THE RESPONSE OF THE NATIONAL UNION
OF TEACHERS TO THE DfE CONSULTATION
ON EARLY EDUCATION AND CHILDCARE
STAFF DEPLOYMENT
FEBRUARY 2013
Introduction
1.
The National Union of Teachers (NUT) welcomes the opportunity to respond to
the DfE proposals on the arrangements for how staff should be deployed in early
years settings. The NUT’s comments focus on its members’ experiences as both
providers and users of early years provision.
Recruitment and Retention
2.
The reasons for and extent of problems with recruitment and retention are longstanding and well-evidenced. The low pay associated with the sector has been a
key issue historically and is linked to gender as well as the status of the
profession. Childcare is still viewed as a predominantly female, unskilled area of
activity, which has both depressed salaries and acted as a barrier to the
recruitment of a more representative workforce. Temporary contracts are often
used to give employers flexibility if their setting is undersubscribed. This
uncertainty adds to the sense of the workforce being undervalued and poorly
treated.
3.
The DfE blames the current adult:child ratios for low pay and subsequent
recruitment and retention problems. It argues that if more qualified staff looked
after more children, they would be paid more as employers would not have to pay
as many staff. This is utter nonsense. Staff deserve increased pay now, for the
work they are currently doing, not for having to try and manage the logistical
nightmare that would ensue from some of the proposed relaxation of ratios. The
increased responsibility and stress arising from this and the ‘collateral damage’
which would be done to the employment prospects of less qualified staff would,
ironically, exacerbate recruitment and retention difficulties.
4.
The only section of the workforce which has not suffered recruitment and
retention problems to the same extent are early years teachers who hold
Qualified Teacher Status (QTS) and who are employed as teachers. This is
because employment under the School Teachers’ Pay and Conditions Document
(STPCD) guarantees them a standardised and regulated pay and conditions
package. The failure of the Early Years Professional (EYP) initiative is in part due
to the lack of similar pay and conditions for this group. If Government is genuinely
serious about addressing the issue of recruitment and retention, it must look at
developing similar arrangements for all grades and positions within the early
years workforce.
116101334
Created: 13 February 2013/KDR/SA
12 February 2016
5.
More Great Childcare, the document which accompanies the consultation
document and provides more detail on its proposals, gives the impression that
teachers working in nursery schools and classes are paid differently to their
primary colleagues. As the DfE is well aware, this is not the case and leads to
suspicions, explored in more detail later in this response, about the intentions
behind the new ‘early years teacher’ role. In addition, figures on staff salaries
given in the document are actually based on average primary teacher salaries,
which will necessarily be higher than for nursery teachers because there are
fewer TLR and senior leadership posts available for those working within nursery
provision, even when those teachers are working within a primary school.
6.
The DfE rightly identifies low pay and low status as two key drivers of recruitment
and retention problems in the early years sector. Its proposals, however, do
nothing to address them in any practical way. Whilst it is still possible to receive
more financial reward, with a lot less responsibility, by working in a call centre or
supermarket, why would anyone, especially those with lower levels of
qualification, want to work in the early years sector?
Ratios
7.
The NUT disagrees strongly with the DfE’s proposed relaxation of the current
adult:child ratios, as do the majority of those running, working in or using early
years provision. These proposals expose the DfE’s ignorance of what constitutes
high quality provision and also its willingness to use international evidence
selectively and misleadingly in order to support a position for which no
independent evidence exists.
8.
Fundamentally, the DfE must understand that ratios are a key determinant of
quality of provision. This is important because only high quality provision has a
positive impact on children’s learning, development and wellbeing and
contributes to narrowing the achievement gap.
9.
For babies and very young children, one to one interaction is critical to
development. They rely primarily on individual attention. This reflects the current
EYFS statutory requirement that opportunities for attachment for babies should
be provided, typically through consistent individual attention from one or two key
workers. It is not possible to give such attention concurrently to four babies by
employing more qualified staff – it is the physical attention as well as the
intellectual and emotional engagement between child and adult that makes the
difference and without it babies will inevitably experience a withdrawal of
attention.
10.
Parents understand this and prioritise it when they make their childcare choices.
A Mumsnet survey in 20121 showed that only five per cent of parents supported a
reduction in childcare staffing levels, even if it meant costs were reduced. Within
two days of the launch of this consultation, 11,000 parents had signed a PreSchool Learning Alliance petition2 opposed to ratio change.
1
2
http://www.mumsnet.com/family-friendly/childcare-costs-survey-2012
https://www.pre-school.org.uk/media/press-releases/345/thousands-of-parents-voice-their-anger-about-ratiochanges
116101334
Created: 13 February 2013/KDR/SA
12 February 2016
11.
More Great Childcare, however, says there is no basis for the current ratios,
‘even four decades ago they only reflected common practice of the time, rather
than firm evidence that they were best at protecting children’s safety and
promoting learning and development’. This is patently untrue.
12.
If only the authors of the report had looked at an evaluation3 of the Graduate
Leader Fund, undertaken for the DfE. They would have read about the clear
positive link between the quality of provision and the number of children staff
looked after, right across the birth to five age range or about the factors identified
as necessary for high quality provision for the under threes; low child: adult ratios,
qualifications and length of staff experience. The report’s bibliography lists over
thirty sources of independent, academic research on ratios which could have
further enlightened the authors of More Great Childcare.
13.
The optimum ratio for under two year olds in education and care settings has
been shown to be 1:3 consistently4 - it is no surprise that the majority of countries
which offer good or better quality early years provision adhere to roughly the
same ratios. Although ratios do not guarantee quality, they are a pre-condition
for it. No matter how well qualified and how hard working a member of staff is, he
or she can only work effectively with a very small number of young children. A
study in Austria5, where ratios and staff deployment are similar to those in
France, which is used in the document as an illustration of good practice,
demonstrated that a 15 month old baby did not receive any individual attention
from anyone during his nursery day – is this what early years settings in England
should aspire to?
14.
The rationale for altering the current ratio arrangements is summarised as
follows: ‘this move to put the needs of the child at the heart of decisions over
staffing is critical if we are to give providers the flexibility to operate effectively,
recruit more highly skilled staff and demonstrate their ability to offer outstanding
education and care.’ This is nonsensical filler, not a well-thought out and
reasoned explanation. The needs of the child and of providers are two very
different things. If ‘quality and safety are paramount’, to quote the preceding
paragraph, they should take precedence over any reduction in ratios, even if
using more highly qualified staff.
15.
Indeed, on a practical level the proposed relaxation of ratios could pose a
significant threat to children’s safety, as there would inevitably be less close
supervision if fewer staff were employed. This is an area where there is a need
for more, not less regulation, as currently no official records are kept on the
number of deaths, serious injuries and accidents that occur when children are in
early years settings6.
3
4
https://www.education.gov.uk/publications/eOrderingDownload/DFE-RR144.pdf
http://www.educationcounts.govt.nz/publications/ece/quality-early-childhood-education-for-under-two-yearolds-what-should-it-look-like-a-literature-review/executive-summary
5
6
http://www.univie.ac.at/bildungswissenschaft/papaed/seiten/datler/Artikel/150_Struggling_Against_the_Feeli
ng_of_Becoming_Lost.pdf
http://www.nurseryworld.co.uk/News/MostRead/1166424/Exclusive-Concern-lack-data-nursery-deathsinjuries/
116101334
Created: 13 February 2013/KDR/SA
12 February 2016
16.
There is also a danger that providers could be penalised for using any increased
flexibility in ratios. It is proposed that Ofsted would expect settings to justify their
staffing structures and the way in which flexibilities are used. This appears to be
an abrogation of responsibility on the DfE’s part, as any inappropriate practices
discovered by Ofsted would be the responsibility only of the individual setting and
would not address the defects in the regulations which allowed the situation to
occur. In addition, if Ofsted became the sole arbiter of what constituted
acceptable practice, this view would become regulatory de facto, as few settings
would risk challenging Ofsted’s view for fear of de-registration.
17.
A significant amount of the information about international ratios given in the
document is incorrect, a view shared by Helen Penn, Professor of Early
Childhood at the University of East London and advisor to the Government on its
childcare policy development7. For example, the figures cited do not include
assistants, who are an integral part of ratio calculation in a number of countries or
the number of children who might be with a child minder at any one time.
18.
In France, for instance, which is used as an example to support proposals, it is
not true that child minders can look after up to eight children – they can be
registered to care for this number, but cannot look after more than four at any one
time. Indeed, standards of French early years provision are currently a matter of
public debate, as the youngest children are often cared for by a number of
different staff and institutions within the same day. In Germany, contrary to what
More Great Childcare says, ratios do exist but are set locally by lander, rather
than nationally, as early years is not counted as part of the education system but
included in the child and youth welfare sector. They are generally quite similar
within the country and are actually lower than the OECD average for children
aged three and over.
19.
Arrangements in the Netherlands are cited in several sections of More Great
Childcare as evidence of ‘what works’. The authors of this document omitted to
mention that the Dutch government had to reverse the reforms it established in
2005 which led to reduced ratios and increased setting sizes because of their
disastrous effect on the quality of provision, especially in terms of child/ staff
interaction8. Day nurseries retained their more qualified staff and dismissed the
less qualified. The increased workload and mental and physical demands
interfered with the level and quality of interaction between staff and the greater
number of babies and toddlers they cared for. Another important detail omitted
from the report was that employers in the Netherlands meet a third of childcare
costs and that it was this, rather than ratio reform, which made childcare more
affordable for parents.
20.
The current ratios, and their contribution to quality, have ensured that England’s
early years provision is world class. In a document full of references to
international practice, it is inexplicable that no reference was made to the 2012
report ‘Starting Well’ by the Economist Intelligence Unit9, which rated this country
fourth out of 45 countries, behind Finland, Sweden and Norway but ahead of
France, Germany and the Netherlands, all of which are used as examples in
7
8
9
http://www.dailymail.co.uk/news/article-2269604/Better-qualified-nursery-staff-allowed-look-toddlers-insteadALL-parents-promised-help-bills.html#axzz2K85S4DKQ
http://www.nurseryworld.co.uk/news/1127031/Going-Dutch---dangers-deregulation/
http://www.lienfoundation.org/pdf/publications/sw_report.pdf
116101334
Created: 13 February 2013/KDR/SA
12 February 2016
support of the consultation’s proposals. The one area of weakness noted for the
UK was in its ratios for over threes. How can the DfE claim that its proposals
would not affect quality when the current ratios are already preventing provision
from being as good as it could be?
21.
More Great Childcare blames the current ‘high’ ratios for both the higher costs
parents are forced to pay and the lower pay staff are forced to accept. It claims
that in other countries providers can use the extra income they receive from
taking on more children to rectify both of these issues. The DfE should publish
the evidence base for this assertion, as none of the international studies,
including by the OECD and the European Commission, contain this information.
It is certainly unlikely that greater income would be used for one, let alone both,
of these purposes, as most providers have already said that any additional
income would be retained to increase or make a profit. A Pre-School Learning
Alliance survey in 201210 found that only a small minority would lower their fees
for parents, the majority arguing that any additional revenue arising from greater
flexibility in staffing would go towards addressing their historic underfunding.
22.
A specific consultation question is asked about how providers might be
encouraged to use more graduates, in order to increase group size, which is part
of the current regulations on ratios. The private and voluntary sectors have
historically been averse to employing qualified teachers because of the costs
involved, even when there are clear benefits for the quality of that provision.
Similarly, graduate employment, including EYPs, was not as high as expected
under the previous government’s early years strategy. Even though there was no
standard minimum pay scale for this group of more qualified workers, they were
still deemed to be too costly. A combination of regulation and financial incentive
would appear to be the only way to ensure the staffing arrangements which
Government desires are implemented by all providers.
23.
The private and voluntary sectors must be encouraged to invest in the quality of
their provision. Many employ graduates only in managerial roles because this
satisfies basic regulatory requirements. Unless it became statutory for qualified
teachers or graduates to work directly with children, this will not happen
voluntarily except in a minority of settings.
24.
The DfE should think again about its proposals to increase ratios, which would
reduce the quality of provision, potentially risking children’s safety and welfare;
prevent children from developing close and nurturing relationships with staff; lead
to less qualified staff losing their jobs rather than being valued for the work they
do and supported to progress within the profession if they wish; and create a two
tier system within the sector, with only those who can afford it being able to pay
for personalised attention for their child. The same concerns have been
expressed by parents, practitioners, nursery owners, child minders, researchers
and children’s organisations – these are not all ‘trendy progressives’ but a wide
cross section of those with a legitimate interest in early years and a wish to
protect it. Their views should not be ignored.
10
https://www.pre-school.org.uk/media/press-releases/315/nursery-providers-overwhelmingly-reject-change-instaff-ratios
116101334
Created: 13 February 2013/KDR/SA
12 February 2016
Qualifications
25.
The NUT does not agree that ratios should become more flexible and enable
more qualified staff to look after more children. Possessing a qualification may
improve the quality of planning activities for the child and the quality of the
interaction with them, but it does not give that person the extra pair of hands or
eyes necessarily to change a nappy whilst simultaneously being responsible for
the care and development of another three children under two years old.
26.
Basic levels of literacy and numeracy throughout the early years workforce are
needed, but the large section of the workforce who do not possess these
currently (16 per cent in nurseries, 41 per cent child minders do not have Level 3
qualification) cannot be ignored and will need support to prevent them from losing
their jobs. This happened in the Netherlands after a similar combination of
qualification thresholds and relaxation of ratios was introduced by the 2005
Childcare Act. It is important to recognise that some of this group may have
different learning needs, they may not see the relevance of gaining qualifications
as their primary focus is caring for children rather than paperwork, even if they do
have to communicate in written formats with parents and colleagues as well as
for educative purposes. The NUT would not support, therefore, any proposals to
apply qualification requirements retrospectively as a condition of remaining in the
early years workforce. Much more emphasis should be given in the DfE’s
proposals to offering additional learning opportunities for serving staff with Level
2 or below qualifications.
27.
It is notable that little reference is made to child minders in this section, even
though they have a significant degree of autonomy and responsibility. If there are
to be any basic levels of qualification introduced, this part of the sector should not
be excluded from it and should have equal access to support and training. This
is particularly important given that much of the expansion of free childcare for two
year olds will come from this sector. Improvements to child minder care must be
of the highest quality if it is to deliver the developmental gains expected from this
programme.
28.
It is disappointing that the section headed ‘Training’ (page 29) begins by referring
to CPD but then focuses only on training for those entering the workforce and
offers nothing for those already working in it. If the aim of the proposals is
maintaining and building on the quality of provision, professional development
should be a central plank of the strategy. It also ignores the vital role local
authorities (LAs) have currently in providing access to CPD, often the only offer
accessed by the Private, Voluntary and Independent (PVI) sector, where there
tends to be less investment in the workforce.
29.
Significant cuts to CPD at local level have already damaged this provision
considerably, however. A Freedom of Information request11 revealed that
between 2010/11 and 2011/12 there was a cut of 40 per cent in (LA) budgets for
early years staff training and that four LAs had no money at all available for this
purpose. This is unacceptable. LAs play a key role in encouraging take up of
CPD and consideration is needed of how this could be built on further, particularly
11
http://www.dailymail.co.uk/news/article-2260127/Training-childminders-nursery-staff-slashed-40-ministersfail-agree-deal-cut-childcare-costs.html#axzz2KaOHzrQ3
116101334
Created: 13 February 2013/KDR/SA
12 February 2016
as the Government has indicated that it will not take responsibility for the
establishment of a suite of online induction and training materials as
recommended by Nutbrown.
30.
The NUT has advocated consistently the sentiment expressed in More Great
Childcare, that teaching young children is just as important as and should have
the same status as teaching children of compulsory school age. It is, however,
concerned by the lack of detail in the document about ‘early years teachers’. It
appears that the DfE envisage they would bear the name ‘teacher’ but not hold
QTS. They would be ‘equivalent’ to a primary teacher and ‘superior’ to an EYP,
who would form the priority group for training for the new role. The training would
have the same entry requirements as primary initial teacher education courses,
including the skills tests component.
31.
It is significant that the only two Nutbrown’s recommendations which the
Government rejected outright were the development of an early years specialist
teacher training route and giving EYPs priority access to routes to QTS. More
Great Childcare needs to explain why the DfE has not proposed a new 0-3 ITT
programme, which would link to the current 3 – 5 to form a discrete EYFS ITT
course or a new 0-7 course as proposed by Nutbrown and whether ‘early years
teachers’ would be able to work in primary schools. How would the ratios work if
a qualified teacher was in charge of a class or setting – would he or she also
have to gain “early years teacher” status? Is this a means of tricking parents into
thinking their child is being taught by a qualified teacher? There are so many
unanswered questions raised in the document that it is impossible to take a view
on this until the DfE’s intentions are clarified. It is clear, however, that a
September 2013 start for the ‘early years teachers’ training is an incredibly tight
timetable to develop, recruit to and implement any new training provision.
32.
Similarly, whilst the new category of ‘early educators’ as a modern equivalent to
the NNEB Nursery Nurse appears attractive, especially as a career path and
developmental route, details are needed of what their role would be, what the
training would consist of, how EEs would be deployed and their terms and
conditions, before any assessment of the proposal could be made.
33.
It is also proposed that more school teachers should work with younger children.
This is already the case in some schools but common barriers have included the
capacity of nursery schools and classes to offer provision for two year olds; the
suitability of premises and resources; and access to training and support for staff.
Although existing early years teachers could meet this proposal by undertaking
the appropriate training, it is important to remember that teachers cannot be
required to undertake such training in maintained settings and cannot simply
have this new responsibility added to their contracts of employment.
34.
The greatest resource and key determinant of quality in early years provision is
its staff. They should have good levels of training to equip them for their roles
and should be rewarded appropriately for their work, their salary commensurate
with the levels of skills, knowledge and responsibility involved. The NUT awaits
further announcements on how requirements for higher levels of qualification will
be funded. If the workforce is expected to fund this themselves, it is unlikely to
succeed.
116101334
Created: 13 February 2013/KDR/SA
12 February 2016
Child Minders
35.
The NUT does not agree that ratios for child minders should be adjusted to allow
them to accept more children. This would undoubtedly compromise standards of
care, a view shared by parents and child minders, the groups which would be
directly affected by the proposals. A recent Mumsnet survey12 reported that 50
per cent of parents felt the current ratio of a maximum of three children under five
years old was right, with a further 20 per cent saying the ratio should be reduced
to a maximum of two children. Comments to the survey showed that parents
value small group sizes and the close relationships between child and carer
which develop from these. Similarly, the National Child Minders Association has
said that child minders would be less likely to take children out and would not be
able to give them as much individual attention and support if they were caring for
a greater number of children.
36.
The example given in More Great Childcare to show that higher ratios work in
other EU countries is extremely misleading. It is suggested that in Germany child
minders are unregulated in terms of ratios. In fact, a distinction in German law is
made between regulated and unregulated child care. Unregulated child minders
can provide care for up to 15 hours a week for a maximum of three months only.
This provision was intended to apply to situations where friends or family might
temporarily provide care when the mother is ill or otherwise incapacitated.
37.
There could be a little more flexibility in the application of the current ratios during
‘changeover’ periods, a problem highlighted in More Great Childcare, which
would allow the ratios to be suspended specifically for a period of ‘reasonable
overlap’. The other example given by the DfE in support of its proposals is,
however, disingenuous. It is already the case that a child minder is able to care
for twins under one year old if they can demonstrate that they can meet and
reconcile the individual needs of all the children they care for. In addition, there is
currently provision for exemption from the ratios in the case of siblings in certain
circumstances approved by Ofsted. The current ratios and attendant safeguards,
which are focused on the safety and welfare of the child, should be retained.
38.
The proposals about the creation of child minder agencies are interesting. There
would definitely appear to be benefits for child minders, who could receive much
practical support from an agency in both setting up and running their business.
The benefits for parents are less certain. There is little demand for help with
finding a child minder currently – only 13 per cent of parents reported difficulty in
a recent survey13. It is suggested that parents would “approach a child minder
agency to match them with a nearby child minder” rather than “having to
investigate every prospective child minder” (page 38). Many parents would,
however, still want to satisfy themselves that provision was right for their child,
even if it had been recommended. It is unclear whether there would be any
liability on the part of the agency in the event of a problem – would parents be
able to take legal action if there was an accident or if the provision was not high
quality and the child minder had been recommended by an agency?
12
13
http://www.mumsnet.com/family-friendly/childcare-costs-survey-2012
http://www.ncma.org.uk/news/news/june_2012_news/parents_want_regulated_care.aspx
116101334
Created: 13 February 2013/KDR/SA
12 February 2016
39.
Additionally, there would be a conflict of interest if agencies were expected to
provide or broker professional development and have responsibility for quality
assurance. No consideration appears to have been given about how the
operation of these three very different functions would work in practice. There is
also no information about what would happen in the event of an agency failing,
whether financially or after an Ofsted inspection. Would all of the child minders
on its books be prevented from continuing to work or would some sort of
transitional arrangements be put in place?
40.
The Children and Families Bill gives more information about how agencies would
operate, even though this is not referenced in More Great Childcare. They would
be able to prescribe their own conditions and exercise discretion over whether to
register a child minder, even if he or she met registration requirements, a
flexibility not afforded to Ofsted. Also, child minders could only register with one
agency and would not be able to be both on the early years register and
registered with an agency, which could increase their marketability and
accessibility to parents. These conditions could also create difficulties for child
minders if there were any disputes between them and their agency, as they could
be unable to continue to work. The details of the requirements for registration
and de-registration need to be made public before any further comment can be
made on these proposals.
Any Other Comments
41.
There are a number of elements within More Great Childcare which have
consequences for the early years sector but which do not feature in the
consultation document. It is unclear whether or not these will be subject to
separate consultation in the future, therefore the NUT will make brief comments
on the most significant of these.
Regulation within the Statutory EYFS
42.
The NUT disagrees strongly with the view expressed several times in More Great
Childcare that the current regulations regarding early years accommodation and
working practices are burdensome. The amount of floor space per child, an area
for children to sleep and an area for staff to talk confidentially to parents, some of
the examples given, are not “trivial issues” (page 10) and “unnecessarily
prescriptive” (page 11), they are there to ensure a minimum level of provision, as
are references to adequate light and ventilation in the EYFS. There are
professional and practical reasons for all of these – sufficient space for children to
undertake different activities, the importance of rest routines, working with
parents and developing trusting relationships with them. If they were not there,
providers would ignore them, as has been shown to be the case with access to
outdoor play in the past. The DfE’s over-emphasis on regulation detracts from
the key issue of reducing costs for parents whilst protecting the quality of
provision.
116101334
Created: 13 February 2013/KDR/SA
12 February 2016
Ofsted Inspection
43.
The NUT agrees that more HMIs should be recruited to improve the quality of
inspection. A key priority must be to improve the quality of the inspectorate, as
there are far too few early years specialists working as either HMIs or contracted
inspectors. NUT members report that this lack of experience can often lead to
misunderstandings and inappropriate recommendations, as these inspectors are
not fully aware of the differences between practice in the early years and
compulsory school age sectors. It is not enough to simply recruit more people –
they must be the right people.
44.
The NUT is equally concerned by the proposal to move to a risk-based approach
to early years inspection. Quality can change extremely quickly in the sector,
especially given the high rates of staff turn-over. It is difficult to see how a deskbased assessment would be able to pick up these kinds of issues. There is not
the same kind of data available as in the compulsory school age sector, where
this model of inspection has not always been successful in identifying issues,
particularly relating to the care and welfare of children. One of the main sources
of information on quality would be local authority early years advisors, yet it is
proposed elsewhere in the document that their role would be severely
diminished.
45.
The NUT supports any proposal which reduces the burden of inspection on
schools, so agrees that early years and school inspection could be integrated
fully in schools which offer additional childcare services. It must be recognised,
however, that a single inspection visit would have to cover two very different
types of provision where use of the same kinds of inspection procedures,
particularly in terms of evidence gathering, would not be appropriate as the two
types of practice should be very different. This proposal may therefore not be as
liberating as More Great Childcare suggests and could cause some practical
difficulties for schools. It might be more sensible, therefore, to present schools
with the option of an integrated single inspection and treat this as a pilot, with
feedback from schools, before completely discontinuing the current
arrangements.
46.
It is planned that settings would be able to request and pay for an early reinspection as “providers should not have to suffer the reputational damage of an
“inadequate” or “satisfactory” Ofsted rating for several months, or even years, if
they believe they have taken rapid action to improve quality” (page 36). This is
simply providing a means for PVI providers to buy their way out of the damage
which the DfE rightly acknowledges that Ofsted can do, in a way that maintained
settings and schools cannot. It is of particular concern that this option would be
available to providers with the very poorest standard of provision and is very
unlikely to be the lever for raising quality which the DfE hopes it might be.
47.
The NUT rejects the notion that Ofsted should be “the sole arbiter of quality”
(page 36-7) and that changes will be made to the statutory guidance for early
education programmes which would enable Ofsted inspection results to be used
to determine eligibility for funding, rather than the current mixture of information
from both Ofsted and LAs. The rationale given for this is that LAs have failed to
pass on £160m of funding, yet no evidence is presented to show that this is a
116101334
Created: 13 February 2013/KDR/SA
12 February 2016
systemic problem or that LAs in general have performed poorly in their quality
assurance functions.
48.
The suggestion on page 35 of More Great Childcare that Ofsted and HMIs would
have a new role to “broker links between weaker providers and outstanding
schools, children’s centres and nurseries” needs far greater explanation. This
goes far beyond Ofsted’s current remit and would be a clear conflict of interest,
as Ofsted also reports on the effectiveness of support received. It also has no
track record in this area of activity, so its efficacy cannot be taken for granted. It
appears to be a clumsy attempt to remove yet another local authority function, an
issue which is considered in more detail later in this response.
49.
It is proposed that “Where child minders are registered with agencies, we do not
envisage Ofsted needing to inspect each of them individually” (page 36).
Instead, Ofsted inspectors would visit a sample of child minders. If child minders
chose to register with Ofsted and continued to operate independently rather than
through an agency, they would continue to be subject to inspection. This is
another example of how the DfE is willing to compromise quality to save relatively
small amounts of money.
50.
This proposal would depend not only on how well the agency monitored its child
minders but also whether Ofsted would be able to assess that and the quality of
the sample accurately using its snapshot inspection approach. It is unlikely that
parents would find this reassuring – a Netmums / NCMA survey14 in 2012
reported that 80 per cent of parents felt that it was ‘very important’ for child
minders to be individually inspected by Ofsted, with a further 14 per cent
considering it ‘quite important’. Seventy-seven per cent said that they would be
less likely to use a child minder if this was no longer the case. Deregulation
would ironically reduce the likelihood of parents using child minders at all.
The Role of Local Authorities
51.
14
It is proposed that all local authority inspection and quality assurance work
currently undertaken would cease. Various reasons for this are given in More
Great Childcare including duplication of Ofsted’s functions and different and/or
contradictory requirements to Ofsted. This shows a lack of understanding that
LAs were intended to play a complimentary role to Ofsted, with LAs having more
focus on building quality and capacity in the sector whilst Ofsted checked
compliance against statutory requirements. LAs’ greater in-depth knowledge of
local provision, gained through regular and on-going engagement with providers,
has been an important source of information for Ofsted. This proposal would
almost certainly destroy the last vestiges of local authority early years advisor
support, which has been invaluable for all types of provider and which deserves
more credit for raising standards in early years provision that it has been given
here.
http://www.ncma.org.uk/news/news/june_2012_news/parents_want_regulated_care.aspx
116101334
Created: 13 February 2013/KDR/SA
12 February 2016
52.
Various examples of how LAs duplicate the work of Ofsted and place excessive
demands on providers are given on page 24, such as requests to “gather
information not required by the EYFS or by Ofsted”. This shows a lack of
understanding that the requirements for all three are different because their
purposes are different. If there are examples of duplication or disproportionate
demands for paperwork, these are examples of poor practice by individual LAs,
not of systemic failures that can only be addressed by dismantling the whole
notion of local authority support, which generally works well.
53.
A further criticism levelled at LAs is that they act as ‘gatekeepers to funding’ and
that there is considerable variation in the amount of funding withheld from
providers. What is missing from this critique is a distinction between money
withheld by LAs to fund some other area of their work and money withheld in
order to provide support services; in the funding arrangements for some
programmes, LAs are told explicitly to withhold funding for poorer quality
providers and to use it for improvement work.
54.
A straightforward distinction should be made between what LAs are able or must
hold back and the selfish or duplicitous practices of LAs which are implied here.
In addition, no consideration is given of the wider context in which local authority
early years services are operating currently. Cuts in central funding, particularly
for Sure Start Children’s Centres, have forced many LAs to look to transfer
money from other revenue streams in order to keep essential early years
services viable. If the DfE is genuinely concerned about this issue, a much
simpler solution would be to ring fence particular early years grants such as the
free entitlement budgets to ensure that rates of funding do not vary so much
across LAs.
Reducing Costs and Achieving Better Value for Money
55.
This is the rationale for the whole package of measures proposed by More Great
Childcare and is supported by a number of comparisons with other European
countries, for example, page 17 says that England’s Government spending on
early years is lower than the Nordic countries, comparable with France and
higher than Germany’s. In fact, the costs of childcare in many European
countries are broadly comparable with those in England, the difference is the
level of state support for childcare, which is much higher on other countries, thus
reducing the price that parents are asked to pay.
56.
In Norway, for example, childcare is heavily subsidised and parents pay no more
than NKr 2,330 (£267) a month for a full time place for their first child, with a
sliding fee scale for any additional children. Government subsidies mean that
parents only pay about 15 per cent of actual costs. In France, government is the
main source of funds for crèches and it also subsidises “nounous” or nannies,
which are employed either on a shared or individual family basis. In Denmark,
poorer families pay nothing for childcare, others pay 10 per cent of their income.
The rest is funded by central block grants, taxation and employer contributions.
116101334
Created: 13 February 2013/KDR/SA
12 February 2016
57.
In the Netherlands, which is cited in More Great Childcare as a positive model for
England in many other respects but not for this one, the costs of funding are
shared between central government, employers and parents, with parents
receiving two thirds of the total care costs via income related childcare tax credits
and employer contributions. Several EU countries operate a cap to childcare
fees in order to reduce the maximum proportion of household income spent on
childcare. Unless Government is more proactive and gives more direct financial
support as in these countries, childcare will remain too expensive for many
families.
58.
It is certainly true that England has some of the most costly childcare in Europe
for parents, with only Switzerland and Ireland having more expensive provision.
What the document does not say is that in all European countries except the UK
and Switzerland, costs are offset by substantial childcare benefits which reduce
the net costs for families, typically targeted at those on low and middle incomes.
This has a direct impact on employment rates for mothers, with only 67.1 per cent
in paid employment in England compared to 73.6 per cent in France, 78.5 per
cent in the Netherlands and 84 per cent in Denmark15. Unaffordable childcare
therefore has an economic cost as well as a social cost.
59.
So what lessons can by learnt from international comparisons? Childcare funding
needs to be simplified, not made more complex. The best way to achieve this
would be to give parents or children clear entitlements that are funded directly by
the state rather than through tax relief or vouchers. Instead, in this country the
Government has not only failed to provide universal childcare free at the point of
use, it has also cut tax credits, frozen or withdrawn child benefit, depending on
family income and made childcare even more unaffordable.
Formalisation of Early Education
60.
An assumption runs throughout More Great Childcare that more qualified staff
would mean more ‘formal’ nursery education. The phrase ‘traditional nursery
class’ is used several times in the document without any expectation of what is
meant by it, although it does conjure up images of children sitting at desks and
learning in the same way as much older children. Nothing could be further from
the truth, as any well qualified early years staff member would confirm. Whether
in a ‘traditional’ nursery school or class, pedagogy is determined by the
developmental needs of the children and would certainly not involve the kind of
passive acquisition of knowledge which is implied.
Conclusion
61.
15
More Great Childcare does highlight some major issues which require attention,
in particular the low pay and status of those working in the early years and the
variable quality of provision, especially the lack of access to high quality provision
for those most in need of it. It is unclear, however, how the DfE’s proposals will
address these problems and it is disappointing that the Government has missed
an opportunity to present a coherent strategy for affordable and high quality early
years provision.
http://www.oecd-ilibrary.org/education/education-at-a-glance-2012_eag-2012-en
116101334
Created: 13 February 2013/KDR/SA
12 February 2016
62.
There is nothing in More Great Childcare which specifically addresses the
Government’s stated aim of reducing inequality and promoting social mobility.
There are no quick fixes for these problems, but they need to be central to a
national childcare strategy.
63.
To really support families, Government needs to reverse the childcare tax credit
and other family cuts and compel employers to contribute to childcare costs and
offer more flexible working patterns. It should understand that market systems
drive up childcare costs unless centrally regulated and offer fewer choices for
parents in areas where there is less money in the local economy.
116101334
Created: 13 February 2013/KDR/SA
12 February 2016