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2 Submission Paper Contents Introduction... 4 Organisation Overview... 4 Churches of Christ in Queensland... 4 Churches of Christ Care... 4 Our mission... 4 Our values... 5 Overview of Child, Youth and Family Care... 5 National Quality Framework Review... 6 Regulation Impact Statement... 6 Options for Consideration... 7 Proposal 1.1 Reducing the complexity of the National Quality Standard... 7 Proposal 1.2 Streamlining the process for quality assessments... 9 Proposal 1.3 Reduction in documentation of child assessments or evaluations in OSHC services10 Proposal 1.4 Significant Improvement Required rating Proposal 1.5 Exceeding the National Quality Standard rating Proposal 1.6 Excellent rating Proposal 1.7 Ensuring ratings accurately reflect service quality Proposal 1.8 Length of time between assessments Proposal 2.1 Removing supervisor certificates Proposal 3.1 Additional services to be included in the NQF Proposal 3.2 Application of assessment and rating processes to additional services Proposal 4.1 Extending some liability to educators Proposal 5.1 Introduce fee for extension of temporary waiver Proposal 5.2 Increase in provider approval fee Proposal 5.3 Increase in service approval fee Proposal 5.4 Increase in annual fee for approved services Proposal 6.1 National educator to child ratio for OSHC services Proposal 7.1 Approval of FDC services across jurisdictions Proposal 7.2 Limiting the number of FDC educators in a service Proposal 7.3 Mandating a ratio of FDC co-ordinators to educators Proposal 7.4 Mandating a minimum Certificate III for FDC educators Proposal 7.5 FDC educator assistants activities Proposal 7.6 Principal office notifications Proposal 7.7 Powers of entry to FDC residences Other changes which will have a regulatory impact Page 2 of 28 Churches of Christ in Queensland 2014

3 Submission Paper Approvals assessment of capability (Proposal 8.1.1) Approvals assessment of capability (Proposal 8.1.2) Approvals assessment of capability (Proposal 8.1.3) Approvals maximum children numbers as service approval condition (Proposal 8.1.4) Revocation of waivers (Proposal 8.2.1) Selecting a nominated supervisor/pidtdc (Proposal 8.3.1) Adopt proposed change Powers of the regulatory authority (Proposal 8.3.2) Job sharing (Proposal 8.3.3) Consenting to the role (Proposal 8.3.4) Notifications (Proposal 8.3.5) Record keeping (Proposal 8.3.6) Terminology (Proposal 8.3.7) Child protection and nominated supervisors (Proposal 8.3.8) Weeks ECT Leave Provision - Extending the scope to include resignation (Proposal 8.4.1) Educator breaks (Proposal 8.4.2) First Aid Qualifications (Proposal 8.4.3) Undertakings expansion of scope (Proposal 8.5.1) Undertakings time within which proceedings for alleged offence must be commenced (Proposal 8.5.2) Drafting issues definition of unauthorised person (Proposal 8.5.3) Extension of liability definition of person with management and control (Proposal 8.5.4) Compliance and Enforcement Information (Proposal 8.6.1) Sharing of Information within and between other state or territory government agencies (Proposal 8.6.2) Publication of information (Proposal 8.6.3) Notifying the regulatory authority of a complaint (Proposal 8.7.1) Regulations Medical conditions policy (Proposal 8.7.2) Regulations Evidence of insurance (Proposal 8.7.3) Qualification requirements for supervisors of volunteers (Victoria specific requirement) (Proposal 8.8.1) Page 3 of 28 Churches of Christ in Queensland 2014

4 Submission Paper Introduction The purpose of this submission paper is to formally provide feedback in relation to the National Quality Framework Review Consultation Regulation Impact Statement (RIS) being conducted by Deloitte. More information on the review being conducted by Deloitte can be found: This submission paper outlines: An overview of Churches of Christ Care. Overview of submission already submitted regarding the National Quality Framework Review Information about the Regulation Impact Statement Preferences for the options to be considered This is a public submission, it does not contain in confidence material and can be placed on the Deloitte Access Economics website. Organisation Overview Churches of Christ in Queensland With over 45,000 Queenslanders involved regularly in one of its churches or missional or care services, Churches of Christ in Queensland is proud to be an integral part of the Queensland community. Churches of Christ in Queensland is one of the leading and most innovative developers of integrated communities in the state, seamlessly bringing together services to support the continuum of life on one campus. The organisation offers a philosophy of holistic client-focused care and service, and a location where the broader community can benefit from additional services provided. Churches of Christ in Queensland operates a range of missional and community care services to assist families, the elderly and people in need through church communities and its care services division, Churches of Christ Care. Churches of Christ Care Established in 1930, Churches of Christ Care is one of the largest, most diverse not-for-profit organisations in Australia, operating more than 150 care services throughout Queensland and Melbourne, Victoria, with the support of over 3,000 staff and 900 volunteers. A division of Churches of Christ in Queensland and working with Churches of Christ in Vic/Tas, Churches of Christ Care is active in the areas of early childhood services, child protection, community housing, retirement living, community care, residential aged care and dementia care, providing Christinspired care and compassion to vulnerable persons at different stages of their life journey. Churches of Christ Care is built on a foundation of Christian values, commitment to quality care, trust, and respect for clients and the community. Services are offered to all those in need regardless of religious background. Services are funded by a mix of government subsidies, grants, fundraising activities, and fees and charges for services such as early childhood, retirement living and residential aged care. Community housing projects have been made possible through funding from the federal government s Nation Building Economic Stimulus Plan. For more information on Churches of Christ in Queensland go to Our mission Bringing the light of Christ into communities. Page 4 of 28 Churches of Christ in Queensland 2014

5 Submission Paper Our values As our name implies Churches of Christ is founded on the teachings and values of Jesus Christ who calls on every one of us to individually be a light in the place we are in, and collectively to be the light of the world through the expression of love. He calls upon us to be united in this effort and to work together as one body, and this is not just something we do, but rather a way of life. Flowing from this understanding of who we are and what we stand for as an organisation, is a commitment to these three core values: Modelling unconditional love. Behaving with integrity. Being good stewards. Overview of Child, Youth and Family Care Churches of Christ Care Child, Youth and Family Care offers a broad range of early childhood and child protection services. Support provided is based on the identified needs and interests of individual communities. Early Childhood Services: Churches of Christ Care is one of the leading not-for-profit providers of high quality, approved child care services in Queensland, operating 22 services for children aged 0-16 years. The organisation s early childhood services were developed with a focus on community needs, and include centre-based care, home-based care and community-based care, all with flexible support options. Home-based care options include family day care and in-home care. Centre-based care options include approved kindergartens operating in co-located early childhood centres, within school grounds and at stand alone sites; long day care; occasional care; and outside of school hours and vacation care. Other community-based services offered to families include a family support service in Maryborough and a rural mobile children s service based at St George. Churches of Christ Care s early childhood services are both in-scope and out-of-scope under the National Quality Framework. Churches of Christ Care is committed to recruiting and maintaining suitably qualified early childhood educators at all services. Staff are supported in their professional development, through attendance at internal and external conferences and workshops, and through their involvement in both peer networks and learning communities across the state. A staff exchange program allows educators to experience a variety of cultures in different service types and locations. Educators also extend their professional growth through mentoring and coaching. While Christian values of kindness and acceptance are reflected in the supportive, loving environment created for the children, all Churches of Christ Care early childhood services are non-denominational and celebrate cultural diversity. Child Protection Services: Established in 1970, Churches of Christ Care is one of the largest non-government providers of child protection services in Queensland, providing foster/kinship care, respite care, and residential and supported independent care to approximately 2,800 children and young people each year who are under the care of the Queensland Department of Communities, Child Safety and Disability Services or at risk of being taken into care. A further 750 children and families are supported through its assessment and intervention services. The organisation is supported by over 920 dedicated and compassionate foster and kinship carers who work closely with staff to provide a vital safety net to children and young people who have often Page 5 of 28 Churches of Christ in Queensland 2014

6 Submission Paper come from backgrounds of abuse and neglect. Service locations include Mt Isa, Townsville, Bowen, Mackay, Bundaberg, Maryborough, Fraser Coast, Caboolture, Brisbane, Ipswich, Logan and the Gold Coast. National Quality Framework Review The organisation provided a submission paper titled National Quality Framework Review Submission Paper dated 03/07/2014. The purpose of this submission paper was to formally provide feedback in relation to the National Quality Framework Review being conducted by Woolcott Research and Engagement. More information on the review being conducted by Woolcott Research and Engagement can be found: This submission paper outlined: Strengths of the National Quality Framework. Challenges of Implementing the National Quality Framework. Qualifications and knowledge. Managing expectations. Language. Quality Improvement Plan. Regulatory Authority. Key improvement areas. Inconsistency of National Quality Framework. Inconsistency of the Assessment and Ratings Process. Compliance aspects of the Assessment and Ratings Report. Streamlining the use of the Quality Improvement Plan. Streamlining and reviewing the National Quality Standards and Elements. Improving consistency and streamlining the Regulations. Streamlining required roles and responsibilities. Streamlining the qualification requirements. Streamlining the visit requirements. Streamlining the kindergarten services. Improving the quality of care by including all out-of-scope services. Improving consistency and support to Assessors and Services. Improving the communication for parents/families and communities. Linking the National Quality Framework to other Australian models. Use of Regulatory Burden in a quality improvement model. Regulation Impact Statement This submission paper focuses on the options for considerations and consultation questions in the Education Council, Regulation Impact Statement for proposed options for changes to the National Quality Framework, COAG Consultation Regulatory Impact Statement, November 2014, %20Consultation%20RIS%20for%20NQF.pdf document. This document will be referenced in this submission paper as RIS. Page 6 of 28 Churches of Christ in Queensland 2014

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8 Submission Paper will help in identifying what is required currently and in the understanding on where proposed element 4.B.i. came from. Proposed standard 6.A Respectful relationships with families are developed and maintained and families are supported in their parenting role the section and families are supported in their parenting role reads as though someone thought it was important and just added it to the end of this standard. It is recommended that the proposed standard be Respectful and supportive relationships with families are developed and maintained. The and families are supported in their parenting role is not required as it is reflected in the proposed element 6.A.ii. Proposed standard 6.B Collaborative partnerships enhance children s inclusion, learning and well-being this standard is written in a different manner to the other standards. It would be suggested to change the wording to Collaborative partnerships are developed to enhance children s inclusion, learning and well-being. Current element Links with relevant community and support agencies are established and maintained is currently linked to 6.A.iii. The meaning of this element changes with that proposed element link. Is it expected that the intent of the current element would be included in the proposed standard 6.B? It would be recommended that the purpose of this element not be eliminated or used incorrectly. Table B1 section for QA7 is titled Leadership and Governance rather than Leadership and Service Management this implies that the purpose of the quality area is going to change. Proposed standard 7.A Appropriate governance and risk management support quality outcomes for each child this proposed standard limits the scope of the standard to only ensure governance and risk management for each child rather than the holistic approach of the service, which includes educators, staff, management, families, parents/guardians, community. This quality area should be about the management of the service and therefore should not have a direct focus on outcomes for children. Also by including risk management it assumes that other management aspects of governance are not relevant. It is recommended that the proposed standard be re-written. Appropriate governance systems are developed to support quality outcomes for the service. Proposed element 7.A.ii Decision making and systems enable the effective management and operation of a quality service. this reads as two ideas have been put together and that as an element is very broad in its interpretation on what it means. It is recommended that this proposed element be broken into two elements and made clearer in its meaning. Current standard 7.3 and elements 7.3.1, 7.3.2, 7.3.3, 7.3.4, are not addressed in proposed element 7.A.ii. These clearly state the intention of the standard and elements but this is not reflected in proposed element 7.A.ii. It is recommended that the proposed elements in QA7 be reviewed. Page 8 of 28 Churches of Christ in Queensland 2014

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22 Submission Paper Approvals maximum children numbers as service approval condition (Proposal 8.1.4) 8.1.4A No change 8.1.4B Adopt proposed change Preferred option is: 8.1.4B Adopt proposed change. This preferred option is with the understanding that it is for centre-based services and not family day care services. Revocation of waivers (Proposal 8.2.1) 8.2.1A No change 8.2.1B Adopt proposed change Preferred option is: 8.2.1B Adopt proposed change. This preferred option is with the understanding that if the reason why 60 days was chosen when first drafting the Regulations is no longer applicable and that 14 days is now deemed as reasonable. Selecting a nominated supervisor/pidtdc (Proposal 8.3.1) 8.3.1A No change 8.3.1B Adopt proposed change Preferred option is: 8.3.1B Adopt proposed change. This preferred option is with the understanding that these changes will not increase regulatory burden on the service or approved provider. Please refer to Proposal for thoughts regarding the use of the term PIDTDC. Adopt proposed change Powers of the regulatory authority (Proposal 8.3.2) 8.3.2A No change 8.3.2B Adopt proposed change Preferred option is: 8.2.1B Adopt proposed change. This preferred option is with the understanding that the reasons why a person may be restricted from being nominated supervisor/pidtdc is provided to the approved provider within a reasonable timeframe. Please refer to Proposal for thoughts regarding the use of the term PIDTDC. Job sharing (Proposal 8.3.3) 8.3.3A No change 8.3.3B Adopt proposed change Page 22 of 28 Churches of Christ in Queensland 2014

23 Submission Paper Preferred option is: 8.3.3A No change. If there was more than one nominated supervisor what is the purpose of the responsible person or PIDTDC. Please refer to Proposal for thoughts regarding the use of the term PIDTDC. If this change does occur will there be guidance on how the job sharing will work in regards to if the nominated supervisor on duty is entirely responsible for the service and any compliance issues that may occur during that time or that all nominated supervisors are responsible all the time? The structure of who is responsible for the service may be confusing to management, educators, staff, families and the community. Consenting to the role (Proposal 8.3.4) 8.3.4A No change 8.3.4B Adopt proposed change Preferred option is: 8.3.4A No change. The requirement of written consent for the nominated supervisor role, no matter the person s current role, allows for the person to formally consent to the role that will be additional to their current role. Notifications (Proposal 8.3.5) 8.3.5A No change 8.3.5B Adopt proposed change Preferred option is: 8.3.5B Adopt proposed change. This preferred option is with the understanding that the Law will be amended as described in (a) and (b). Record keeping (Proposal 8.3.6) 8.3.6A No change 8.3.6B Adopt proposed change Preferred option is: 8.3.6B Adopt proposed change. This preferred option is with the understanding that the Law will be amended as described in (a) and (b). Terminology (Proposal 8.3.7) 8.3.7A No change 8.3.7B Adopt proposed change Preferred option is: 8.3.7B Adopt proposed change. This preferred option is with the understanding that the references to supervisor certificates and verified supervisors will be removed. Page 23 of 28 Churches of Christ in Queensland 2014

24 Submission Paper Can it please be clarified on the purpose of the Service Supervisor Certificate? A service which has been approved and provided with a Service Approval Certificate, is an additional certificate required? The terminology of required positions needs to be more clearly defined. For example what would be the difference between a person that is covered by the Service Supervisor Certificate, a responsible person and the new term that is being used, PIDTDC? In regards to the use of persons in day to day charge and the acronym PIDTDC, it is recommended that responsible person be used to limit the confusion of additional terminology. In the Law the term responsible person is used: 117 Effect of supervisor certificate - be the responsible person present at the education and care service premises in the absence of the approved provider or the nominated supervisor. 162 Offence to operate education and care service unless responsible person is present In the Regulation s the term responsible person is used: Definitions - responsible person, in relation to an education and care service, means a person referred to in section 162(1)(a) to (c) of the Law; 168 Education and care service must have policies and procedures - determining the responsible person present at the service 173 Prescribed information to be displayed - responsible person in charge of the education and care service at any given time; Child protection and nominated supervisors (Proposal 8.3.8) 8.3.8A No change 8.3.8B Adopt proposed change Preferred option is: 8.3.8B Adopt proposed change if for all educators, nominated supervisors, approved providers. Limiting this to only the nominated supervisors or persons in day to day charge is limited, and will need to be extended to all educators. Guidance on if this training is to be provided by the approved provider or by a training organisation (for example provided similarly to the First Aid qualification) must be made clear. How will this change affect Regulation 84 Awareness of child protection law? 12 Weeks ECT Leave Provision - Extending the scope to include resignation (Proposal 8.4.1) 8.4.1A No change 8.4.1B Adopt proposed change Preferred option is: 8.4.1B Adopt proposed change. This preferred option is with the understanding that the Regulation will be amended as described in (a) and (b). Page 24 of 28 Churches of Christ in Queensland 2014

25 Submission Paper Educator breaks (Proposal 8.4.2) 8.4.2A No change 8.4.2B Adopt proposed change Preferred option is: 8.4.2A No change It is acknowledge that this is only for centre-based care. If this was to change would educator/child ratios be under roof or per room? First Aid Qualifications (Proposal 8.4.3) 8.4.3A No change 8.4.3B Adopt proposed change Preferred option is: 8.4.3A No change It is recommended that all educators, no matter what service type have a first aid qualification. Undertakings expansion of scope (Proposal 8.5.1) 8.5.1A No change 8.5.1B Adopt proposed change Preferred option is: 8.5.1A No change. It is unclear what the proposal is trying to achieve. Undertakings time within which proceedings for alleged offence must be commenced (Proposal 8.5.2) 8.5.2A No change 8.5.2B Adopt proposed change Preferred option is: 8.5.1A No change. It is unclear what the proposal is trying to achieve. Drafting issues definition of unauthorised person (Proposal 8.5.3) 8.5.3A No change 8.5.3B Adopt proposed change Preferred option is: 8.5.1A No change. It is unclear what the proposal is trying to achieve. Page 25 of 28 Churches of Christ in Queensland 2014

26 Submission Paper Extension of liability definition of person with management and control (Proposal 8.5.4) 8.5.4A No change 8.5.4B Adopt proposed change Preferred option is: 8.5.4B Adopt proposed change. This preferred option is with the understanding that the Law and Regulation will be amended as described. Compliance and Enforcement Information (Proposal 8.6.1) 8.6.1A No change 8.6.1B Adopt proposed change Preferred option is: 8.6.1B Adopt proposed change. Sharing of Information within and between other state or territory government agencies (Proposal 8.6.2) 8.6.2A No change 8.6.2B Adopt proposed change Preferred option is: 8.6.2B Adopt proposed change. Publication of information (Proposal 8.6.3) 8.6.3A No change 8.6.3B Adopt proposed change Preferred option is: 8.6.3A No change. Notifying the regulatory authority of a complaint (Proposal 8.7.1) 8.7.1A No change 8.7.1B Adopt proposed change Preferred option is: A No change Why is this change required? Is the term serious incident still to be used? Is this going to be replaced by serious risk? How is this change different to what is currently written in the Law, Section 174? Page 26 of 28 Churches of Christ in Queensland 2014

27 Submission Paper Regulations Medical conditions policy (Proposal 8.7.2) 8.7.2A No change 8.7.2B Adopt proposed change Preferred option is: 8.7.2B Adopt proposed change This preferred option is with the understanding that Regulation 90 will be more descriptive and clear in its requirements. In regards to a medical management plan before education and care is provided what happens when an unknown condition is discovered after the commencement of education and care, is care to cease until a medical management plan is provided? Regulations Evidence of insurance (Proposal 8.7.3) 8.7.3A No change 8.7.3B Adopt proposed change Preferred option is: 8.7.3B Adopt proposed change Qualification requirements for supervisors of volunteers (Victoria specific requirement) (Proposal 8.8.1) 8.8.1A No change 8.8.1B Adopt proposed change No comment as organisation does not have services in Victoria. Page 27 of 28 Churches of Christ in Queensland 2014

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