Response to Commonwealth Government
Proposed National Quality Reforms for early
childhood education & care - Feedback on
regulatory impact statement (RIS)
Municipal Association of Victoria
August 2009
INTRODUCTION
The Municipal Association of Victoria
The Municipal Association of Victoria (MAV) is the legislated peak body for local government in
Victoria. The purpose of the Association is to promote and support the interests of local
government throughout Victoria, as defined in the Municipal Association of Victoria Act 1907.
Local Government in Victoria
Councils in Victoria have historically played a major role in the planning, funding and provision
of a range of human services, and actively partnered with State and Commonwealth
governments in the development of early childhood services and policy objectives. A recent
survey undertaken into Victorian local government involvement in early childhood services 1,
confirmed that Victorian councils are involved in a wide range of early childhood services and
that local government has the largest number of licensed children’s services in Victoria.
Intergovernmental Agreement
The MAV supports the National Reform Agenda for early childhood education and care being
driven through the Council of Australian Governments (COAG). In addition, the MAV wishes to
highlight the Intergovernmental Agreement 2 (or IGA) signed nationally in 2006, which
established a framework to improve how local government matters are dealt with by the
Commonwealth and the States. The IGA provides a set of principles to guide the way in which
functions and services are transferred to local government. Measures to improve the quality of
children’s services proposed under the Reforms may have service provision, facility
development and cost implications which will in Victoria require the consideration of the three
spheres of government. Specifically, the MAV and councils wish to ensure that adequate
consideration is given to any additional responsibilities and costs which may flow to local
government as a result of quality reforms for early childhood education and care.
Key issues of concern to councils are:
 Balancing the need for increased quality against the costs of the reforms and impacts on
current kindergarten participation rates in Victoria
 Availability of facilities for services other than 4-year old kindergarten groups and
displacement of important children’s services such as playgroups and 3-year old
kindergarten groups
 The three spheres of government responsibilities in financing of the improvements and
increased costs.
 The economic cost-benefit analysis of the reforms did not extend to consideration of
new/modified early childhood infrastructure and the impacts on infrastructure were not
discussed in the RIS.
 Required rates of growth of the early childhood workforce, particularly university qualified
teachers, to support the ambitious reforms
Survey undertaken jointly by MAV and the Victorian Government Department of Human
Services , 2006.
2 Inter-government Agreement: Establishing Principles to Guide Inter-Governmental Relations in
Local Government Matters, April, 2006.
1
2
RECOMMENDATIONS
The MAV makes the following recommendations in response to the reform options.
1. The MAV supports a nationally over sighted system which is implemented at the local
level by the State.
2. Support for the proposed reforms is contingent upon funding being provided from State
and Commonwealth levels for the increased recurrent and capital costs for kindergarten
and childcare.
3. In regard to staff-to-child ratios, that Option 2 is adopted, which includes a staff: child
ratio of 1:11 by the end of 2016, for children 3 to 5 years in long day care and preschool.
This option is preferred as it provides the longest lead in time for reform, expected to be
necessary to allow all levels of government more time to plan what is required and to
secure the resources needed to fund the required additional local early years’ recurrent
and infrastructure costs.
4. In support of Option 2, that the Commonwealth Government (and States as agreed)
provide additional capital and recurrent funding:
a) Capital funding to cover the full costs of construction of any required additional local
early years infrastructure and, if necessary, additional funding to enable relocation
costs for displaced early years services, or the purchase of land for children’s
centres in specific locations, particularly agreed sites in locations where land prices
are high.
b) Additional recurrent funding will be required in Victoria - on a per child basis (for
kindergarten) and additional childcare benefits to families (for childcare) - due to the
reduced capacity of group enrolments and impacts on service budgets resulting from
the reforms.
5. Investment by the Commonwealth Government is required in the development and
introduction of new, more flexible training options, to meet the proposed workforce
targets and encourage existing staff across the state to increase their current level of
training and qualifications.
6. That the proposal for ‘services with 60-80 children on any day, are required to employ
0.5 of an additional university qualified professional by 2015’ is modified slightly to better
fit with Option 2 (and reads by end 2016).
7. That the timelines for implementation of change associated with the preferred reforms,
including plans for universal access to 15 hours of early childhood education by 2013,
should be carefully aligned, to maximise positive outcomes and to reduce any
duplication of effort. In Victoria this should also take into account the timelines for
introduction of changes under the 2009 Children’s Services Regulations.
These positions area explained in more detail in the following pages.
3
MAV FEEDBACK ON OPTIONS in the regulatory impact statement (RIS)
CONTEXT & OVERVIEW
In principle support for national standards in early childhood education & care
The MAV accepts the evidence on the need for improved quality in early childhood education
and care, and accepts the rationales for a set of nationally consistent standards where
appropriate; including reduced staff-to-child ratios for 4 year olds in Victoria.
The MAV notes the changes proposed for Family Day Care and also the improved qualifications
and staff:child ratios in long day care and preschool for children under 3 years of age. These
proposals are consistent with the new Victorian Children’s Services Regulations and therefore
fully supported.
Concern about impacts for Victoria
The MAV holds considerable concern however about the impacts in Victoria of the proposed
changes to staff:child ratios for children aged 3 to 5 years.
-
The main impact expected for Victorian local government is the expected strong demand
for new local children’s facilities (arising from the reduced group sizes and the
subsequent numbers of children/families expected to be ‘displaced’ from their
neighbourhood or township kindergarten facility.)
-
The main impact for Victorian children and state policy outcomes, is a potential reduction
in kindergarten participation rates within Victoria, resulting directly from any change to
group sizes (for funded kindergarten, the year before school). This could prove to be a
negative unintended consequence of the national reforms.
In consideration of the above, the MAV supports Option 2 for staff-to-child ratios. While this
option is for a staff: child ratio of 1:11 for children 3, 4 and 5 years in long day care and
preschool, it is not required until the end of 2016, therefore providing the longest lead in time for
reform. This option allows all levels of government more time to plan what is required and to
secure the resources needed to fund the required additional local early years’ infrastructure and
necessary additional recurrent costs. Support by Victorian local government for this reform
(changed staff:child ratios) is conditional on the provision of capital grants to cover the full costs
of construction of any required additional early years infrastructure and, if necessary, funding to
enable the purchase of land in specific locations.
Cumulative impact of concurrent reforms
Victorian local government is highly cognisant of COAG’s ambitious goal to achieve universal
access to 15 hours of early childhood education, by 2013, and is committed to working with the
Sate and Commonwealth to achieve this goal. However, plans for these reforms were only
recently released. The impacts on local kindergarten centres, children’s services and staff of
this major change are yet to be identified. Local government in Victoria is expecting that this
reform will require significant resourcing at the local service level, including new infrastructure in
many locations.
Councils have raised with the MAV the cumulative or compounding impacts of these dual
reforms on Victorian children’s services/centres. The reforms will require:
1) the introduction of much longer kindergarten sessions for every 4 year old child, and
2) the delivery of smaller group sizes.
4
As a consequence, the following issues are highlighted.
- Many children’s centres in Victoria, although facilities may be owned by council, are
managed by community committees/parent volunteers. Such committees have limited
capacity to respond and adapt to changing service demands. Such committees often
lack the capacity to manage financial and other pressures, with little time given to
considering coordinated service delivery for families within their local area or planning for
their facility over the long term.
- Strong support for a longer period of time being provided to enable local communities,
with their local council, to develop strong structured approaches to these forthcoming
changes, and adapt to these changes.
- Strong support for “appropriate and realistic” levels of capital funding and/or relocation
funding and support, from Commonwealth and State Governments, to enable
communities to retain the capacity to provide a diversity of early years services to their
local community.
- In growth areas particularly the impacts on early years infrastructure and councils must
be addressed.
- Strong support for supplementary recurrent funding to resource the reforms.
The impact of these reforms on 3 year old kindergarten experiences and supported playgroups
Another important issue highlighted by all councils is that the COAG reforms will impact on the
ability of Victorians to access the highly sought after 3 year old kindergarten/activity groups and
supported playgroups both of which have proven important for vulnerable children and families:
- There is growing demand throughout Victoria for 3 year-old-kindergarten and supported
playgroups. Local Government is experiencing continued pressure to provide suitable
local facilities for such groups.
- It is feared that the consequences of a focus on services for 4 year olds within all
existing children’s centres, will limit the capacity and flexibility of most children’s centres
to provide a range of family & children’s services. The provision of other children’s
services in response to local needs may be compromised.
- a reduction in capacity of local centres to be flexible in provision of services to meet a
variety of local needs, could have particular negative impacts on accessibility of services
by vulnerable families.
- There is concern that 3 year-old-groups and playgroups will become a lower priority,
putting these valuable services at risk. This would be a counterproductive public policy
outcome given that the Victorian State Government has recently acknowledged the
importance of 3 year old kindergarten for “at risk” groups (such as indigenous children,
children of refugees and children from families known to Child Protection). The State
has this past year provided funding to enable attendance of these children in “early start
kindergarten” programs.
- It is also noted that both Federal and Victorian State governments currently provide
funding for playgroups. Local government in particular is the main provider of
infrastructure for these types of services, and will be placed under further pressure to
provide alternative facilities if necessary.
Alignment of reform implementation timelines
Finally, in regard to the timelines for change associated with the preferred national reforms, it is
also recommended that all reforms, including plans for universal access to 15 hours of
kindergarten/early childhood education (or UAECE) by 2013, require careful alignment of their
implementation timelines, to maximise coordination and positive outcomes and reduce
duplication of effort at all levels.
5
OPTIONS FOR CHANGED STAFF-TO- CHILD RATIOS for Long Day Care and Preschools
Impacts on group sizes and the utilisation of Victorian children’s centres
Regulating standards for staff-to-child ratios is the most significant determining factor in
establishing group sizes. Standardised group sizes also determines design of facilities and the
capacity of playrooms being built for children’s services.
It is recognized that smaller group sizes nationwide will have a positive impact on the quality of
early childhood education and care for Australian children.
However, as a result of implementation of any of the change options 2-4, the enrolment capacity
of existing kindergarten centres in Victoria would be significantly reduced. The maximum group
size for a funded kindergarten group in Victoria would be reduced as a result of these new
standards: from the current 25–30 children per group, down to 20 children per group (option 4)
or 22 children per group (option 2 or 3).
In Victoria, these changes will result in a ‘displacement’ of 5 -10 children per kindergarten group
(under option 4) or a displacement of 3– 8 children per kindergarten group (under option 2 or 3).
-
Option 4 is therefore not acceptable to Victorian local government.
-
Option 2 & 3 provide a better outcome, with option 2 being the preferred option for
Victorian local government.
-
At present most ‘traditional’ kindergarten centres in Victoria offer places for 50 – 60
children (25 – 30 children per group). Some kindergarten centres in areas of high
demand offer 3 groups per centre (maximum of 90 children, in a fully utilised centre).
With the proposed introduction of 15 hours per week of kindergarten from 2013 the
enrolment capacity of centres currently providing three groups of kindergarten (@ 10
hours per week) is already being significantly reduced. Some of these centres are not
owned by local government, but the non-government, community-based sector, such as
not-for profit incorporated associations or churches.
-
Some councils in Victoria construct double unit kindergarten centres in areas of high
demand for sessional kindergarten – a more cost effective way of providing infrastructure
for children’s services and allowing for up to 180 kindergarten places where demand
requires this, fully utilising two playrooms.
Impacts on early childhood infrastructure in Victoria & infrastructure costs for local
government
-
Victorian local government has responded to local needs, and new funding opportunities
provided by both State and Commonwealth governments for family & children’s centres,
integrating kindergarten with child care and other services for families with young
children. Victorian councils are therefore sensitive to any reforms that may shift the cost
of reform on to local government without due recognition of the local ramifications of the
reforms.
-
Option 2 provides a longer lead in time than does Option 3 for the change in staff-to-child
ratios for 4 year olds (option 2 requires change to 1:11 by 2016; Option 3 requires change
to 1:11 by 2015). This additional time would allow local government in Victoria more time
to plan for the impacts of the reduced group sizes, and build on the learnings from
implementation of the UAECE initiative due at this stage for implementation in 2013.
MAV therefore supports adoption of Option 2 for staff-to-child ratios.
-
In Victoria, local government experience has shown that a minimum of 3 years is required
for ‘lead in time’ for a successful new early years facility (more time for fully integrated
6
services centre/hub). Lead in includes planning, negotiations, selecting & supporting the
most appropriate governance structures, which may be community-governance.
-
The experience of Victorian councils has also shown that it takes time to negotiate new
partnership arrangements for the delivery of new models of facility provision/service
delivery. It may take a few test runs/trials for council to settle on the better, most
sustainable model(s).
-
By 2013 all stakeholders will be in a better position to determine the capacity of the long
day care sector to take up additional kindergarten places in Victoria.
-
The MAV is mindful of the Victorian Government’s Blueprint for early childhood
development and school reform, specifically the commitment for more children’s centres
on, or adjacent, to school sites. It is noted that many land parcels for schools already
have limited space, preventing the addition of children’s centres without new multi-storey
designs being considered. By 2013 DEECD (central and regional offices) may have
greater opportunity to position schools to respond to this blueprint action, and assess the
capacity of the schools sector to provide for construction of new early years service
centres including kindergartens.
-
This reform is a national initiative and as such it is expected that the Commonwealth
Government would ensure that resources are provided to enable this reform on the
ground.
-
The MAV’s support for Option 2 is conditional therefore on the provision of capital grants
to cover the full costs of construction of any required additional local early years
infrastructure and, if necessary additional funding to enable relocation costs for displaced
services, or the purchase of land for children’s centres in specific locations, particularly
agreed sites in locations where land prices are high.
-
It is noted that the economic cost-benefit analysis prepared by Access Economics did not
extend to consideration of impacts on costs of necessary new early years infrastructure
(both new and modified facilities). The impacts on infrastructure are not discussed in the
RIS. This is considered a serious oversight. The Commonwealth Government must
recognize and cost the impacts of these reforms on local early years infrastructure and
the likely costs of such should be established in full consultation with state and local
government.
-
Commonwealth implementation plans for all the national early childhood education and
care reforms must factor in costs of capital grants for any required new/modified facilities.
It is recommended that Commonwealth budget allocations for capital works be made in
every financial year leading up to deadlines for reforms.
-
Without these costs being planned and provided by the Commonwealth, the costs of
construction of new/modified early years facilities risk be passed from licensees onto the
service users, and affordability and accessibility of services risk be impacted. In Victoria
this is expected to impact on kindergarten participation rates and impact on
Commonwealth Goals for Universal access to early childhood education.
Impacts on Victoria’s high kindergarten participation rates
-
Kindergartens in small towns (and distinct, separated suburbs) operating only 1 group of
4 year old kindergarten and currently accommodating up to 30 children, would be limited
to placing only 20-22 children under the proposed new standards. Between 10-12
children from that township or suburb could be ‘displaced’ (required to travel out of area to
secure a kindergarten place, given that 10-12 is an insufficient number of enrolments for a
viable new kindergarten group, within the current facility) It is highly probable that children
from small rural communities and some suburban locations may not attend their
kindergarten year is the family/caregiver would have to travel to a neighbouring town or
suburb for that service.
7
-
The current set of kindergarten centres in Victoria would not have capacity to provide for
all enrolled children for kindergarten in the year before school - thus jeopardizing the
current strong record that Victoria holds for participation in Kindergarten by children in
their year before school. Many Victorian kindergarten centres, particularly in areas where
demand is high run three groups of funded kindergarten each week, accommodating up
to 90 children within one centre.
-
The option of including an extra staff member in a group, rather than reducing group
numbers would address impacts of reduced staff:child ratios on centre capacity and
mitigate need for new capital funding, but this response would require increased recurrent
funding.
Impacts of changed staff:ratios for children under 3 years
Expected increased costs for care and possible increased demand on the not-for-profit
childcare sector
Many Victorian council provide long day child care centres (LDC) and Family Day Care (FDC).
With the combined National and Victorian regulatory changes, the lowered staff: child ratios for
children under three years of age will impact on costs of LDC due to associated increased
staffing costs and impacts on group and room sizes. These costs are likely to be passed onto
families using the services. The profit margins of for-profit providers are also likely to be
reduced, and as a result, for-profit child care providers may decrease their number of places for
children less than 3 years.
As a consequence, there may be increased demand on the not-for -profit child care sector, to
provide the more expensive care for children less than 3 years of age.
One possible solution might be to introduce incentives (e.g. increased subsidies) specifically for
LDC centres that provide places for children less than 3 years of age.
8
RECOMMENDED CHANGES TO QUALIFICATIONS for Long Day Care and Preschools
The MAV wishes to highlight the overall increases to costs of delivering early childhood
education and care services arising from the improvements to standards regarding the training
and qualifications of staff in the services. These costs will add burden to all stakeholders –
service users, licensees/providers, staff themselves and governments (funding bodies).
Councils have made mention in particular of the financial impacts for the industry of requiring
Certificate III for all “untrained” childcare workers nationally.
There may be a need for a longer lead time to ensure adequate expansion of the available
qualified workforce.
The MAV considers there is an urgent need for Commonwealth investment in the development
and introduction of new, more flexible training options, to meet the proposed workforce targets
and to encourage existing staff across the state to increase their current level of training and
qualifications: e.g.
- On-line study opportunities;
- Part-time courses of study, delivered locally, to ensure staff in regional and rural
locations are not disadvantaged;
- Paid release for on-campus study.
In regard to the proposal that ‘services with 60-80 children on any day, are required to employ
0.5 of an additional university qualified professional by 2015’ the MAV puts forward the following
questions and recommendations:
-
Question:
It is noted that this standard does not specify the nature of the additional university
qualification required. Further information is required as to the intent of this standard. If
it is to ensure improved early childhood programming and additional input to the
child/family-focused program, then an early-childhood qualification should be specified.
Otherwise the intent of this standard requires clarification.
-
Recommended modification:
It is preferred that the timelines for this requirement are matched to synchronise with the
timeline for introduction of the recommended new staff-to-child ratios. If Option 2 for
staff to child ratios is adopted, Victorian preschools could be disadvantaged in 2015, for
it is likely that some preschool centres might still in 2015, be offering 2 groups per day of
30 children per group, a total of 60 children. To ensure that such Victorian preschools
are not disadvantaged by this disjunction between the standards, it is recommended that
the proposed qualification standard be modified to read either:
1. ‘services with 60-80 children on any day, are required to employ 0.5 of an additional
university qualified professional by 2016’,
or
2. ‘services with 61-80 children on any day, are required to employ 0.5 of an additional
university qualified professional by 2015’
9
PROPOSED ENHANCED REGULATORY ARANGEMENTS
The MAV supports a nationally over sighted system which is implemented at the local level by
the State.
The MAV endorses the introduction of an integrated national system for administering the
National Quality Standard and Ratings Framework, and believes that one national system has
the potential to provide the most legible, cohesive and effective method of developing and
ensuring quality in children's services. It is recommended that a wide range of stakeholders are
consulted extensively in the process of constructing a national system to assess and promote
quality in early childhood education and care.
In constructing this new system there is the opportunity to address the importance of inclusion,
a factor that is certainly undervalued in the current accreditation system. The concept and
philosophies of providing quality programs that include and meet the needs of all children is
heavily supported through government policy and through the funding of Inclusion Support
Agencies to provide Inclusion Support Facilitators, as well as Preschool Field Officers, yet to
date there have been few other incentives for services to focus on inclusion. The changes
provide an opportunity to embedded inclusion as an integral part of any quality early childhood
service/system and services failing demonstrate this would have having their quality rating and
accreditation results impacted accordingly.
The MAV’s recent submission to the Australian Senate Inquiry into the provision of childcare
(February 2009) included suggestions on additional useful roles for a national childcare
‘authority’ or ‘committee’. These roles are listed below. Some of these functions might be
considered in the development of any new national regulatory arrangements.
- Reviewing the criteria and application processes of planning controls for new federally
funded child care services.
- Evaluating available data collection and reporting opportunities to support the roles of
federal, state and local governments in child care service development and planning.
Data will support assessments of service accessibility and quality. Some data would
also be available to the public.
- Monitoring the outcomes of policy, funding and planning controls on the child care
industry and families, including evaluation of various approaches by each state, against
agreed national performance indicators, to feed into national improvements for the child
care industry.
10