Consultation Response Form
Consultation closing date: 10 August 2015
Your comments must reach us by that date

Cost of providing childcare review: call for evidence

If you would prefer to respond online to this consultation please use the following link:

The Department for Education is undertaking a review of the cost of childcare. This call for evidence is part of an evidence gathering exercise and will inform the outcome of the review. The findings from the review will be available in the autumn.

Information provided in response to this consultation, including personal information, may be subject to publication or disclosure in accordance with the access to information regimes, primarily the Freedom of Information Act 2000 and the Data Protection Act 1998.

Recorded information is subject to the provisions of the Freedom of Information Act 2000. However, the Act contains a number of exemptions that allow public authorities to withhold information from a requester, if, for example, disclosure would be likely to prejudice someone’s commercial interests. The Department will apply all exemptions that it considers appropriate to protect sensitive information.

If you want all, or any part, of your response to be treated as confidential, please explain why you consider it to be confidential, and the Department will take your views into account when deciding how it should respond to any request. An automatic confidentiality disclaimer generated by your IT system will not, of itself, be regarded as binding on the Department.

The Department will process your personal data (name and address and any other identifying material) in accordance with the Data Protection Act 1998, and in the majority of circumstances, this will mean that your personal data will not be disclosed to third parties.

/ Please tick if you want us to keep your response confidential.
/ Reason for confidentiality:
/ Name: Anne Fox
/ Please tick if you are responding on behalf of your organisation.
/ 
/ Name of Organisation (if applicable): The Communication Trust
/ Address: 31 Angel Gate, Goswell Road, London, EC1V 2PT

If your enquiry is related to the DfE e-consultation website or the consultation process in general, you can contact the Ministerial and Public Communications Division by e-mail: or by telephone: 0370 000 2288 or via the department's 'Contact Us' page.

Which of the following best describes your role/context? If you wish to provide more detail about your role, please do so in the text box below.


/ Local Authority /
/ Parent /
/ PVI Provider

/ Childminder /
/ Representative Body /
/ School
/ 
/ Other
/ Please Specify:
The Communication Trust is a coalition of over 50 not-for-profit organisations.Working together we support everyone who works with children and young people in England to support their speech, language and communication.Our work focuses on supporting children and young people who struggle to communicate because they have speech, language and communication needs (SLCN) as well as supporting all children and young people to communicate to the best of their ability.

If you are aware of any useful evidence, report, research or analysis on the cost of childcare, please send a copy to:.

1 Please describe below your evidence on the cost of providing childcare.

/ Comments:
The Communication Trust is delighted to have the opportunity to respond to the Government’s ‘Call for Evidence’ to inform its review of the cost of childcare in England. The Trust welcomes the Government’s planned extension of free places and its commitment to give working parents of three and four year olds 30 hours of free childcare a week ‘knowing that their children are well cared for’.
In The Trust’s view, there are two main challenges facing the review:
  • How to significantly improve the skills, knowledge and understanding of the early years workforce to meet the needs of children with SLCN/SEND by ensuring that they are identified and met at the earliest opportunity; and so give their parents equal opportunities to work.
  • How to fairly support the additional costs involved for both nursery and home-based providers in providing tailored and timely support for children with SEND/SLCN.
In conducting the review, we would urge that the following factors are considered in order to ensure that children with SEN and disabled children and their families are not unintentionally discriminated against in accessing the new provision.
The scale of the issue
The Department for Education’s Statistical Release bulletin for January 2014 shows that schools identify nearly 1.5m children with SEN, and that SLCN is the primary type of need (23.8%) affecting over 350,000 children and their families. These numbers are likely to still significantly under-estimate the actual figures and in some areas of social disadvantage studies have found that up to 50% of children entering primary school may have delayed speech and language skills.[1]
The impact on family lives
Children with SEN/SLCN are more than twice as likely to be living in a family that is eligible for free school meals (29.1% compared to 13.4%).[2]One of the main reasons for this is the lack of suitable childcare provision for these families, who may want to work but already struggle to access their free early year’s entitlement. Reports from the charity Working Families indicate that nearly 90% of parents surveyed who do not work, wish to return to work[3] and more than 80% say that the lack of suitable childcare is the main barrier to work.[4] The Department’s own latest survey of parents[5] of disabled/SEN children found that seven out of ten parents describe finding suitable, affordable childcare as ‘very difficult’ or ‘impossible’.
This point is well illustrated in a report from Mowbray School, North Yorkshire – a special school for children with learning difficulties and a full statement of Special Educational Needs, where all 160 pupils from 3-16 encounter a range of communication difficulties. The Deputy Head Teacher says ‘one of the difficulties which our parents encounter is locating childcare providers who have the knowledge and empathy to care for their children’.
The importance of high quality early years provision
Early identification and intervention are essential to ensure that children with SEN/SLCN get the right support in place at the right time. Research identifies that some difficulties, particularly with language, can be resolved or reduced with the correct early support in place.[6] Research also shows that early support is vital in terms of children’s life chances as the impact of not accessing appropriate quality provision can be lifelong, as‘the positive effects of pre-school experience last up to and continue beyond the end of compulsory education’.[7]
However, the latest Early Years Foundation Stage Profile results show that the gap in attainment between children with SEN and children with no identified SEN has widened in the last year from 42% to 47%, with the largest attainment gap in ‘speaking’. This suggests a skills gap in early years training and qualifications and as aconsequence, practitionersmiss and under identify children with difficulties. In one example, despite a highly committed staff team, only 50% of children with SLCN were being accurately identified.[8]One research study found that 60% of teachers reported that they lacked confidence in their ability to meet children’s language needs.[9]
Improving the quality of provision is achievable however. The evaluation of The Communication Trust’s Platform 3 pilot study, which delivered an online early years level 3 qualification, showed that the course improved the quality of early years provision and the effectiveness of practitioners working with children to support speech, language and communication development. The report also shows increased knowledge, skills and confidence of practitioners in being able to identify and support children who were struggling.[10]
The importance of a skilled and qualified workforce
The Communication Trust welcomes the steps that have been taken as part of the SEND reforms to tackle the lack of suitable provision for children with SEN in the early years, through initiatives like the use of SEND champions; peer to peer training, mentored workforce development networks and on-line support. However in the Trust’s view, the scale of the issue is such that a more fundamental workforce reform programme is required.
This needs to build on the Nutbrown Review and the latest research evidence relating to ‘quality’. The Nuffield Foundation’s recent report demonstrated that PVI sector settings with a graduate member of staff scored more highly on all quality measures, with supplementary analysis from Ofsted showing that the most highly graded settings had both a graduate and a high proportion of staff qualified to Level 3 (A level standard).[11]
For this reason, The Communication Trust supports the recommendation of the Read on. Get On. Campaign[12] that every early years nursery is led by an early years graduate by 2020, through increasing the level of the early years pupil premium to the level of the primary pupil premium (limited to those settings that employ early years graduates). Also that every non-domestic setting should have at least one non-graduate member of staff with an appropriate intermediate level qualification in SLC/SEN.
The need to reconcile funding for the childcare entitlement and the SEND reforms
The recent report on SEN funding commissioned by the Department for Education states that some providers were finding it difficult to fund the full free entitlement for children with SEN. This was due to therebeing no reflection within the funding that the cost of meeting the needs of these children was greater than the standard per-child funding they received.[13] Other concerns included the increased demands on staff time involved in multi-agency meetings as a result of the SEND reforms, a lack of clarity about the interaction between SEN funding and the free-entitlement, and a decrease in the support available from the local authority.[14]
The bullet points below were submitted by a member of the The Communication Trust’s Consortium, working with a local authority in the Midlands to implement a whole systems language strategy. They illustrate the ‘additional’ costs incurred by PVI settings that are not covered by the existing 3 and 4 year old funding:
  • Backfill for all staff to attend language development training and ongoing networks to maintain and extend their skills.
  • Time for a Language Lead to ensure the environments are language rich and to maintain quality standards in relation to language development.
  • Time and resources to engage parents with their children’s language development.
  • Time and resources to develop the Language Lead and finance the Level 3 award in Speech, Language and Communication as part of the accreditation process.
  • Time and resources to set up and implement using pictures and symbols in the setting to support children's speech, language and communication development.
  • Time and resources to track children’s progress and provide targeted support for those who have identified needs.
We believe that within the context of reviewing the cost for childcare, it is essential that the ‘hourly rate’ for early years providers reflects such costs, as thesewere either in whole or in part, referred to in the Minister’s own statement that ‘the importance of early identification and intervention cannot be overstated and it is core to the 0-25 reforms’.
We look forward to learning the results of the funding review and would be happy to be contacted to discuss anything raised in this submission further.

Thank you for taking the time to let us have your views. We do not intend to acknowledge individual responses unless you place an 'X' in the box below.

/ Please acknowledge this reply.
/ X
/ E-mail address for acknowledgement:

Here at the Department for Education we carry out our research on many different topics and consultations. As your views are valuable to us, please confirm below if you would be willing to be contacted again from time to time either for research or to send through consultation documents?

/ 
/ Yes /
/ No

All DfE public consultations are required to meetthe Cabinet Office Principles on Consultation

The key Consultation Principles are:

  • departments will follow a range of timescales rather than defaulting to a 12-week period, particularly where extensive engagement has occurred before
  • departments will need to give more thought to how they engage with and use real discussion with affected parties and experts as well as the expertise of civil service learning to make well informed decisions
  • departments should explain what responses they have received and how these have been used in formulating policy
  • consultation should be ‘digital by default’, but other forms should be used where these are needed to reach the groups affected by a policy
  • the principles of the Compact between government and the voluntary and community sector will continue to be respected.

If you have any comments on how DfE consultations are conducted, please contact Aileen Shaw, DfE Consultation Coordinator, tel: 0370 000 2288 / email:

Thank you for taking time to respond to this consultation.

Completed responses should be sent to the address shown below by 10 August 2015

You can contact us byemail at: , or you can write to us at:

Department for Education, Early Years Funding Team, Sanctuary Buildings, Great Smith Street, London, SW1P 3BT.

[1]Locke, A., Ginsborg, J. and Peers, I. (2002) Development and disadvantage: implications for the early years and beyond, International Journal of Language and Communication Disorders, 27(1), p. 3 and p. 9.

[2] Department for Education SFR31/2014Children with Special Educational Needs 2014: An Analysis

[3] Working Families (2015) Off balance

[4] Working Families (2012) Finding flexibility

[5] Department for Education (2014) Childcare and early years survey of parents 2012-14

[6] Bishop D V M and Adams (1990). A Prospective Study of the Relationship Between Specific Language Impairment, Phonological Disorders and Reading Retardation, Journal of Child Psychology and Psychiatry 31

[7] Department for Education Students’ educational and developmental outcomes at age 16 (EPPSE 3-16) Project Research Report

[8] Lee, W. and Wagg, E. (2012) Talk of the Town Evaluation Report: TCT London

[9] Sadler, J. (2005) Knowledge, Attitudes and Beliefs of the Mainstream Teachers of Children with a Pre-school Diagnosis of Speech/Language Impairment Child Language Teaching and Therapy Volume 21, 2.

[10] Baars, S. (2015) The Communication Trust: Platform 3 2013 – 2015 pilot evaluation: LKMco London

[11] Mathers,S. and Smees, R.(2014) Quality and inequality – do 3 and 4 year olds in deprived areas experience lower quality early years provision: Nuffield Foundation

[12] Save the Children (2015) Ready to Read: closing the gap in early language skills

[13] Parish, N. & Bryant, B. (2015) Research on funding for young people with special educational needs, Isos Partnership -

[14] Ibid.