Submission. The 2014 NQF Review COAG Consultation RIS. National In-Home Childcare Association (NICA)

Transcription

1 Submission The 2014 NQF Review COAG Consultation RIS National In-Home Childcare Association (NICA) 16 January

2 CONTACTS Submission from: National In-Home Childcare Association (NICA) Contact: Position: Postal Address: Office: Mobile: Fax: ( Web: 2

3 APPENDIX 1 ABBREVIATIONS ANA Australian Nanny Association CCB Childcare Benefit CCR Childcare Rebate COAG Council of Australian Governments CCMS Child Care Management System CPR Cardiac Pulmonary Resuscitation DEEWR Department of Education and Workplace Relations DHS Department of Human Resources ECEC Early Childhood Education and Care ECLS Early Care and Learning Subsidy FDC Family Day Care IHC In-Home Childcare LDC Long Day Care NCPA National Child Protection NICA National In-Home Childcare Association NQF National Quality Framework NQS National Quality Standard OOHC Out of Home Care SCCB Special Childcare Benefit SELCS Special Early Care and Learning Subsidy Appendix 2 - In-Home Care Operating Standards 2008 Appendix 3 - Home Childcare Educator Share Pilot Plan 3

4 Contents THE 2014 NQF REVIEW COAG CONSULTATION RIS... 1 CONTACTS... 2 APPENDIX 1 ABBREVIATIONS... 3 LETTER TOTHE COMMISSIONERS... 5 INTRODUCTION THE NATIONAL IN-HOME CARE ASSOCIATION (NICA) IN-HOME CHILDCARE (IHC) PROGRAMME EXECUTIVE SUMMARY BACKGROUND TO THE 2008 NATIONAL STANDARDS FOR IHC THE WAY FORWARD NICA RECOMMENDATIONS CAPACITY - ADDITIONAL PLACES HOME EDUCATOR SHARE PLAN HOME EDUCATOR SHARE PLAN COSTING S DEEMED COST OF HOME CHILDCARE CONCLUSION

5 The Commissioners National Quality Framework Review Deloitte Access Economics GPO Box 78 MELBOURNE VIC 3001 Dear Commissioners The National In-Home Childcare Association (NICA) is the representative organisation (PEAK body) for the In-Home Childcare sector. In-Home Childcare (IHC) is an Early Childhood Education and Care model where the Educator comes to the home of the Child, and while it is currently the smallest part it is also a vital part of the Government approved formal Child Care network. IHC is a model of care that has been proven, tested and successfully tried in Australia for more than 14 years. IHC is also the most flexible, adaptable, and perhaps inexpensive model of care and has the capacity for Governments to fill the gaps in the shortfall of Childcare from both an availability and flexibility point of view. IHC Educators are not Nannies, nor are we babysitters, but rather we are a consortium of professional Early Childhood Educators who have been selected and vetted by Approved In- Home Care Service Providers based in a central coordination unit or Hub and Spoke model that is staffed by Early Childhood professionals. These Service Provider diligently support and care for the needs of both Educators and the Children and Families who are cared for and educated by the Service. NICA as the peak body for IHC provides information, membership support, resources, advocacy, representation, and research and policy development for its members and the IHC sector in Australia. The members of this organisation are comprised of the stakeholders from the In-Home Childcare community. NICA also sets the industry benchmarks and maintains a voluntary code of ethics designed for the In-Home Childcare (IHC) sector that ensures the safety and welfare of the families and children we care for. Many are already working under the National Quality Framework. IHC was the first Child Care Service type to have a uniform nationally recognised set of standards operated by the Department of Education and Employment Funding Agreements in These Standards have proven themselves to be an effective starting point in ensuring the provision of child care that is safe, nurturing and educational environment for a child using IHC. IHC is currently classified as an out of scope service and was expected to remain so until the review of the National Quality Framework (NQF) in Over the last few years NICA has been actively lobbying governments for an earlier inclusion for IHC in the NQF. However, there is a recognition this may take some time and as a consequence NICA are suggesting a 4 year ( ) transitional arrangement to the NQF in this submission. 5

6 IHC has delivered Australian families with 14 years of stable care with an unblemished history and has cared for more than 50,000 children and their families since it was established in We thank the Commissioners for the opportunity of commenting on the Regulation Impact Statement for proposed changes to the National Quality Framework, and we would welcome the opportunity of speaking directly to the Commissioners or providing further information if required. Yours sincerely 6

7 INTRODUCTION 1.0. THE NATIONAL IN-HOME CARE ASSOCIATION (NICA) The National In-Home Care Association (NICA) was established in 2004 and is the national peak body for the Commonwealth funded In -Home Care program. NICA represents the in-home childcare community, carers, approved agencies, their staff and families aiming to ensure the success and continual growth of in-home childcare. As the peak body for IHC, NICA is the representative organisation that provides information, membership support, resources, advocacy, representation, and research and policy development for its members and the IHC industry in Australia. The members of this organisation comprise of the stakeholders from the In-Home Childcare community. NICA sets the industry benchmarks and maintains a voluntary code of ethics designed for the In-Home Care (IHC) industry that ensures the safety and welfare of the families and children we care for. In June 2005, RPR Consulting carried out a research project - Department of Family and Community Service Final Evaluation Report: In Home Care, which made clear recommendations that In-Home Care develop National Regulatory Standards to ensure that services meet basic health and safety standards and are consistent across the States and Territories. In response to these recommendations, funding was allocated to NICA for the development of a set of Standards and NICA convened a steering committee which culminated in the roll out and implementation of the In-Home Care Standards in February IHC was the first Child Care Service type to have a uniform nationally recognised set of Standards operated by the Department of Education, Employment and Workplace Relations (DEEWR) Funding Agreements in These IHC Standards have proven themselves to be an effective tool in ensuring the provision of child care that is safe, nurturing and educational for a child using IHC. NICA has also been at the forefront of working to progress and raise the profile and value of the Government funded IHC programme and highlight many of the key issues for the Home Childcare sector. NICA have promoted new ideas for opening up the sector to the many families who have been loudly voicing their concerns relating to the flexibility and affordability of care for their children. NICA have communicated with the Government, the Department and the ECEC sector, and have proactively provided submissions to Government and the PC in response to calls by families, the business community and the unions for increased flexibility and to uncap and extend the government funded IHC programme. NICA have put forward innovative pilot plans for extending IHC to Emergency Service workers, and most recently have suggested a Home Childcare Share Educator plan, that will allow families to share an educator in their home and share the cost. NICA believes that Home Childcare produces a quality learning experiences and education from 0 to 5 years in family-focused home environments for parents who choose this form of care for their children. 7

8 2.0. IN-HOME CHILDCARE (IHC) PROGRAMME In-Home Care (IHC) is a capped, small, vital and integral part of child care services for families and a highly successful part of the early childhood mix and is presently only half of one percent of the Early Childhood budget of more than $31.5 billion over four years with the majority of the funding $28.5 billion to helping families with the cost. There are currently only around 5011 places within the IHC program across the country, and there has been no allocation of new places in recent years apart from a reallocation of 790 unused places in IHC is classified as an out of scope service and was expected to remain so until the review of the National Quality Framework (NQF) in However, NICA has been actively lobbying government for the early inclusion of IHC in the NQF. IHC operates under National IHC Standards under which the IHC Provider arranges the placement of educators with families and monitors the care provided. The service provider organises the assessment, selection and registration of the educators; and provides inservice training and professional development. IHC is recognition that some families do not have access to other child care options for a range of reasons, including non-standard working hours, which affects workers in a range of industries like emergency services, health, tourism, performing arts, retail and manufacturing. Many families live in remote locations with dispersed populations where there are no other forms of child care. IHC started as a small additional funding program attached to family day care, designed to provide child care for families in particular circumstances. The first approval to provide IHC was given in 1993, and growth was limited, with only 25 approvals made by In 2000, the then Minister Senator the Hon. Jocelyn Newman put in place a collaborative research project investigating the child care needs of families with a child with a chronic illness or disability, and parents who work shifts or non-standard hours and this led to the funding of three pilot in-home care services. The research project was undertaken by the NSW Family Day Care and the Australian Federation of Child Care Centres in collaboration with the Department of Family and Community Services. These pilots projects were located in New South Wales, Tasmania and Queensland, and were seen to be successful in meeting the objectives of providing flexible monitored child care to eligible families. As a result IHC as a targeted form of child care was funded by the Australian Government in 2001 under the Stronger Families and Communities Program. Presently, IHC is only real flexible option for families who cannot access existing child care services such as those working shift or non-standard hours, have an illness or a disability or those located in rural or remote communities who do not have a service available. The current demand and growth of demand for IHC places is constant and is placing pressure on families who are forced to wait for support as their broader coping and provisioning resources are eroded. This is a wide recognition that IHC is a vital part of the ECEC policy mix in the wide suite of integrated child care arrangements that has the capacity to provide the flexibility of care that families are calling for. There is a high need for IHC places to be uncapped and extended. 8

9 Currently IHC places are targeted to families who: have no access to existing child care services; or their circumstances mean that an existing child care service cannot meet their needs And at least one of the following criteria also applies: the child has, or lives with another child who has, an illness or a disability; the child's guardian (or guardian's partner) has an illness or disability that affects their ability to care for the child; the child lives in a rural or remote area; the work hours of the child's guardian (or guardian's partner) are hours when no other approved child care service is available; or the child's guardian (or guardian's partner) is caring for three or more children who ve not yet started school EXECUTIVE SUMMARY Over the next few months, the Government will be making some major decisions relating to the Early Education and Care of our children. Presently, we have a three pillar system made up of the Long Day Care (LDC), Family Day Care (FDC), and In-Home Childcare (IHC). The test for the policy makers is to ensure these three pillars actually work together for the benefit of our children and their families. As the Government considers its family policy in early 2015, there are early indications from both from the Government and the Productivity Commission of likely major move towards an extended Home Childcare sector that will see the official Government funded IHC programme be extended and for the inclusion of approved nannies to be regulated under the NQF. NICA was also pleased to note recent comments by the Prime Minister of his intention to rework aspects of the Paid Parental Leave scheme, and also note that the Commission of Audit recommended a cap to the Parental Leave scheme and to redirect the savings to expand child care services, including to the government funded IHC programme. During the December quarter 2013, more than 1.1 million children were in approved child care formal care in Australia, being cared for by early childhood educators. Another 1.4 million were in what is called informal care, which involves siblings, grandparents, neighbour, nannies and friends i. The care of our children is an issue that reaches out and touches many, and in turn affects our productivity as it places limitations on families, usually mothers to fully commit to full time employment opportunities. An expanded and uncapped IHC programme with approved nannies is the answer to the question being asked by so many families especially for those who are shift workers. The present policy mix doesn t go far enough to fully support the aspirations of working women who just need the flexibility to return to work in the confidence of knowing young children are being well cared for whether it be in the family home under Home Childcare, or in an Early Child Learning Centre 9

10 In response to the NQF Review Consultation COAG - RIS, NICA is taking the opportunity to re-enforce, confirm and re-commit to the submissions made to the Productivity Commission in 2014 to extend and uncap the official Government IHC programme that will include approved nannies while keeping in place the SCCB (or form of) for the care of vulnerable families and at risk children who quality under this funding programme. In addition, NICA recommends that an extended IHC programme should initially be regulated under the IHC National Standards that will transition to the NQF over a four year period between 2015 and The reality is, as recognised by NICA and outlined in the NQF-RIS that the inclusion of any additional service under the NQF may take a number of years to achieve, and as such NICA will outline interim measures for the transition where an uncapped and extended IHC programme with approved nannies can be regulated and recognised under the National Standards for IHC while transitioning to the NQF in a staged rollout over a four year period. Presently, In Home Care providers are required to adhere to these standards and have a number of obligations under family assistance law they are required to meet. In addition, the department assists providers in compliance with their obligations under section 24 of Child Care Benefit (Eligibility of Child Care Service for Approval and Continued Approval) Determination 2000 (also known as the Eligibility Determination). NICA are proposing that the Government: 3.1. Provide freedom of choice and open access to the government approved IHC programme so as to allow families to choose the best care option to meet their needs and working commitments; 3.2. Uncap and extend the IHC programme over a 4 year period expanding it by 10,000 places per year to around a total of 40,000 places over the 4 year transition period; 3.3. Parents using Home Childcare would qualify for either/and the CCR and the CCB or the Early Childhood Education and Care Subsidy (ECLS) as proposed in the PC draft report ii as a replacement to the CCR/CCB payments; 3.4. Adopt a compliance model of IHC National Standards, and State Regulation with Home Educators having to enroll or hold a minimum Certificate III qualification; 3.5. Put in place additional compliance measures that during the transition period will assess and rate the IHC National Standards in terms of the children s education and care services; 3.6. The expanded places will be allocated to registered IHC providers and approved Nanny Agencies who have an established history of quality service delivery and compliance; 3.7. Approved service providers would need to commit to the extended IHC programme, regulated under the existing IHC National Standards, but moving towards the NQF over the four year transition period; 3.8. The monitoring of the integrity of service provision, risk and compliance can be achieved through either no or limited additional cost to the Government; Providers should allow for these vital reporting standards in their cost structure by adopting a hub and spoke model of approved co-ordination ensuring educators are employed under correct awards and entitlements as specified by Fair Work Australia; 3.9. Put in place an additional measure of compliance that would enable families to have the capacity to update on line that care etc. took place through the existing Child Care Management System (CCMS) or a paper reporting process for those who without access to a computer; Establish a Home Educator Share Plan that will allow families to share the cost of a qualified Home Educator at a lower cost rate to each family, working under one umbrella agreement with families, the service provider, and home educator 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 and by type of care iii ; 10

11 3.12. Adopt the draft PC recommendations that the Commonwealth, the State and Territories through the COAG process to set-up a national system of vetting and registration of all ECEC educators in association with established IHC providers across the sector iv BACKGROUND TO THE 2008 NATIONAL STANDARDS FOR IHC IHC was the first childcare sector to operate under nationally recognised standards when in February 2008, DEEWR released the National Standards for the IHC sector - The Interim Standards for In- Home Care, Funding Agreement Requirement. These National IHC Standards put in place safeguards and quality outcomes for our Service Providers. In the ensuing 6 years, these In-Home Care Standards have proven themselves to be very effective in ensuring the provision of child care that is safe, nurturing and of educational value for a child using IHC. This is confirmed by the NICA, who in their role as the National Peak Body for In Home Care providers, are the most effective barometer in the gauging of feedback from the various services Australia wide. NICA sets the industry benchmarks and maintains a voluntary code of ethics designed to ensure that the In-Home Care industry is self-regulating and ensures the safety and welfare of the families and children we care for. The Practice Guidelines manual sets the benchmarks for our service providers with the key priorities being with the families and children; we care for, our clients. As prescribed by the IHC National Standards there 13 comprehensive guiding standards and sub-standards that prescribe the minimum requirements necessary to ensure the provision of IHC that is safe, nurturing and educational for a child using IHC. All these standards prescribe the minimum requirements necessary to ensure the provision of child care that is safe, nurturing for children using IHC. However, while IHC remains out of scope it has continued to be an evolving programme since its inception in 2000 and has the capacity for further development to provide the flexibility of care that Australian Families are calling for and recommended by the Productivity in their draft report released in July THE WAY FORWARD IHC and Family Day Care (FDC) are at the leading edge of a solution for parents who require greater flexibility in the care arrangement for their children because of their working hours and for those who live in city areas where childcare places are presently at a premium and providers have long waiting lists. Australian families need the freedom of choice and open access to the government approved IHC programme so as to enable them to choose the best care option to meet their individual needs. This has been the guiding tenet in the NICA submissions to the Productivity Commission Inquiry into Childcare and Early Childhood Learning. 11

12 NICA RECOMMENDATIONS 5.1. The IHC programme be uncapped and extended to all families, who would then qualify for a CCR and or CCB payment or the PC draft recommendation of combined ECLS payment; 5.2. IHC be brought under the umbrella of the NQF framework over a four year period and regulate approved Nannies under the IHC National Standards in a staged introduction over a four year period as bridge moving across to the NQF; 5.3. NICA will work with the Government to put in place put in place additional compliance measures, in advance of the transition period that will assess and rate the IHC National Standards in terms of the children s education and care services; 5.4. Work with the federal Department of Education to ensure that Home Educators meet the National Quality Standards (NQS) by 2019; 5.5. Uncap and extend the IHC programme over a 4 year period and expand by 10,000 places per year to around a total of 40,000 places using IHC National Standards and State Regulation with transition to the NQF over four years between 2015 and 2019, this will relieve the considerable delays in the compliance to the NQF that is placing severe pressure on State Governments in terms of compliance; 5.6. Expanded places to be allocated to registered IHC providers and approved Nanny Agencies who have an established history of quality service delivery and compliance and However, as there is currently considerable delays in the compliance to the NQF that is placing a severe pressure on State Governments in terms compliance Monitoring of the integrity of service provision, risk and compliance can be achieved through either no or limited additional cost to the Government. Service providers should allow for these vital reporting standards in their cost structure by adopting a hub and spoke model of approved co-ordination ensuring educators are employed under correct awards and entitlements as specified by Fair Work Australia, agreed services are provided; 5.8. Families have the capacity to update on line that care etc. took place through the existing Child Care Management System (CCMS) or a paper reporting process for those who haven t got access to a computer; 5.9. As an additional compliance measure all approved educators will be required to provide their tax file number that could be registered and maintained by the Department using the CCMS system Under Home Childcare programme the Home Educators and approved nannies will all be qualified at a minimum Certificate III level and be registered, giving parents a sense of security that the people looking after their children have satisfied strict regulatory and education requirements; 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 and by type of care; Adopt the draft PC recommendations for the Commonwealth, the State and Territories through the COAG process to set-up a national system of vetting and registration for all ECEC educators in association with established IHC across the sector v ; 12

13 5.13. Put in place a steering committee made up of ACECQA, Department of Education, NICA, and ANA that will work together to put in place the regulations and requirements that will fast track the registration/regulation of approved nannies qualified nannies under IHC National Standards CAPACITY - ADDITIONAL PLACES NICA believes there is enough current capacity in the system to provide up to 40,000 In- Home Childcare places over the next four years. These places are achievable by rolling into the Government funded IHC programme educators working as nannies but are currently unregistered and FDC Educators who are prepared to work after hours overnight and weekends. There are currently around 30,000 nannies working in Australian homes 1,that are largely unregistered and un-vetted by the appropriate government agencies, and are working within the cash economy. These are places that need to be officially unlocked and professionally registered and supervised. Unfortunately, the shortage of flexible places currently in the system has forced many parents to seek unregistered and unlicensed child care either online or through classifieds in the media. These are largely nannies that don t have any qualifications as educators and without any vetting in terms of police checks and first aid qualifications. Under the NICA plan to extend Home Childcare, the educators will be qualified and registered, giving parents the peace of mind and a sense of security that the educators looking after their children have satisfied all these requirements and have the appropriate first aid and police checks, as well as being monitored and supported on an ongoing basis by a professionals via a coordination unit/agency HOME EDUCATOR SHARE PLAN NICA has submitted to the Government and copied to the Productivity Commission a plan for a Home Educator Share Care Plan that can be part of a real solution in a suite of early childhood options for families, and note that the PC in their draft report also indicates a Home Childcare system could enable parents to share an educator. The NICA plan can provide families with the flexibility and stability they are asking for but in a more convenient and less stressful environment for the family and the children. This is a plan that will appeal to parents as it will allow each parent to hire a qualified educator and share the cost with the other family, it will also offer contact with other local children who enjoy the same activities and similar needs. The following steps will need to be considered: 7.1. Department to invite Expressions of Interest to registered/licenced IHC Providers interested in participating in the pilot plan; 7.2. Successful IHC providers will put in place a strategy to promote the pilot plan i.e. online media/advertising etc; 1 Nicole Brady and Deborah Gough, Sydney Morning Herald 5 August

14 7.3. Pilot plan will be an extension of the current Government IHC plan and as such will operate under the current IHC National Standards, with the exception of the eligibility criteria that will allow the service to be more available to families; 7.4. Families and Educator to sign one umbrella agreement/contract; 7.5. IHC service providers will have an emergency contact person available after hours for use of parents and educators; 7.6. Families will be able to register interest on line by completing their family profile to be matched with another like-minded family and educator; 7.7. Neighbour families, work colleagues or close friends could apply together to participate in the share pilot; 7.8. Educator and the family will be overseen by a diploma qualified Programme Coordinator who will maintain regular contact with the families and educators, both through a schedule of regular visitation and via phone and communications; 7.9. Educator activities will be strictly limited to the care, play and education of the children, and will not be available for other household chores; The Programme Co-ordinator will arrange meetings with like-minded families looking to share an educator in the same local area to establish the compatibility of the families; All educators will be interviewed, and will undergo a full background check and an experienced and qualified programme co-ordinator will oversee the pilot plans; IHC providers will have the responsibility to organise a back-up educator where possible for the family in case of illness or family emergency; Programme Co-ordinators and educators providing care for families will ensure they agree on parenting philosophy i.e. approach to discipline, ages, dietary requirements, and planning for a well-rounded day of activities for the children; Care will primarily be provided in one home or be divided between two households depending on families schedule and suitability. The educator with put in place an exact schedule that will include some sit-down time with parents and educators to ensure for good communications; The pilot will be monitored for success or otherwise by Departmental officials. HOME EDUCATOR SHARE PLAN COSTING S Many families, especially mothers are finding the cost of getting back in the workforce, especially with more than one child is just not affordable. The average cost of long day-care in NSW is around $81.50 a day and can be as high as $ in Sydney s northern beaches and $ a day in Sydney s Eastern Suburbs. A basic calculation at the lower average for two children would be $163 a day, $815 a week. Sharing an IHC Educator can be a cost effective way to get flexible, consistent and high quality care in an in-home environment. We believe that such a Flexible IHC Share arrangement can be achieved at a more affordable cost to the family budget for families who are able to claim the CCR and for those eligible for both the CCR and CCB. This is a plan that can provide families with the flexibility and stability of care they crave for within percentage ranges of the cost of LDC, but in a more convenient and less stressful environment. Our calculations indicate that families on an income of $80,000 a year who are eligible to claim both the CCR and the CCB, may enter into a shared care arrangement with as little as a nine per cent cost at night or twelve per cent during the day to the family budget. These 14

15 calculations are only intended to be indicative and are based on the best information available at the time of making them, but are not intended to be used as a finite resource, rather an indicative measure to inform broad policy direction. The educators may be employed by the IHC providers as indicated in the tables below that allow for the cost of administration, superannuation, and payroll tax and workers compensation for the educators who are employees. However, estimations may vary slightly where educators are self-employed. It s interesting to note that families using IHC pay for only the care they receive as opposed to long day care that fees are based on a 12 hour day whether the family uses it or not DEEMED COST OF HOME CHILDCARE There is currently no subsidy for families who choose to have their children cared for in the family home, apart from those few families who able to qualify for a place under the strict criteria and very limited places available in the Government funded IHC programme. In discussing this issue in their draft report the PC states that in demand base systems, the subsidy for ECEC can be based on actual fees or on a deemed cost of care per child per hour, that could be established by a benchmark set at a median level. However, the Government needs to determine annually deemed cost of care (initially using a cost model, moving to a benchmark price within three years) this would allow for differences in the cost of supply by age and by type of care. The IHC sector is currently made up of for profit and not for profit service providers and it is difficult to determine and compare these two services especially between those running urban and rural and remotes services. For example many non-profit services have a contracted workforce where the educators pay for their own resources and supplies (self-employed model often adopted by FDC providers). By comparison those operating as for profit service have home educators who are employees as opposed to contractors. This greatly increases the cost to the provider with services such as extensive office support for both families and educators and a responsibility for superannuation, workers compensation, holiday and sick leave, taxation and of course the supply of teaching aids and resources and of course GST on the total amount. NICA are unable to do a cost benefit analysis, but believe that a contribution from the Government of between $8.00 and $14.00 per hour would assist families with the cost of a Home Educator, employees could network for these rates, so families would need to make a contribution to reach a market rate of an accepted hourly rate for a qualified home educator. While the quality of ECEC services was paramount in the introduction of the NQF, the byproduct of which has also led to a large increase in fees for parents due to the additional compliance and red tape burdens imposed on the service provider. This development has also made IHC competitive with LDC and a more affordable option for families under a proposed new Home Childcare sector. In addition, the total cost could halve for families who choose to share a Home Educator as per the NICA submission to the PC and as outlined in this submission. In discussing a deemed cost for Home Childcare it also interesting to note that the Australian Nanny Association (ANA) believe there is currently between 30,000 and 80,000 nannies, au pairs, and child minders working in the system. These workers are largely unregistered, unqualified, and have no police checks or first aid certificates and are working in the cash/black economy. It goes without saying there is a tax implication to the Australian 15

16 economy of around (average) $1.8 billion in tax revenue per year, and in addition these workers are missing out on superannuation benefits and this will ultimately cost the Commonwealth in social welfare payments in their senior years. NICA strongly believe that the children who are currently qualify for IHC funded by the SCCB should continue to receive a 100 per cent rebate, especially those who are deemed to be at risk and are not included in this submission. These children should be included in a separate category of care as proposed and outlined in the NICA submission to the PC CONCLUSION For some years many families and diverse organisations such as Industry Groups, Unions, and Peak Bodies have called for the IHC programme to be extended and approved nannies to be brought into the ECEC sector for Australian families who will be eligible to receive ECEC assistance. The PC in their draft Report into Child Care and Early Childhood Learning outlines a framework and opportunity for a once-in-a-generation reform and is advocating a new home childcare sector that will include IHC, FDC and approved nannies. NICA was concerned that while the NQF RIS recommended the inclusion of the out of scope services such as BBF, Occasional Care Services, ACT Playschools and Mobile Service for inclusion in the NQF, neglected to mention the important third pillar of the ECEC sector in Australia, IHC. NICA believes the Department of Education are correct when they say we need a new Early Childhood environment for Australian families who are trying to cope with a system that was designed for another age. We need to foster a new environment that offers families more flexible and better options to assist them balance their working and family lives while ensuring the very best of Early Education and Care for their children. In the words of the former Assistant Minister for Educator, the Hon. Sussan Ley MP, maintaining the status quo is simply not a viable option if we are to provide working parents with a child care system that is affordable and flexible enough to support today s 24/7 economy, not the rigid 9-to-5 working week of last century vi. The IHC National Standards have the capacity to provide the bridge to transition to NQF by 2019 as outlined in this submission, and we are happy to provide further information as required. The Government has signalled they will be delivering a new Families package in 2015, and NICA looks forward to working with the new Minister for Social Services, the Hon. Scott Morrision MP and the Department in further developing key policy for the development of a new Australian Home Childcare sector. 16

17 i The Hon Sussan Ley MP, Assistant Minister for Education address to the Committee for the Economic Development of Australia on Women in leadership the childcare debate. ii Draft Productivity Commission Report into Childcare and Early Childhood Learning draft recommendations 12.2 page 45. iii Productivity Commission Childcare and Early Childhood Learning draft recommendations 12.2 pages 45 & 46 iv Draft Productivity Commission Report into Childcare and Early Childhood Learning draft recommendation 7.10 page 60 v Draft Productivity Commission Report into Childcare and Early Childhood Learning draft recommendation 7.10 page 60 vi The Hon Sussan Ley MP, Assistant Minister for Education address to the Committee for the Economic Development of Australia on Women in Leadership the childcare debate 17