) to help ensure all children reach a good level of
development at age 5 and are ready and able to learn in school.
16 Do you agree there should be a requirement for providers to give parents a
written summary of their child's development in the prime areas when their
child is 24 - 36 months (paragraphs 2.3-2.4)? Please explain.
Yes
No
X Not Sure
Comments:
A training and moderation programme will be essential to enable
practitioners to complete this effectively.
A concern from all sectors is that assessment and feedback to parents
should be ongoing from birth and that this should be essential practice at all
stages of the EYFS.
17 Do you have any further comments on the 24 - 36 months summary of
development?
Yes
No
X Not Sure
Comments:
What if children do not start until the term in which they are three? How will
practitioners provide a summary of development for parents?
The assessments should be made nearer to 24 months so that it can inform
the health visitor review.
This is a very broad brush description of where a child should be at this age.
There needs to be an emphasis on using other evidence and knowledge and
understanding of children’s development.
All sectors have expressed concern at the removal of the Development
Matters statements for birth to 24 months which suggests that practitioners
do not need to be aware of this crucial stage of development.
The Tickell Review recommended that the EYFS should be clearer about
how children with special educational needs should be assessed.
18 Do you think that paragraph 2.10 of the revised draft EYFS is clear in
relation to the assessment of children with special educational needs?
Yes
X No
Not Sure
Comments:
There is no indication of how to record the attainment of children who are
below ‘emerging’ in each of the ELG’s, nor any indication of how to share
children’s progress with parents of children with SEN.
It is particularly important to illustrate what are currently the first three
phases of development of the EYFS. If this is not included, practitioners will
focus on older children and those without SEN.
There needs to be clear guidance about how you record the
progress/developmental levels for children who have severe and complex
learning needs and have not reached 24 months before the end of the F
Stage.
The previous Early Support sections of EYFS are valuable and need to be
retained.
19 Do you have any further comments on the assessment of children with
special educational needs?
x Yes
No
Not Sure
Comments:
The EY Inclusion Service in Cornwall appreciates the current system as all
children are included at the relevant phase of development and practitioners
have clear guidance re ‘next steps’.
Section 3 - Safeguarding and Welfare Requirements
This section explains the requirements that all early years providers
must meet, in relation to children's safety and welfare. In the main, the
current welfare requirements were supported in responses to the Tickell
Review. The revised draft EYFS aims to simplify and clarify existing
requirements. It also provides additional guidance on child protection.
20 Do you agree that the safeguarding and welfare requirements are set out
clearly and cover the right areas? Please explain.
x Yes
No
Not Sure
Comments:
3.13 States providers other than childminders must obtain enhanced CRB
check, (query why childminders not included).
3.15 Providers must record, where relevant, the CRB reference number etc
(don’t see where relevant should be included, should always be recorded)
3.44 Providers must keep a written record each time medicine is
administered, and inform parents on the same day or as soon as reasonably
practicable. (I think this should be removed, child must be collected so
someone can be informed at that time)
3.51 Where action taken was taken for the purposes of averting immediate
danger of personal injury needs to add details of the incident must be
recorded, parent informed and signature on the same day.
3.54 Providers must produce and implement a written procedure for
assessing any risks and review risk assessments regularly (how is regularly
defined – suggest at least annually, more often if any changes)
3.56 Providers must have appropriate fire detection and control equipment
(for example fire alarms, smoke detectors and fire extinguishers). There
could be an emphasis that all providers having smoke detectors and fire
blanket if cooking facilities plus additional equipment if necessary).
3.59 Sleeping children must be frequently checked (suggest checks logged
for under 12 months)
3.63 Providers must have an agreed procedure for checking the identity of
visitors (and log)
3.64 The risk assessment for outings does not have to be in writing. A new
and/or written risk assessment will not be necessary in every instance for a
repeat outing or journey. (Suggest removal of the risk assessment for
outings does not have to be in writing).
Notes to Local Authority
3.6 Policy for clear policy on the use of mobile phones and cameras new to
welfare requirements, we have already suggested and supported on this to
settings visited, not sure about countywide.
3.18 Possibly training required to support expectations of supervision, these
have increased, now to include:
 Support, coach and train practitioners and promote interests of
children
 Foster a culture of mutual support, teamwork and continuous
improvement which encourages the confidential discussion of
sensitive issues, whistle blowing
 Discuss issues and difficulties
 Identify solutions to address the
 Be coached in tackling issues as they arise
3.23 Childminders will have to attend LA approved training to help them
implement and understand EYFS before registering was previously within six
month. ?Re-introduce session 3 or ensure diploma in home based care
available soon after pre reg.
3.30 For children aged under two, at least half the staff must have received
training that specifically addressed the care of babies. County needs to
provide training – e.g. SEAD.
3.45 Now in group provision, staff preparing or handling food must receive
food hygiene training (previously said prove they are safe to handle food).
There is constant access to courses through distant learning options, include
this in training directory.
.
21 The requirements for staff training on safeguarding now include examples
of inappropriate staff behaviour which are warning signs for the possibility of
child abuse (paragraph 3.9). Do you think this will better equip staff to take
action to protect children where necessary? Please explain.
x Yes
No
Not Sure
Comments: However, it is essential that a robust Safeguarding (Child
Protection) Policy is in place which includes Whistle blowing and that this
and the Procedures are shared with staff as part of the Induction process.
I also feel that it should be statutory for all staff to attend or complete basic
Safeguarding Awareness training in addition to training in the Setting’s
Policies and Procedures and that training should be completed on/following
appointment or within 6 months. Set timescales should also be in place for
updating training. Training and Induction of staff/new staff should also be
done verbally and not just through handing over of paperwork, which might
not be read or understood properly.
It should also be statutory that a Designated Person for Safeguarding is in
place on a Management level e.g. Committee Chair and that training is also
compulsory. This would ensure there is always another person that a
member of staff can go to for reporting concerns regarding the
actions/conduct of a member of staff, possibly the Designated Person.
22 Do you think that the requirement for staff supervision (paragraph 3.19)
would help leaders and managers support their staff and keep children safe
from harm? Please explain.
X Yes
No
Not Sure
Comments: : I think it should be statutory that Leaders and Managers
attend/complete approved training for this; otherwise it will not be effective,
especially within voluntary Committee led Settings.
23 The current EYFS sets a lower age limit of 17 for people looking after
children unsupervised whilst the General Childcare Register (GCR) for those
looking after older children sets a minimum age of 18. We think that it is
important that our youngest children should be looked after by responsible
adults. We therefore propose that only those over the age of 18 should be
counted in ratios for both the EYFS and the General Childcare Register. Do
you agree that we should raise the age limit in the EYFS?
x Yes
No
Not Sure
Comments:
24 Childminders have previously been allowed six months to complete their
training after registration. This means that they can look after children without
having been trained in the EYFS. Do you agree that childminders should be
trained to understand fully the requirements of the EYFS before they can
register and look after children? Please explain.
Yes
X No
Not Sure
Comments:
We think that it is important that childminders should have some training on
the EYFS however in practice this would be difficult to fulfil.
In all other childcare settings, Managers are required to be qualified to Level
3 (full and relevant) and ½ of all other staff Level 2 and the Manager is
required to have at least 2 years experience. Although childminders are
required to attend Unit 1 of the Home Based Childcare (Level 3) and Level 2
Food Safety (LA) this currently does not have to be completed before
registration. The majority of childminders with whom I have worked have no
previous experience of working with children or any formal childcare
qualification. They also will not have completed training for Safeguarding
(Child Protection) observation, assessment and planning etc.
Although they are required to attend Pre-registration briefing sessions, which
include basic information and activities regarding the Welfare Requirements
and a 3rd session which covers an overview of EYFS, it is not always
possible to cover either in depth. The majority of childminders I have visited
have either no systems in place to carry out observations assessment and
planning or do not have a confident understanding of how to do this, as they
have no formal childcare qualification or basic child development knowledge.
Childminders are vulnerable as they work alone, therefore the more training
and information we can provide pre-registration the stronger their practice
thus improving outcomes for children.
25 a) Paragraphs 3.54 and 3.64 explain the requirements for risk
assessments by settings. Do you think the explanation is clear? Please
explain.
x Yes
No
Not Sure
Comments:
I think it is clear regarding overall risk assessments and makes it clear that
regular checks etc by named persons should be made e.g. Daily safety
check. However, for outings I think it is confusing and woolly. Why would a
risk assessment not be written and used as a working document? Where is
the evidence if something goes wrong? I feel it is really important to have
written risk assessments in place for all outings and then a simple system to
demonstrate that it has been carried out each time, dated and signed and
any problems identified and the action taken and any further actions needed.
It is possible to do this simply and effectively and safeguards the Provider
(especially childminders) in addition to the children
25 b) Do you think this would help providers keep children safe without
completing unnecessary paperwork? Please explain.
Yes
No
X Not Sure
Comments:
Practitioners will require further guidance from the LA!
The safeguarding of children should always be paramount. It is possible to
have simple effective systems of record keeping in place without reams of
paperwork. I think Providers will become blasé and not consider what is risky
and what isn’t. Risk assessments can be a positive practice and can include
the benefits of risky play/activities etc. Risk assessments make staff aware
of possible dangers and can empower them to make decisions on how to
minimise risks and necessary actions, if carried out in a positive manner.
26 Do you have any further comments on the safeguarding and welfare
requirements?
Yes
X No
Not Sure
Comments: : I am disappointed that the following areas have not been
tightened up in the light of recent high profile cases:CRBs in place before a person is allowed to begin working with the children,
Requirement to update CRBs regularly e.g. every 2-3 years.
Ratios- these are now across the whole setting at the discretion of the
manager. This really worries me, in the light of recent events. I have already
had concerns regarding lone working in a baby room, where a member of
staff was left alone for the majority of the day with no proper checks carried
out or viewing area used effectively. I think this will increase and is a real
concern.
Also:Qualifications- disappointed that this has not been tightened. It does not
include the requirement any more for Supervisors to have a Level 3 and still
does not require a Deputy to have a Level 3.
Childminders- still no restriction on ratios of over 8s.
Inspection Arrangements
Ofsted inspection assesses how well providers meet the standards of
the EYFS and Ofsted publishes inspection reports on its website.
If providers breach any of the welfare requirements Ofsted can issue a
Welfare Requirements Notice. If providers do not comply with the
Welfare Requirements Notice by the date specified, then Ofsted can
cancel the provider's registration and prosecute as they judge
appropriate.
There are some breaches of requirements which can lead to immediate
prosecution without a Welfare Notice first being issued. These are
detailed at (paragraph 3.79 and 3.80) of the draft EYFS. The Government
is considering whether the system for handling breaches of
requirements could be simplified and would welcome views on whether
any of these requirements could be appropriately dealt with through
Welfare Notices rather than under caution/through prosecution.
27 Do you think that we should remove the automatic offence from any of the
welfare requirements? If so please specify which ones need not carry an
automatic offence. Please explain.
Yes
Comments:
X No
Not Sure
28 The Government would also welcome views whether Ofsted's powers are
sufficient in the area of learning and development. Should the Government
introduce a system similar to Welfare Notices for breaches of the learning and
development requirements?
X Yes
No
Not Sure
Comments:
General
29 Overall, do you think that the revised draft EYFS is clear and easy to
navigate? Please explain.
X Yes
No
Not Sure
Comments:
Yes, but it does not carry sufficient detail in order to enable practitioners to
carry out their job effectively, especially for those new to this age group.
30 Do you think the Government should make any further revisions to the
EYFS, to simplify and shorten it further? Please explain
Yes
X No
Not Sure
Comments:
We think many of the key messages of the original EYFS have been lost in
this revised version which is much too short.
31 Do you think that the revised draft EYFS would support effective
partnership working with parents and carers, enhancing their involvement in
children's' learning and development? Please explain.
Yes
X No
Not Sure
Comments:
Apart from the requirement to write a 24- 36 month report there is no
guidance on how to build effective partnerships with parents.
32 Please use this space for any other comments on the proposals.
Comments:
The brevity and lack of detail in the revised framework will make it extremely
difficult for those of us in advisory roles to secure high quality provision.
The revised framework does not sufficiently acknowledge birth to 24 months
or valuing early childhood as a distinct stage of development.
The emphasis seems to be on the second half of the EYFS (24 months+),
leaving practitioners who work with the youngest children the least
experience with very little guidance. These practitioners are often the
youngest and least experienced in the EYFS workforce. We are very
concerned that this will have negative impact on outcomes for children
especially communication and emotional development.
Although we understand the need to make language more accessible for
parents we are concerned the tone and terminology lack precision and
professionalism e.g the use of the word ‘bond’ rather than ‘attachment’.
33 Please let us have your views on responding to this consultation (e.g. the
number and type of questions, was it easy to find, understand, complete etc.)
Comments:
The requirement to complete the consultation by the end of September is not
helpful as this is a very busy time of year for settings and schools.
Thank you for taking the time to let us have your views. We do not intend to
acknowledge individual responses unless you place an 'X' in the box below.
Please acknowledge this reply
Here at the Department for Education we carry out our research on many
different topics and consultations. As your views are valuable to us, would it
be alright if we were to contact you again from time to time either for research
or to send through consultation documents?
Yes
No
All DfE public consultations are required to conform to the following criteria
within the Government Code of Practice on Consultation:
Criterion 1: Formal consultation should take place at a stage when there is
scope to influence the policy outcome.
Criterion 2: Consultations should normally last for at least 12 weeks with
consideration given to longer timescales where feasible and sensible.
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process, what is being proposed, the scope to influence and the expected
costs and benefits of the proposals.
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and clearly targeted at, those people the exercise is intended to reach.
Criterion 5: Keeping the burden of consultation to a minimum is essential if
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If you have any comments on how DfE consultations are conducted, please
contact Carole Edge, DfE Consultation Co-ordinator, tel: 01928 438060 /
email: carole.edge@education.gsi.gov.uk
Thank you for taking time to respond to this consultation.
Completed questionnaires and other responses should be sent to the address
shown below by 30 September 2011
Send by post to: CYPFD Team, Department for Education, Area 1C, Castle
View House, East Lane, Runcorn, Cheshire WA7 2GJ.
Send by e-mail to: revisedeyfs.consultation@education.gsi.gov.uk