1 P a g e. Emma Richards Project Co-ordinator CS&HISC Children's and Youth Services Review Project P.O. Box H61, Australia Square, NSW, 1215

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1 Emma Richards Project Co-ordinator CS&HISC Children's and Youth Services Review Project P.O. Box H61, Australia Square, NSW, /12/2012 Please find below a submission from Community Child Care Co-operative (NSW) on Draft One of the revised children s services qualifications. Thank you for the opportunity to make comment on the draft. Yours faithfully, Leanne Gibbs CEO Community Child Care Co-operative 1 P a g e

2 Who we are Community Child Care Co operative (NSW) was established in 1978 and is a not for profit organisation that promotes, supports and advocates for quality early education and care services; meeting the needs of children, their families and the community. Community Child Care Co operative NSW has a variety of roles in the NSW education and care sector which leave us uniquely placed to provide this submission. We are: a peak organisation in NSW representing over 1300 education and care services, families and individuals. Although Community Child Care Co operative represents services in all areas of the education and care services sector, our full members are community based long day care services and community based preschools. Our submission thus predominantly reflects the interests of these two groups A Registered Training Organisation offering a variety of nationally accredited VET courses to education and care services in NSW and their employees, including early childhood teachers. The lead agency of Children s Services Central, the Professional Support Co ordinator in NSW. This program, funded by the Australian Government, under the Inclusion and Professional Support Program, provides a range of professional development to all Australian Government Approved Child Care Services in NSW. A well respected advocacy organisation for education and care services in NSW. CCCC endeavours to: Provide leadership which empowers the decision makers within education and care services; Identify service provision gaps and needs, and proactively target resources to these areas; Support and collaborate with other education and care service providers who reflect similar philosophical beliefs. 2 P a g e

3 General Comments Community Child Care NSW wishes to comment on draft one of the revised Certificate III in Children s Services and the Diploma of Children s Services. We make no comment on the Outside Hours School Care qualifications, as these are outside our major areas of expertise and knowledge. 1. The move to update the qualifications and streamline the packages is exceptionally timely for the education and care sector given the important changes to the skill and vocational requirements for workers in this sector bought about by the implementation of the New National Quality Framework and the Early Years Learning Framework. Employees working in the new regulatory environment that education and care services now operate in requires an understanding of this regulatory framework as well as the National Quality Framework as a whole, the National Quality Standard in particular and the Early Years Learning Framework. It is important that these components are reflected across all competencies within the qualifications to reflect current job roles within the sector. 2. Community Child Care NSW looks forward to a greater involvement in the further review process. The National Quality Framework is essentially based on delivering into the sector greater numbers of more qualified staff for education and care services. The skill set of staff achieved through qualifications must meet the requirements of the National Quality Framework in order to meet the mandated quality improvements. 3. This review is therefore vitally important to the education and care sector, and Community Child Care NSW offers our understanding of the sector as an RTO, a peak body, as the Professional Support Co-ordinator in NSW and as a provider to support the review and ensure that the packages, when adopted, will enable the appropriate skilling of the sector. 3 P a g e

4 Overarching comments on the Certificate III and Diploma Entry 4. Community Child Care believes that the removal of entry requirements to enable students to have direct entry into the Diploma will encourage more students to obtain the higher qualification. We believe this is a sensible move, and note the necessity for all subject content of the Certificate III to be covered within the Diploma due to the revised entry process. 5. The Certificate III in Children s Services is now the entry level qualification for anyone wishing to work with children in the majority of early education and care services. Community Child Care believes that the level of responsibility and capacity to perform activities (as expressed in the assessment requirements) is above what should be required of an individual holding a Certificate III qualification. The content of the unit is essentially pitched above the level a student studying for this qualification could be expected to have. 6. The Certificate III has an emphasis on implementation. Without greater content knowledge it would be impossible for an educator to implement practice. Complex decision making skills are required to individually implement practice - this is too great an expectation for a Certificate III qualified educator. More realistic is implementation working in coordination with other team members and under the direction of a team leader. Language 7. Like any sector, the language used in the education and care sector changes to reflect current knowledge. An example of this is how the term education and care service has almost replaced the term children s service or its predecessor, child care sector. It is important that education and care is used throughout both packages. 4 P a g e

5 8. It is however not just the use of the new industry name that needs to be reflected but also the contemporary language used within the education and care sector. The use of strengths based language to describe children s development is dominant within the sector, but this is not apparent in the revised packages. 9. Likewise the education and care sector is a sector, not an industry. The use of the term industry should be removed from the qualifications. Embedding the NQS and EYLF 10. Community Child Care NSW applauds the introduction of the unit Support the Implementation of an Age Appropriate Learning Framework into both qualifications. 11. A greater understanding of the basic premise of the learning frameworks, that the curriculum should develop from the interests and skills of the children being educated, must be embedded in this unit. 12. The concepts within the learning frameworks also need to be integrated throughout every unit and used as a basis for the competencies. Although familiarity with the outcomes, principles and practices of the frameworks is an essential competency for any educator, these also need to be woven through all units, from children s safety to caring for babies. 13. Educators spend a great deal of their contact time facilitating engagement with the creative and expressive arts. This area is missing from the draft. The importance of creative arts to children s education means competencies around this must be core. Caring for Babies 14. Community Child Care is pleased with the inclusion of this unit in both qualifications. The draft unit needs to be revised to reflect contemporary understandings of best practice education and care for babies, and the use of the Early Years Learning Framework in 5 P a g e

6 working with this age group. The unit does not reflect well researched understandings of babies development from a strengths based viewpoint. Omissions 15. Community Child Care NSW believes there are a number of omissions in the core units in both the Certificate III and the Diploma. There needs to be core competencies and units on cultural competence and understanding of Aboriginal and Torres Strait Islander culture and Culturally and Linguistically Diverse (CaLD) children and families. Educators holding either a Certificate III or a Diploma must be culturally competent and must have a base understanding of Aboriginal and Torres Strait Islander culture and heritage and CaLD issuesto be equipped to educate and care for children in Australia. As well as a specific core unit/s covering these competencies, understandings of cultural competency must be reflected across all core units. 16. Community Child Care NSW does not believe that the Certificate III contains enough content about children s development. We acknowledge there is more content in the Diploma on children s development and see this as foundational understanding for any educator working in the sector. 17. There must also be embedded in both competencies determining and responding to children s interests in designing and implementing curriculum. This appears to be absent from both qualifications. 18. Sustainability is a major focus of practice within early education and care services. This is reflected in the National Quality Standard. Sustainability needs to be reflected across and embedded within all units. 19. The National Quality Standard is now the overarching document that describes the optimal operation of an education and care service. An absolute and thorough understanding of the National Quality Standard must therefore be an essential competency for any educator. In addition the content of the National Quality Standard must be reflected in the competencies and the content of every unit within the Diploma 6 P a g e

7 and the Certificate III. This is not currently the case. Unless this occurs, students will be learning a body of knowledge that is at odds with what all services must aspire to. Community Child Care NSW believes a specific unit on the National Quality Standard is as required as the new unit on the Early Years Learning Framework. We also believe that the naming of units need to reflect the names used within the National Quality Standard. Job descriptions within the sector are being aligned with and developed from the National Quality Standard this needs to be reflected in the competencies we are equipping educators with. 20. The new regulatory environment for early education and care services, for the first time is nationally consistent and applied. The regulatory framework within which the majority of education and care settings now operate must be included and reflected within all units of both qualifications. Community Child Care NSW believes it is currently, for the most part, missing from the units. Where competencies do refer to regulations they refer to an out dated concept of state and territory regulations. 21. The reality in our sector is that many Diploma qualified educators become education and care service co-ordinators and directors with little further training, education and experience. It is vitally important the Diploma qualification contains more management skills such as policy development, staff and financial management skills. These are currently not comprehensively covered in the qualification. 22. In the Diploma there is currently no consideration of leading a staff team, undertaking collaborative management or assisting staff through change processes. Co-ordinated work and collaborative management is the only pathway for education and care services to meet the National Quality Standard so this needs to be a reflected in competencies within the Diploma. Tonal differences 23. There appear to be tonal differences between the revised qualifications and current sector practices. An example of this is the emphasis across units on the individual conducting their duties in isolation, whereas educators in early education and care 7 P a g e

8 settings work in coordination with other team members and often in consultation with a more senior staff/higher qualified team member. Education and care can be carried out by individually qualified educators, for example in family day care settings, but the majority of educators will work within small teams in centre based settings. The tone of the units and competencies needs to reflect this reality. 24. The other major tonal difference is the emphasis throughout both qualifications on the care of babies and children. Strong arguments exist that care is implicit in education and as such, the focus of language in current use in the sector gives more emphasis to education and less to care. Because this is not reflected in the qualifications, they appear somewhat dated tonally. Specific comments on courses and competencies We include some issues that became apparent on initial assessment of the units. These should be read in conjunction with the overarching comments above. 25. Community Child Care recommends that units such as HLTHIR403C Work Effectively with culturally diverse clients and co-workers and CHCIC302A Support Aboriginal and/or Torres Strait Islander families to participate in children s services be core units of the Diploma qualification 26. CHCCN302A Provide care for children There is a duplication of content within this unit could be streamlined. 27. CHCIC301E Interact effectively with children In the Assessment Requirements under Knowledge Evidence the unit refers to behaviour management. This should be written using more contemporary education and care language. 28. CHCFCXX2 Foster physical development in childhood Community Child Care NSW is pleased to see this unit having concise guidelines such as the requirements to follow national standards and the fundamental movement skills. Could other units have similar levels of guidance in their assessment requirements? 8 P a g e

9 29. CHCIC501A Manage children s services workplace practice to address regulations and quality assurance This unit correctly embodies competencies around Quality Improvement Plans. In the Assessment Requirements under Performance Evidence there seem to be significant emphasis on completing a whole QIP. Section also refers to Self-Evaluation. We believe this may be better referred to as Self-Assessment to reflect the wording of the National Quality Framework. 30. CHCPR303D Developing understanding of children s interests and developmental needs. Knowledge Evidence expectation of developmental knowledge for children aged 0 12 years, is too broad for this qualification. It would be more suitable to expect them to have knowledge of children from birth to school age. 31. CHCCN520C Advocate for the rights and needs of children and young people. Community Child Care believes this should be a core unit within the Diploma qualification. Conclusion We offer these comments on the draft for consideration in the next stage of the process. Community Child care NSW will welcome the next opportunity to be involved in consultation and we plan to have in depth consultation with our members in coordination with the Industry Skills Council. The alignment of the latest developments in the education and care with the qualifications of Certificate III and Diploma ensures the delivery of quality education and care for children and families and facilitates career pathways for those people entering and continuing in the early education and care sector. 9 P a g e