Consultation closing date: 22 May 2014
Your comments must reach us by that date
Childminder agencies and changes to the local authority role
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/ Name: Shona Crichton
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/ Name of Organisation (if applicable): The Communication Trust
/ Address: 8 Wakley Street, London, EC1V 7QE
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Please mark the box that best describes you as a respondent.
(If 'Other' please specify in box below)
/ Local Authority /
/ Childminder /
/ Parent/Carer
/ Private/voluntary provider full day care /
/ Independent school /
/ Childcare or early years organisation
/ Private/voluntary provider sessional /
/ Breakfast/After school club /
/ Maintained nursery school
/ Holiday activity provider /
/ Maintained nursery class /
/ Employer
/ Network childminder / X
/ Other
/ Please Specify: Third sector organisation
INTRODUCTION
This consultation seeks views on changes to the provision of early education and childcare as a result of measures in the Children and Families Act 2014. These measures were fully debated by Parliament during the passage of the Children and Families Bill.The measures in the Bill were set out in the report 'More Great Childcare', published by the Department for Education on 29th January 2013 and More Affordable Childcare published on 16th July 2013.
The consultation document is in two parts:
Part A seeks views on the key requirements for registration with Ofsted for anyone wanting to set up a childminder agency. This consultation focuses on some technical aspects of how they will operate, rather than the concept of agencies which was fully debated during the passage of the Children and Families Bill. We therefore welcome responses to the specific issues addressed. Views on the policy itself are out of scope for this consultation.
Part B seeks views on regulations which make changes to the way local authorities discharge their duty under section 7 of the Childcare Act 2006 to secure early years provision, free of charge, for eligible children in their area. It also seeks views on draft statutory guidance for local authorities under the Childcare Act 2006 related to early education and childcare.
Please note the regulations do not change the existing policy on how local authorities discharge that duty which is set out in the department’s current statutory guidance. This policy has previously been consulted on and views on the policy itself are out of scope of this consultation.
Part A: Childminder agency key requirements
The government is proposing in the draft regulations that childminder agencies secure 16 hours of CPD per year for early years childminders (those delivering the EYFS) or 8 hours per year for later years childminders (those working with older children or outside the EYFS) registered with them.
1 Do you agree with the suggested hours of CPD?
/ Agree, the level is about right / X
/ Disagree, the level is too low /
/ Disagree the level is too high
/ Not sure
/ Childminders who are registered with a childminder agency will require access to support relating tosafeguarding and welfare and business as well as support that allows them to develop their skills aroundchildcare/early education. The Communication Trust is concerned that crucial CPD for childminders around speech, language and communication development and identifying and supporting those with speech, language and communication needs would not be part of a limited CPD programme consisting of only 16 hours per year and that this suggested number of hours needs to be significantly increased. The 2012 Nutbrown review highlights the fact that, currently, childminders do not have qualification requirements and that there are fewer childminders qualified at level 3 than across the early years workforce as a whole, highlighting the requirement for an increase in CPD hours for childminders to develop their skills.
A further argument for a significant increase in CPD hours for childminders is based on the knowledge that there will need to be an increase in 2 year old places in less affluent areas and that childminders are less strongly represented in less affluent areas of the country. It’s therefore important that these limited childminder places are high quality for two reasons: 1) there will be less choice in areas of disadvantage and 2) the children who these childminders will be seeing will be more likely to have speech, language and communication needs (SLCN) as SLCN is more prevalent in areas of disadvantage.
Communication and language is one of the 3 prime areas of the EYFS and therefore CPD in this area should be a priority, especially when considering the EYFSP attainment results published in October 2013 stating that by the end of their foundation stage education, only 52% of pupils achieved a good level of development across the 3 prime learning areas, including 28% of children who don’t reach the expected level in communication and language. This indicates that lots of children struggle with their speech, language and communication development and highlights the importance of nurturing these skills from a very early age. Speech, language and communication iscrucial for babies’ and young children’s development and childminders who are supporting these children play a crucial role supporting essential speech, language and communication skills.
Supporting speech, language and communication skills to develop effectively is even more critical in areas of social deprivation where children achieve lower attainment levels; only 36% of children eligible for free school meals achieve a good level of development at the end of the EYFS. In some areas of deprivation, up to 50% of children are starting school without reaching the expected speech, language and communication milestones for their age.
In addition, recent EYFSP attainment results have shown that there is an attainment gap of 46 percentage points between the speaking skills of children with and without identified SEN. This provides a strong indication that childminders don’t only require support to ensure that all children in their care receive optimal support for the development of their speech, language and communication needs, but also that they are enabled to access specific CPD opportunities that will allow them to support the language and communication needs of those children in their care who have identified SEN.
Prevalence statistics surrounding SLCNdemonstrate the need for childminders to receive CPD in this area and to develop their skills in both identifyingand supporting children with SLCN. In some areas of deprivation, up to 50% of children will have SLCN at the time of starting school, while 7% of children have a specific language impairment, making it the most prevalent childhood disability. Childminders need access to a wide range of fully accessible CPD opportunities to ensure that they have the correct level of training, advice and support to enable them to support children with SLCN. If childminders feel under confident and unskilled in supporting children with SLCN, they may be less likely to offer places to these children, therefore limiting childcare places for those children with SLCN. This is already an issue for parents of children who have a disability, whereby only 40% of parents with a child with a disability feel that thereare childcare providers in their local area who could cater for their child’s disability. There is clearly already a deficit in ensuring that early years childcare providers are skilled and confident in managing children with disabilities and increasing CPD opportunities are a way to develop these skills within the early years workforce. With the correct support in place, children with identified, persistent SLCN will make gains.
We know that on the EYFSP scales, measures of communication, language and literacy are the best predictors of later attainment, therefore it is essential that childminders are supported to develop these skills as part of their CPD.
Research has shown that if language difficulties are resolved by age 5, this reduces associated later literacy difficulties and also that children who have unresolved SLCN are more at risk of behaviour, social and emotional difficulties.
It may be the case that older years’ childminders can access fewer hours of CPD support, as the children they are looking after will also be supported in school; however 8 hours is not enough. Even for school age children, childminders have the potential to play a crucial role in identifying needs that are not picked up at school. School staff do not always identify SLCN –research has shown that schools only identify 1.6% of pupils as having a primary SLCN and we know from prevalence figures that the prevalence of SLCN as a primary need is far greater than that. Older year childminders will benefit from CPD opportunities not only to identify needs in an older age group, but also to increase their knowledge of key strategies to support children who have identified SLCN.
The Communication Trust would be happy to have further discussions to support with decisions regarding CPD hours and content in relation to speech, language and communication development and SLCN.
In the draft regulations, the government sets out specific proposals around support time and visits that childminder agencies must undertakefor early years and later years childminders registered with them.
In relation to early years childminders, we are proposing that:
- agencies be required to secure 20 hours support time per year;
- that the support time may include CPD activity delivered by the CMA; and
- that the support time should include at least two visits for early years childminders in their first year of operation but that agencies be free to scale these down to a minimum of one visit per year once they are satisfied as to the childminder’s quality.
In relation to later years childminders, we are proposing that:
- agencies be required to secure 10 hours support time per year;
- that the support time may include CPD activity delivered by the CMA; and
- that the support time should include at least one visit per year.
2 Do you agree with the number of hours of support time and the number of visits by childminder agencies to their registered childminders?
/ Agree, this level is about right / X
/ Disagree, think this is too low /
/ Disagree, think this is too high
/ Not sure
/ It is essential that support time offered by childminder agenciesincludes regular, direct support meetings with the childminders who are registered with them. These meetings need to be regular enough to ensure that childminders are able to discuss their support and training needs, any concerns that they have about the children in their care and to reflect on their everyday practice in relation to children’s speech, language and communication development.
There need to be clear and robust guidelines as to who carries out support visits/meetings. This needs to be done by someone from the agency who is qualified as a minimum with an early years level 3 qualification which meets the full and relevant level 3 criteria and who has at least 2 years’ experience of working in an early years setting. We see childminder agencies as an opportunity for childminders who don’t hold level 3 early years qualifications to be supported by a qualified colleague to support their development, as we know that a better qualified workforce means that children achieve better outcomes (More Great Childcare 2013).
High quality, regular support and supervision is essential to ensure that childminders are enabled to identify children with SEN or SLCN – in areas of disadvantage (where we know there are already fewer childminders) 50% of children may be presenting with a speech and language delay. These children will need to access appropriate, timely support to prevent this delay becoming entrenched and having a significant impact on their later development and long term educational outcomes. Childminders also need support to ensure that they can access advice, supervision and training for the 10% of children with long term SLCN and the 7% who present with specific language impairment.
Early identification of SLCN and supporting all children’s speech, language and communication skills are essential, particularly for those children who are from disadvantaged backgrounds – appropriate early intervention is a solution to breaking the cycle of disadvantage where poor language skills lead to poor life chances. This will mean that particularly in areas of social disadvantage, childminder agencies need to be in a strong position to offer robust support opportunities to ensure that these children are receiving the early intervention that they require to allow them better life chances. A growing body of evidence has shown that early language skills can predict later performance, for example language skills at 2 years old predict children’s performance on entry to primary school. The majority of language delayed children will catch up with their peers with the right support, whereas without the correct support their difficulties can persist and have a greater impact later in life. A range of evidence based interventions, approaches and training packages are available to support childminders in understanding and supporting these children, though without the appropriate level of training and support, it is highly unlikely childminders would be aware of the available support
It is important to consider that the amount of support time available to childminders needs to reflect that childminders are remote from their agencies and they will be working autonomously without access to spontaneous discussions with senior colleagues about the children they are working with, which may happen daily in a different early years setting. Support time is essential to ensure that childminders have the opportunity to engage in supervision, reflective practice and to raise concerns and follow procedures about children in their care who they have concerns about.
3 Do you agree that childminder agencies should only have to undertake a minimum of one visit per year after the first year based on their assessment of the quality of the childminder?
/ Yes / X
/ No /
/ Not sure
With the right level of support and guidance, the Trust feels that agencies could be in a position to facilitate early SLCN/SEN identification and intervention. They could provide an opportunity for their registered childminders to develop and build on good practice in relation to encouraging speech, language and communication development and identifying and supporting those children with SEN/SLCN, while increasing the quality of the workforce. In order for childminder agencies to make the most of these opportunities and to quality assure their childminders, yearly visits are not enough.
Regular visits will allow childminders to reflect on their own practice and continue to improve the quality of their setting, therefore leading to better outcomes for the children in their care. Ongoing professional development and support is crucial for childminders. As highlighted above, the role of CPD and support opportunities are crucial to maintain quality of care, particularly for those childminders who are in less affluent areas, who are less likely to hold qualifications, yet who will be supporting our most vulnerable 2 year olds, 50% of whom may have SLCN. Regular support visits will ensure that childminders are supported to develop the quality of their setting, which will then have an impact on speech, language and communication development and in turn on the later academic attainment, literacy, behaviour, social and emotional development of the children in their care.
As early years in particular is such a crucial time for identifying needs and providing early intervention, visits need to be regular enough to ensure that needs are identified as soon as possible to help to avoid children ‘slipping through the net’. Childminder agencies therefore need robust mechanisms to ensure that childminders are enabled to identify and support children who have speech, language and communication needs.
In addition, because of the range of SLCN and its prevalence, it’s important that visits are regular to ensure that high quality childcare is being provided to allow all children to achieve optimal speech, language and communication development, including those with SLCN.
The Government proposes that childminder agencies will have to meet a number of requirements in order to register with Ofsted and operate as an agency. These are set out in the draft regulations which form part of this consultation. The matters here will be of particular interest to anyone interested in establishing a childminder agency, but we are grateful for all comments.