CONSULTATION
RESPONSE
Welsh Government
Draft 10-year plan for the early years, childcare and play
workforce in Wales
15 December 2014
1. The NASUWT welcomes the opportunity to comment on the proposed
Draft 10-year plan for early years, childcare and play workforce in Wales
(the draft 10-year plan).
2. The NASUWT is the largest teachers’ union in Wales and the UK
representing teachers and school leaders.
GENERAL COMMENTS
3. The NASUWT welcomes the ambition of the Welsh Government to provide
a highly skilled workforce to deliver education and care of children in early
years (children aged 0 to 7) but notes that this is set against a background
of a tough economic climate and a need to find efficiencies.
4. The NASUWT recognises that the thrust of proposals relies heavily on
access to high-quality continuing professional development (CPD), the
sharing of good practice and collaboration between settings, but notes the
lack of detail about the provision of time and resources to accommodate
the implementation of such an approach.
5. The NASUWT questions seriously the decision to focus on leadership as
one of the three themes of the draft 10-year plan. The Union maintains
that the Welsh Government concentration on leadership and the
hierarchical structures, ethos and cultures this promotes is damaging the
education service in Wales. Far from creating a culture of increased
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professionalism, the models of leadership that are being encouraged by
the consortia, through the new Model for Regional Working, by Schools
Challenge Cymru (SCC), and by the school inspection system, serve only
to demoralise and de-motivate the education workforce.
6. The NASUWT maintains that the promotion of a collegiate structure and
ethos among the early years, childcare and play practitioners in Wales
would be far more conducive to developing the highly skilled and
enthusiastic workforce envisaged by the Welsh Government than focusing
on command and control leadership approaches.
7. The NASUWT notes that the Welsh Government does not intend to
develop an early years childhood specialist route to Qualified Teacher
Status (QTS) but welcomes the recognition in the draft 10-year plan of the
important role in early years settings for qualified teachers, in both the
maintained and non-maintained sectors. The Union appreciates fully that
this approach contrasts with the approach being taken in England and
Scotland, where qualified teachers have been removed from the early
years workforce to an alarming extent and maintains that the retention of
qualified teachers is vital to achieving the highly skilled workforce
envisaged in the draft 10-year plan.
8. The NASUWT acknowledges the importance of providing children with the
best start in life possible in educational terms. However, the Union is
concerned that the draft 10-year plan appears to place too great an
emphasis on the Literacy and Numeracy Framework (LNF) and the Welsh
Government’s standards agenda, at the expense of the underlying
philosophy of the Foundation Phase.
9. The NASUWT maintains that great care must be taken to ensure that
youngsters are not turned off learning by a target-driven agenda linked to
the LNF and/or deprived of their childhood.
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SPECIFIC COMMENTS
10. The NASUWT offers the observations and comments that follow in relation
to the questions posed on the consultation response form.
The questions below relate to proposals and recommendations set out in the
Draft 10-year plan for the early years, childcare and play workforce. The page
numbers indicated after each question refer to that document.
1.
Leadership
Recommendation 4 of the Foundation Phase Stocktake stated that there
should be:
compulsory training for leaders across the sector including strategic
leaders in the Country, consortia, primary head teachers, advisory
staff, leaders of funded non-maintained settings and services to
support their understanding of the principles and practices of the
Foundation Phase. The training should be bespoke to the audience
taking into account their history and previous experiences and include
research showing how effective implementation of the Foundation
Phase can support standards and impact on social and economic
growth generally.
Question 1 – Do you agree that there should be compulsory training for
leaders to support their understanding of the principles and practices of the
Foundation Phase? (p.21)
Agree
Disagree
Neither agree
nor disagree
Supporting comments
The NASUWT agrees with this proposal on the clear understanding that
those providing the training must:

command the respect of those being trained;

be able to demonstrate a commitment to the underlying
philosophy of the Foundation Phase; and

recognise fully the need to ensure that the Foundation Phase is
not hijacked by the LNF.
Question 2 – Do you agree that the learning hub model as set out in the draft
10-year plan would encourage greater collaboration in the early years,
childcare and play sector and help to support a self-improving network? (p.24)
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Agree
Disagree
Neither agree
nor disagree
Supporting comments
The NASUWT accepts that the learning hub model, as set out in the draft
10-year plan, could provide a useful vehicle to aid collaboration in the
early years, childcare and play sector and could help to support a selfimproving network. However, dedicated time must be provided during
the working day to accommodate access to the learning hub. The early
years, childcare and play workforce must not be expected to access the
learning hub outside of contracted time.
Question 3 – Please consider Recommendations 15 and 16 of the Graham
Review.
Recommendation 15: We recommend that Welsh Government
ensures that regulations are revised to require appropriate Level 5
qualifications for leaders of all newly registered settings from 2018,
and all settings from 2020.
Recommendation 16: We recommend that Welsh Government
introduce regulations that require larger settings (registered for 20
children or more) to have a supernumerary manager should also
require that manager to hold an appropriate Level 5 qualification (with
specific leadership modules) by 2020 and a Level 6 qualification by
2024.
Do you agree with these recommendations? (p.26)
Agree
Disagree
Neither agree
nor disagree
Supporting comments
The NASUWT supports these recommendations in principle. However,
the Union maintains that the Welsh Government must also ensure that
those practitioners who are required to hold such qualifications are
provided with commensurate remuneration which is governed by a
national pay and conditions structure across the early years, childcare
and play sector. However, the Union is clear that for teachers and
headteachers working in this sector, the School Teachers’ Pay and
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Conditions Document (STPCD) must apply.
The NASUWT maintains that where existing leaders would be required
to obtain these qualifications, they must be provided with study time
within the working day to do so.
Question 4 – Do you agree that the proposed Level 6 qualification would
equip practitioners with the necessary knowledge and skills to lead and
deliver high-quality practice? (p.26)
Agree
Disagree
Neither agree
nor disagree
Supporting comments
In the absence of any detail about the content of the course that would
lead to this qualification, the NASUWT is unable to answer the question
directly.
However, the Union notes that the intention for the Level 6 qualification
is that it could be undertaken through both work-based learning and a
higher education institution route providing an option for part-time or
full-time study.
The NASUWT maintains that where existing leaders would be required
to obtain this qualification, they must be provided with study time within
the working day to so, whichever route they chose to follow.
Further, the Union questions why the further education sector could not
provide this training.
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2.
Attracting high-quality new entrants
Question 5a – Do you agree that it would be beneficial for pre-entry
information sessions to be extended to cover the requirements and
opportunities of working in all types of settings in the early years, childcare
and play sector? (p.32)
Agree
Disagree
Neither agree
nor disagree
Supporting comments
The NASUWT agrees with this proposal in principle but notes that scant
regard is paid to the level of remuneration that would be on offer to
attract high-quality new entrants.
The Union maintains that establishing a national pay and conditions
structure across the early years, childcare and play sector is essential to
attracting new entrants of the quality envisaged.
However, the NASUWT issues a note of caution here as such an
approach could result in the cost of childcare increasing unless the
sector is subsidised heavily by the Welsh Government.
Question 5b – If you agree, please provide information as to how these
sessions could most effectively be extended and delivered. (p.33)
Supporting comments
The NASUWT maintains that the issues raised in answer to question 5a
would need to be addressed before consideration is given to extending
these sessions.
Question 6 – Do you agree that a structured induction process should be the
first stage in a personal development plan for all new entrants to the sector
and that completion of this should be recorded in a continuous professional
development (CPD) portfolio? (p.33)
Agree
Disagree
Neither agree
nor disagree
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Supporting comments
The NASUWT is sympathetic to the proposal in principle but is
concerned that it may only serve to create unnecessary bureaucracy
around early years, childcare and play provision.
The Union maintains that major investment by the Welsh Government
would be needed to ensure that the introduction of a structured
induction process, as the first stage of a personal development plan, did
not impact adversely on the workload of the practitioners involved.
Further, the NASUWT is concerned that this approach could result in the
early years, childcare and play sector being distracted from their work to
satisfy paper trails.
Question 7 – Do you agree that any future Level 6 qualification should be
complemented by a Graduate Level Certificate in Leadership in Childhood
Practice to enable graduates to gain a competency qualification at an
appropriate level and to practice in the sector on completion of their degree?
(p.33)
Agree
Disagree
Neither agree
nor disagree
Supporting comments
The NASUWT is concerned that this approach could present a barrier to
extending childcare and play provision across Wales.
Further, the Union maintains that for early years practitioners in school
settings, the qualification could be enshrined in the National Profession
Qualification for Headship (NPQH) and within initial teacher training
routes leading to qualified teacher status.
Question 8a – Do you support the ambition to see Level 3 in a relevant
qualification become the acceptable standard for all practitioners in the sector
over time? (p.34)
Yes
No
Unsure
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Supporting comments
The NASUWT supports this approach in principle but maintains that it
must be complemented by the introduction of a national pay and
conditions structure for those working in the early years, childcare and
play sector.
The Union is aware that, currently, pay and conditions are low across all
levels of the sector.
The NASUWT is, therefore, concerned that the ambition of the Welsh
Government to attract and retain a highly skilled workforce will remain
largely unrealisable in practice until this issue is addressed and funded
and/or subsidised, as appropriate.
Question 8b – Do you agree with the phased introduction of this requirement,
in two stages over a 10-year period? (p.34)
Agree
Disagree
Neither agree
nor disagree
Supporting comments
The NASUWT supports this approach in principle but maintains that it
must be complemented by the introduction of a national pay and
conditions structure for those working in the early year, childcare and
play sector.
The Union is aware that, currently, pay and conditions are low across all
levels of the sector.
The NASUWT is, therefore, concerned that the ambition of the Welsh
Government to attract and retain a highly skilled workforce will remain
largely unrealisable in practice until this issue is addressed and funded
or subsidised, as appropriate.
Question 9 – In your view, is it appropriate for childminders to achieve a
relevant Level 3 qualification within three years of their initial registration?
(p.34)
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Yes
No
Unsure
Supporting comments
The NASUWT recognises the merit of the proposals but maintains that
the responsibility for ensuring the provision of opportunity to gain the
qualification would rest with the Welsh Government.
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3.
Raising skills and standards across the existing
workforce
Question 10 – Do you agree that the workforce would benefit from a set of
overarching CPD principles and individual online portfolios to record learning
and development? (p.41)
Agree
Disagree
Neither agree
nor disagree
Supporting comments
The NASUWT agrees with this proposal in principle but would expect
time to be provided in the working day to access and record the training
and development.
The Union would expect to be involved in the development of the
overarching CPD principles and the online portfolios to ensure that
neither impact adversely on the workload or work/life balance of the
practitioners.
As stated elsewhere in this response, the NASUWT is concerned that
this approach could result in the early years, childcare and play sector
being distracted from their work to satisfy paper trails.
Question 11a – In your view, should there be a system of professional
registration for the non-maintained sector? (p.41)
Yes
No
Unsure
Supporting comments
The NASUWT acknowledges that the non-maintained sector should be
subject to the same scrutiny as the maintained sector.
Question 11b – If yes, how could this system be monitored? (p.41)
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Supporting comments
The NASUWT recognises that the Education Workforce Council (EWC)
would be the appropriate body to register and regulate practitioners in
the early years, childcare and play sector in both the maintained and
non-maintained sector.
However, the Union is clear that this role should not extend to the
registration of private providers or the provision of CPD or records of
professional development or training within both the maintained and
non-maintained sectors.
Question 12a – Please consider Recommendation 12 of the Foundation
Phase Stocktake, which called the Welsh Government to:
Develop training that ensures all staff understand the research on the
effects of disadvantage and poverty and the possible ways to close
the achievement gap. Sharing good practice from those maintained
schools and funded non-maintained settings where this is working well
should be part of the training and so should research on supporting
the home learning environment (HLE). Maintained schools could be
asked to devote some of their Pupil Deprivation Grant (or similar) to
support staff development here.
Would training on the effects of disadvantage be of benefit to practitioners and
teachers in the Foundation Phase? (p.44)
Yes
No
Unsure
Supporting comments
The NASUWT accepts that such training could be of benefit to
headteachers,
teachers
and
other
practitioners
working
in
the
Foundation Phase.
However, the Union is clear that those providing the training must:

command the respect of those being trained;

be able to demonstrate a commitment to the underlying
philosophy of the Foundation Phase; and
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
recognise fully the need to ensure that the Foundation Phase is
not hijacked by the LNF.
Question 12b – Who would be best placed to develop and deliver this
training? (p.44)
Supporting comments
The NASUWT is clear that the training should be provided by
experienced practitioners who satisfy the criteria listed in answer to the
previous question.
Question 13 – Do you agree that that the proposed ‘stepped approach’ to upskilling could potentially help to address the appetite within the early years,
childcare and play workforce to further learning and development? (p.44)
Agree
Disagree
Neither agree
nor disagree
Supporting comments
The NASUWT recognises the obvious advantage of a ‘stepped
approach’ to developing the skills of the early years, childcare and play
workforce but maintains that it should be acknowledged that many
practitioners would have no desire or appetite to aspire to leadership
roles.
Question 14 – Please consider Recommendation 18 of the Foundation
Phase Stocktake, which stated that the Welsh Government should:
Review the current adult to child ratio in reception classes. Currently it
is 1:8, primary schools’ staff, advisors and inspectors agreed that it
could be increased to 1:10 without affecting quality. However, some
schools may need to apply for an exception where, for example, they
are situated in very rural areas or where they have a considerable
number of children with additional needs such as SEN or E/WAL as it
would not be practical to increase the ratio.
Do you agree with this recommendation to change adult to child ratios in
reception classes in schools? (p.46)
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Agree
Disagree
Neither agree
nor disagree
Supporting comments
The NASUWT objects in the strongest possible terms to this proposal as
it presents little more than an exercise in cost-cutting.
The Union reminds the Welsh Government that the adult-to-pupils ratios
were introduced as a cheaper alternative to providing the teacher-pupil
ratios proposed by the proponents of the Foundation Phase.
The NASUWT maintains that this proposal has the potential to
undermine the basis of the draft 10-year plan.
Question 15a – Do you agree that a Grade C GCSE, or equivalent, is the
appropriate minimum level of essential skills for those working within the early
years, childcare and play workforce? (p.47)
Agree
Disagree
Neither agree
nor disagree
Supporting comments
Although it is acknowledged that this would provide a minimum
standard that could be considered appropriate for those working in the
early years, childcare and play workforce, the NASUWT cautions that the
approach should be equality impact assessed.
Question 15b – Should these skill levels be a requirement on entry to the
sector (rather than achieved while working, within a fixed time period)? (p.47)
Yes
No
Unsure
Supporting comments
The NASUWT maintains that a degree of flexibility may be necessary
here to avoid stifling the enthusiasm of would-be early years, childcare
and play practitioners.
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Question 16 – Do you agree that the Welsh language support as set out in
this draft plan would help to promote greater use of the Welsh language in
schools/settings? (p.47)
Agree
Neither agree
nor disagree
Disagree
Supporting comments
The NASUWT recognises the merit of the proposal.
The Union notes that this proposal is about increasing practitioner
confidence in the use of Welsh in English-medium early years and
childcare settings and is comfortable with this approach, as it appears
far more realistic, pragmatic and less controversial than the ambition set
out in the consultation document that suggests the establishment of a
bilingual workforce in the early years, childcare and play sector.
Question 17 – We have asked a number of specific questions. If you have
any related issues which we have not specifically addressed, please use this
space to report them:
Please enter here:
The NASUWT questions seriously the timing of the draft 10-year plan as
other initiatives, such as the Donaldson and Furlong Reviews, the New
Deal on professional development for the education workforce, the
introduction
of
the
Early
Years
Development
and
Assessment
Framework (EYDAF), and the requirement for support staff to register
with the newly formed EWC, could all impact on the plan.
The Union is concerned that ambition has been allowed to override
pragmatism in the construction of the draft 10-year plan. Consequently,
the NASUWT urges the Welsh Government to reflect carefully before
progressing with the draft 10-year plan.
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Chris Keates (Ms)
General Secretary
For further information on the Union’s response, contact Rex Phillips, Wales
Organiser.
NASUWT Cymru
Greenwood Close
Cardiff Gate Business Park
Cardiff
CF23 8RD
029 2054 6080
www.nasuwt.org.uk
nasuwt@mail.nasuwt.org.uk
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