CAREWEST LTD. RESPONSE TO PRODUCTIVITY COMMISSION DRAFT REPORT ON CHILDCARE

Please find response to the Productivity Commission Draft Report into Child Care from CareWest Ltd, dated Friday 5th September 2014.

This response includes a number of comments (italicised) made by our early childhood educators employed in our preschools working face to face with children every day.

Families using mainstream services — improving the accessibility, flexibility and affordability

draft recommendation 12.2

The Australian Government should combine the current Child Care Rebate, Child Care Benefit and the Jobs Education and Training Child Care Fee Assistance funding streams to support a single child-based subsidy, to be known as the Early Care and Learning Subsidy (ECLS). ECLS would be available for children attending all mainstream approved ECEC services, whether they are centre-based or home-based.

“Having a single subsidy to overarch CCR, CCB & Jet is certainly a more effective way to go within systems.”

CareWest broadly supports this recommendation as it will make it easier for families and it does simplify the current complicated system. However, we express concern at the fact that it would only be available for “approved services” i.e..long day care. family day care. Preschools, including mobile services are currently classed as “registered care”, and limited CCB is currently available.

CareWest recommends that the Early Care and Learning Subsidy be available for both approved and registered care.

draft recommendation 12.4

The Australian Government should fund the Early Care and Learning Subsidy to assist families with the cost of approved centre-based care and home-based care. The program should:

  • assist with the cost of ECEC services that satisfy requirements of the National Quality Framework
  • provide a means tested subsidy rate between 90 per cent and 30 per cent of the deemed cost of care for hours of care for which the provider charges
  • determine annually the hourly deemed cost of care (initially using a cost model, moving to a benchmark price within three years) that allows for differences in the cost of supply by age of child and type of care
  • support up to 100 hours of care per fortnight for children of families that meet an activity test of 24 hours of work, study or training per fortnight, or are explicitly exempt from the criteria
  • pay the assessed subsidy directly to the service provider of the parents’ choice on receipt of the record of care provided.

“I am for simplifying the government funded subsidy payment to parents. Yes, I think the subsidy should be means tested on an agreed cost of care and this needs annual adjustment and review. I agree that funding should be provided to those services that meet the NQF.”

However, CareWest notes that again this recommendation only refers to approved care services. CareWest agrees with means testing. We remain unsure of what “deemed cost of care” refers to. Will this be according to the market, or a standardised cost that takes into account the age of the child and the type of care provided? Not sure what the 100 hours clause means in respect of families who don’t meet the work test. Does this mean that the most disadvantaged children can’t access?

draft recommendation 12.3

The Australian Government should exempt non-parent primary carers of children, and jobless families where the parents are receiving a Disability Support Pension or a Carer Payment from the activity test. These families should still be subject to the means test applied to other families.

CareWest is concerned that there is no mention of those unemployed parents who may be on Newstart allowance?

draft Recommendation 8.3

The Australian Government should abolish operational requirements that specify minimum or maximum operating weeks or hours for services approved to receive child-based subsidies.

Agree as long as services that are open for many hours, and/or overnight, are still subject to strict quality control.

draft recommendation 8.4

The Australian Government should remove caps on the number of occasional care places.

CareWest disagrees with this recommendation. This could mean that we could have large occasional care only places and/or many occasional children accessing mainstream services. We would consider that there may be adverse impacts to quality of care and secure attachment for children.

draft REcommendation 8.5

Governments should allow approved nannies to become an eligible service for which families can receive ECEC assistance. Those families who do not wish their nanny to meet National Quality Standards would not be eligible for assistance toward the costs of their nanny.

National Quality Framework requirements for nannies should be determined by ACECQA and should include a minimum qualification requirement of a relevant (ECEC related) certificate III, or equivalent, and the same staff ratios as are currently present for family day care services.

Assessments of regulatory compliance should be based on both random and targeted inspections by regulatory authorities.

“No I don’t agree that nanny care should be subsidised. I believe the system would be rorted and it would be too hard to assess and regulate nannies within the NQF. If we include Nanny care I believe the standing of our profession as early childhood teachers may be diminished in the eyes of the community.”

CareWest does not support this recommendation. This would mean that anyone can get a Cert 111 and set up as a nanny without the supervision of more highly qualified early childhood staff as in presently the case in Family Day Care schemes. Nannies operating in private homes would be difficult to police (especially in terms of numbers and ages of children in care) and to effectively monitor compliance with the NQF is unrealistic. CareWestbelieve this is a backwards step for children and for the maintenance of high quality for children in the early childhood sector.

draft REcommendation 8.7

The Australian Government should simplify working holiday visa requirements to make it easier for families to employ au pairs, by allowing au pairs to work for a family for the full 12 month term of the visa, rather than the current limit of six months.

CareWest disagrees with this recommendation in the context of assessing quality early education and care. Whilst some families may employ au pairs to mind children for short periods of time, they should not be a substitute for properly regulated and high quality education and care for young children. If au pairs can work for 12 months in the early childhood sector, they should they be required to have some basic childcare training e.g. Cert 111.

Additional needs children and services — improving the accessibility, flexibility and affordability

DRAFT Finding 5.1

Generally, Australian children are doing well developmentally and most are well prepared to begin formal schooling. Those who are less well prepared tend to be Indigenous children, children living in socio-economically disadvantaged communities, children living in very remote areas and children from non-English speaking backgrounds. There is likely to be overlap across these groups.

CareWestwould like to take issue with this statement on the basis of findings in the AEDI National Report 2012 which found that 22% of all Australian children are developmentally vulnerable in at least one measure of the AEDI, and Aboriginal children are twice as vulnerable at 44% on one or more measure. To say that Australian children are doing well when 1 in 5 or 1/5 are clearly not, is gilding the lily. The situation for Aboriginal children, disadvantaged children and those living in very remote communities is truly appalling – a National shame. We cannot accept the statement that these children are simply “less well prepared”.

draft recommendation 12.6

The Australian Government should establish three capped programs to support access of children with additional needs to ECEC services.

  • The Special Early Care and Learning Subsidy would fund the deemed cost of meeting additional needs for those children who are assessed as eligible for the subsidy. This includes funding a means tested proportion of the deemed cost of mainstream services and the ‘top-up’ deemed cost of delivering services to specific groups of children based on their needs, notably children assessed as at risk, and children with a diagnosed disability.
  • The Disadvantaged Communities Program would block fund providers, in full or in part, to deliver services to specific highly disadvantaged community groups, most notably Indigenous children. This program is to be designed to transition recipients to child-based funding arrangements wherever possible. This program would also fund coordination activities in integrated services where ECEC is the major element.
  • The Inclusion Support Program would provide once-off grants to ECEC providers to build the capacity to provide services to additional needs children. This can include modifications to facilities and equipment and training for staff to meet the needs of children with a disability, Indigenous children, and other children from culturally and linguistically diverse backgrounds.

“I agree with the 3 types of capped funding programs suggested.”

CareWest agrees with all of the above recommendations, as long as the funded amounts are sufficient to meet the need, and funding is made available to preschools and mobile services as well as approved services.

draft recommendation 12.7

The Australian Government should continue to provide support for children who are assessed as ‘at risk’ to access ECEC services, providing:

  • a 100 per cent subsidy for the deemed cost of ECEC services, which includes any additional ‘special’ services at their deemed cost, funded from the Special Early Care and Learning Subsidy program
  • up to 100 hours a fortnight, regardless of whether the families meet an activity test
  • support for initially 13 weeks then, after assessment by the relevant state or territory department and approval by the Department of Human Services, for up to 26 weeks.

ECEC providers must contact the state or territory department with responsibility for child protection within one week of providing a service to any child on whose behalf they apply for the ‘at risk’ Special Early Care and Learning Subsidy. Continuation of access to the subsidy is to be based on assessment by this department, assignment of a case worker, and approval by the Department of Human Services. The Australian Government should review the adequacy of the program budget to meet reasonable need annually.

CareWest supports all of the above recommendations. This is a positive step in the right direction for “at risk” children.

draft recommendation 12.8

The Australian Government should continue to provide support for children who have a diagnosed disability to access ECEC services, through:

  • access to the mainstream ECEC funding on the same basis as children without a disability and up to a 100 per cent subsidy for the deemed cost of additional ECEC services, funded from the Special Early Care and Learning Subsidy
  • block funded support to ECEC providers to build the capacity to cater for the needs of these children, funded through the Inclusion Support Program.

The relevant Government agency should work with the National Disability Insurance Agency and specialist providers for those children whose disability falls outside the National Disability Insurance Scheme, to establish a deemed cost model that will reflect reasonable costs by age of child and the nature and extent of their disability. Based on an assessment of the number of children in need of this service, and the costs of providing reasonable ECEC services, the Australian Government should review the adequacy of the program budget to meet reasonable need annually.

“There should be a consistent funding criteria for Commonwealth and state programs to support services that have children with additional needs enrolled. ISS funding should be increased to 100 hours per fortnight, and ISS funding be made available for children with high medical needs. IPSP funding should be amended to support children without a diagnosis who present with challenging behaviours or extreme anxieties. There should be greater consistency of assessment practices for students completing early childhood qualifications to ensure that theyhave the capacity to work effectively with children with additional needs.”

“I would recommend additional funding to support children with additional needs, and argue in favour of this in relation to the hundred hours, though an element of flexibility should be considered for regional/remotely based services. I would also like to see emergency funding (approx. 10 weeks/1 term) for non diagnosed children who may display challenging behaviours or who have suffered trauma.”

CareWest supports these recommendations.

draft recommendation 13.1

The Australian Government should continue support for the current block funded ECEC services for Indigenous children to assist their transition to mainstream ECEC funding (where there is a viable labour market).

Regulatory authorities should work with providers to assist them in satisfying the National Quality Framework and managing the transition to child-based funding arrangements.

CareWest offers basic support for this recommendation, on the basis that assistance will continue to be provided to those services where parents are unable to pay for the cost of care.

draft Recommendation 5.2

Governments should plan for greater use of integrated ECEC and childhood services in disadvantaged communities to help identify children with additional needs (particularly at risk and developmentally vulnerable children) and ensure that the necessary support services, such as health, family support and any additional early learning and development programs, are available.

“An integrated, holistic approach in particular for isolated areas I have sense is the way forward for these communities in real need of assistance not only for early childcare education but in all areas for the children and families.”

“A broad concept, ensuring that no disadvantaged or vulnerable children in families are worse off through this process – particular concerns about the proposal to increase the work-study activity test to 24 hours per fortnight.”

CareWest agrees with this recommendation. Integratedservice provisionwith a holistic approach is good for children and families, and particularly good for disadvantaged families who may be facing a multitude of complex issues. CareWest recommends that where possible, integrated services are located within local schools.

draft recommendation 12.5

The Australian Government should establish a capped ‘viability assistance’ program to assist ECEC providers in rural, regional and remote areas to continue to operate under child-based funding arrangements (the Early Care and Learning Subsidy and the Special Early Care and Learning Subsidy), should demand temporarily fall below that needed to be financially viable. This funding would be:

  • accessed for a maximum of 3 in every 7 years, with services assessed for viability once they have received 2 years of support
  • prioritised to centre-based and mobile services.

CareWest agrees with the concept of viability assistance for services in regional and remote areas, and recommends this commences as soon as possible. Not every service in remote locations experiences constant demand. CareWest agrees that mobile services are likely to be best placed to respond to changing demand and community demographics. Mobile services can be set up relatively quickly when demand is high, but can also be relocated when demand slows.

Preschool — supporting universal access

draft recommendation 12.9

The Australian Government should continue to provide per child payments to the states and territories for universal access to a preschool program of 15 hours per week for 40 weeks per year. This support should be based on the number of children enrolled in state and territory government funded preschool services, including where these are delivered in a long day care service.

The Australian Government should negotiate with the state and territory governments to incorporate their funding for preschool into the funding for schools, and encourage extension of school services to include preschool.

“I believe the states should fund universal access to 15 hours of preschool one year prior to the start of school in all states of Australia, but I do not believe that parents should be punished by losing FTB if they chose not to take it up.”

“Support the recommendation that the Commonwealth should continue to fund 15 hours preschool, to be made through the transparent funding instrument such as the National Partnership.”

CareWest supports the retention of Universal Access, and agrees that the creation of additional preschools within schools is desirable. However, if all preschools merge with schools what will become of the community based sector? Can the schools accommodate such large numbers of children?