CPS Child & Family Centre’s submission to the 2014 NQF Review
– Consultation Regulation Impact Statement
CPS values the opportunity to contribute to the discussion around proposed
changes to the National Quality Framework (NQF). Our first and most
important message is that the NQF, including the assessment and rating
process has been instrumental in improving quality education and care for
young children across the sector. We assert that any weakening of the NQF
will be a backward step in achieving high quality ECEC for all Australian
children. We do acknowledge some teething issues and some areas for
improvement; however as a whole the NQF is delivering better outcomes for
children and families.
The following directly addresses some of the proposed changes as outlined in
the regulation impact statement. We hope that any changes to the NQF will
reflect the feeling across Australia that the NQF has delivered a more
professional, reflective, quality focussed early childhood sector, and that we
must keep the momentum going.
Proposal 1.1 Reducing the complexity of the NQS.
We have reviewed the draft of the revised NQS and our recommendation is
for no change to be made to the current NQS. While the initial period of
getting to know the NQS may have been challenging for services we are now
actively using this document to monitor and promote quality in our services.
The current NQS is very carefully worded to be specific, purposeful and to
give ECEC services a clear vision in working towards quality in all seven areas.
There are 4 key issues with the proposed revisions of the NQS; we have
included examples for each:
1. The revised NQS dilutes the current standards. High expectations have
driven improvement across the sector. There should not be a lowering
of challenging standards, instead services should be supported to build
and improve their practice.
Eg. Standard 3.3 (3.3.1 & 3.3.2) will be replaced with 3.B.iii that excludes the
concept of contributing to a sustainable future, of embedding sustainable
practices into the program and supporting children to show respect for the
environment. The amendment fails to recognise the important role that
children play in creating a sustainable future. If we believe that children will
shape our future we must embed notions of respect and responsibility into
everyday living so that the next generation feels engaged and connected with
the future of our planet.
2. The revised NQS offers less clarity in what is expected of services. The
current NQS gives specific and clear expectations. Cutting out
standards and including them under one umbrella standard reduces
clarity and gives services less information to base their practice.
Eg. Standards 7.3, 7.3.1 – 7.3.5 & 7.1.5 will be reduced to the very broad
7.A.ii. The current standards around administration and management give
services clear goals and quality indicators to work towards. The revised
standard is too broad to give any guidance as to what quality looks like in this
area. The aim of the NQS is to provide a framework for improvement, our
concern is that this amendment gives a vague idea that decision making and
systems are important but offers no specific advice on how to achieve them.
3. The revised NQS is change for the sake of change. Many of the revised
standards have the same message as the current NQS but with
different wording. For an industry that has undergone such huge
change over the past few years there is a high level of change fatigue
and no room for unnecessary amendments. The current NQS is
expertly worded; there is no need to re-write it.
Eg. Current Standard 4.2.2 reads, “Educators, co-ordinators and staff
members work collaboratively and affirm, challenge, support and learn from
each other to further develop their skills, to improve practice and
relationships.” The revised standard 4.B.i reads, “Management, educators and
staff work collaboratively and interactions convey mutual respect, equity and
recognition of each other’s strengths and skills.” This statement carries most
of the same intent however it removes the idea that educators challenge and
learn from each other, a key part of effective collaborations.
4. The current NQS gives a key statement at the beginning of each
quality area. This statement sets the tone and expresses the ideals of
high quality under the standard. It would be counter-intuitive to
remove these driving statements.
Eg. Current Quality Area 7. Staffing arrangements. “Effective leadership and
management of the service that contributes to quality environments for
children’s learning and development. Well-documented policies and
procedures, well-maintained records, shared values, clear direction and
reflective practices enable the service to function as a learning community. An
ongoing cycle of planning and review, including engagement with families,
creates the climate for continuous improvement.” This statement is additional
information to guide services towards better outcomes for children and
should not be removed.
Proposal 1.5 – Exceeding the National Quality Standard rating &
Proposal 1.6 Removing the excellence rating
The assessment rating received by a centre should accurately reflect their
level of quality across the 7 quality areas. CPS strongly advocates for
distinction in early childhood education and care; however we feel that the
cost burden in applying for excellence is too high. We assert that the
excellence rating should be available to centres who achieve exceeding in all
seven standards and that it should not require a regular payment as this is
not sustainable for community and not for profit centres. Excellence should
be based on merit, not on performing additional tasks and making a payment.
Proposal 2.1 Removing the requirement for supervisor certificates
The move to service supervisor certificates is a positive one in reducing cost
and regulatory burden. We agree with changes to the supervisor certificates,
and agree that services should have the responsibility of identifying
responsible persons.
Proposal 3.1 Expanding the scope of services under the NQF
CPS strongly believes that the NQF has increased quality in services across the
country. We conditionally agree to expand the scope of the NQF provided
that there is support (e.g. financial) & consideration around how these
services operate and the resources available to them in implementing the
NQF.
Proposal 4.1 Extending some liability to educators
Children’s wellbeing and safety should be paramount in all services. We do
not feel, however, that making educators liable will create safer environments
for children. We would not support any changes that reduce the responsibility
of leaders and management for the culture/safety of the service. We are also
wary that educator liability may reduce or eliminate ‘risk taking’ in learning
for children, a necessary part of challenging, & engaging educational
programs.
Proposal 1.7 – Ensuring ratings accurately reflect service quality
It is important that the NQS rating accurately reflect the centre’s quality. CPS
supports the current rating system but agrees that a service should be able to
apply the current Minor Adjustments Policy if the standard can be remedied
quickly. This would ensure that services who were ‘working towards’ in a
small number of elements would not have to wait 2 years plus to be
reassessed.
Proposal 1.8 Length of time between assessments
Timely and regular assessments are integral to the effectiveness of the NQF.
CPS agrees that services who are ‘working towards’ the National Standard
may need shorter time frames between assessments to support their
development against the NQS. We do however; contend that 5 years may be
too long to ensure quality in other services. Streamlining is needed to meet
the current timelines as much as is practicable. We assert that the regulatory
authority continue to work towards the current timeframes, using the earned
autonomy system. If the current timelines are unworkable we would
recommend 4 years, as a compromise.
Proposal 5.4 – Increase in annual fee for approved services
CPS understands the need to raise revenue for the ongoing application of the
NQF assessment and rating process. We are, however opposed to the
increase in fees for all services. Our Child and Family centre offers specialised
education and care to vulnerable families. We are a not for profit centre with
elevated costs associated with high staff ratios, an interdisciplinary approach
to family support and intensive model of education and care. We propose
that community based, specialist and not for profit centres be excluded
from fee increases, as these impact unfairly on the ability to sustainably
provide these services.