Sutherland Shire Council Children s Services (SSCCS) currently operates a range of services, which include

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1 Page 1 of 10 ABOUT US Sutherland Shire Council Children s Services (SSCCS) currently operates a range of services, which include 11 Early Education Centres 1 Before and After School Care Centre 2 Vacation Sites 21 Current Family Day Care Educators SSCCS also operates as a Registered Training Organisation and delivers: Certificate III in Early Education and Care, Diploma in Early Education and Care, and Cert IV in School Age Care, Diploma in School Age Care, accredited courses. A non-accredited training program undertaking both scheduled courses related to Early and School aged Education and Care and also providing customised training to interested parties. Parent training including partnerships with local community health and project youth and other family services to assist with building the capacity of families within the Sutherland Shire and surrounds. SSCCS is supported by a: Central administration team for management of waitlists, fees and enquiries. A multi-tiered management team located with the administration team at central office. Overarching Response We believe that some changes proposed in the RIS will have a positive impact for children attending Early and Middle Education and Care in Australia. However, we are very concerned regarding some proposed changes to the Regulations. In particular the change to the National Quality Standard is a major concern. We believe that if implemented these changes will firstly create unnecessary regulatory burden as services adapt to the change and secondly the proposed changes reduces and waters down the current high standard required in order to operate a quality education and care service within Australia.

2 Page 2 of 10 Refining the National Quality Standard and assessment and rating process Proposal 1.1 Reducing the complexity of the NQS Our preferred option 1.1A No change Sutherland Shire Council Children s Services is strongly opposed to any revision of the National Quality Standard through this NQF Review process. The reasons for this opposition include: Changing the NQS will result in a regulatory burden on current services and have a cost impact. The change would require professional development and resources to the sector as a whole which will in turn result in cost implications. Rather than merely amalgamating the NQS standards, the proposed revised NQS provided in the RIS appears to remove or water down professional standards and requirements such as intentional teaching. The removal of these re-defines and reduces the quality required for providing Early and Middle Education and Care to children in Australia. Examples of these include (but is not limited to); o Amalgamation of Elements to 2.A.ii waters down the requirements for hygiene and infectious diseases. o The removal of sustainable practices. o Amalgamation of into 3.A.i removes the requirement of ensuing access and participation of all children to supporting o 5.A.ii Educators promote the dignity and rights of each child - At all times has been removed. The proposed revised NQS contains ambiguous language such language leaves standards and elements that are not clearly assessable. Examples of this language include, (but is not limited to) the below; o Effective illness and injury management. (2.A.11) o reasonable precautions (2.B.i) Some key concepts from the learning frameworks are no longer present in the proposed Standard, such as Intentional Teaching and Scaffolding have been removed from the Descriptor and moved to the Concept. We believe that the Concept column could be added to the existing Standard as an interim measure because this gives further direction to services and Assessment and Compliance Officers.

3 Page 3 of 10 Proposal 1.2 Streamlining the quality assessment process Our preferred option 1.2B streamlining the process of assessment and rating Sutherland Shire Council Children s Services support streamlining the process of assessment and rating and believe this may lead to greater consistency and improved timelines. We would like to see a streamlined approach encompassing the following elements: Removal of assessment of regulatory compliance by Assessment and Compliance Officers as part of the Assessment and ratings visit. We strongly believe that Assessment and rating visits should focus on quality practices. Services may participate in a self-assessment of compliance prior to the assessment and rating visit, or alternatively an increase in spot visits relating to compliance can be undertaken prior to the Assessment and Rating process. Increased quality training for Assessment and Compliance Officers including training on how meeting the standards would appear in each sector type and how the standards should be assessed in services catering for culturally and linguistically diverse and Aboriginal communities. Recruitment for Assessment and Compliance officers should hold sector specific qualifications and experience as a mandatory minimum requirement, and currency in the sector should be upheld and promoted and maintained. Sector specific guidelines to be developed for Assessment and Compliance Officers including a glossary of terms for assessment and rating by sector type. This should be a publicly available document which could increase the capacity of educators to apply the standards to service delivery. Such guidelines would provide clarity to both educators, assessors and families in the differences in how the Standard looks in each sector. Proposal 1.3 OSHC Documentation Our preferred option is that 1.3B (program not child level documentation) and 1.3C (retraining authorised officers) both be adopted. Training of Assessment and Compliance Officers in the context of OSHC services is currently inadequate. The proposed one day of sector specific training is not enough and training must include a practical component. The trainers delivering the training to

4 Page 4 of 10 Assessment and Compliance Officers must have relevant qualifications and experience in working within the OSHC sector. Current requirements in relation to programming for every child in OSHC does not reflect the unique nature of this service type or manifest the balance required for school aged children to have autonomy and relaxation. Children and staff attendance - particularly in the Vacation Care programmes are often sporadic and the current requirements are often unattainable for educators, with children often missing out on valuable face to face interaction and chances for relaxation after full days of learning at school. We agree with the proposal that documentation about development of the program would be sufficient for OSHC as long as the requirement for this program is to be reflective of and incorporate My Time Our Place. Further, we believe that proposal 1.3 should be expanded to apply to school age children in any service type. Proposal 1.4 Significant Improvement Required Rating Our preferred option is 1.4B (removal of rating and ceasing of A&R process) We believe that the A+R process ceases immediately and the service receives a rating of Assessment and Rating Suspended Pending Regulatory Compliance. Parents should be advised of this via a compulsorily displayed notice in the service and notices on public sites such as My Child and the ACECQA register. Proposal 1.5 Exceeding the NQS Rating Our preferred option is a further proposal. We believe that a further distinction should be made for a service to achieve an Exceeding rating. And have two proposals for this option. o If the proposed NQS is adopted, we believe that 1.5B - All standards in a Quality Area must be rated as Exceeding AND all 7 Areas must be rated as Exceeding for an overall Exceeding rating to be given. o If the current NQS was to remain, we propose that rather than all standards being rated as Exceeding, we believe that All Areas must be rated at Exceeding for an overall Exceeding. This would mean that for Quality Areas 2, 3, 6 + & 7 only two of the three standards would be required to be rated as Exceeding, however all 7 areas would be required to have an overall Exceeding. Proposal 1.6 Excellent Rating

5 Page 5 of 10 Our preferred option is 1.6B (Removing the Excellent Rating) We believe the existence of the Excellent Rating: Has little impact of quality improvement. Is inequitable due to the high cost not all services can afford to apply. The resources devoted to assessing services as excellent could be better used, such as assisting services Working Towards to achieve higher quality. Is not truly reflective of quality how can a service be excellent if they have not obtained an exceeding rating in all elements Proposal 1.7 Ensuring ratings accurately reflect service quality Our preferred option is 1.7A No change. We believe that the overall rating provides families with an easily comparable, easy to understand benchmark for comparison when looking to access education and care services for their children. Proposal 1.8 Length of time between assessments Our preferred option is 1.8A No change. We believe that the maximum 3 year assessment ant rating cycle for services should remain, and further that resources are increased to ensure that the 1 and 2 year timeframes are met for services working towards and meeting quality standards. We strongly oppose an increase to a 5 year cycle, and feel that a child could and would have their entire experience within Early education at a low quality service which would provide long lasting detrimental effects for them. Removing supervisor certificate requirements Proposal 2.1 Removing supervisor certificates Our preferred option is 2.1B Remove the requirement for supervisor certificates

6 Page 6 of 10 Expanding the scope of the NQF Proposal 3.1 Additional services to be included in the NQF Our preferred option is 3.1C include services currently regulated outside of NQF. We believe eventually all BBF entre based services, occasional care services, playschools and mobiles should be under the NQF, but as a first step those that are currently regulated under state laws should be brought in scope. We believe it is essential that these services receive additional resources to enable them to work towards meeting the NQS and embedding the learning frameworks in their services where they do not currently. We also believe it is essential that Assessment and Compliance Officers receive additional training to enable them to assess these service types in a way that takes into account their unique service delivery. Proposal 3.2 options for rating these services Our preferred option is 3.2A assess and rate these services the same way as others. Again these services need additional resourcing, recognition of their unique operating situations and appropriate training for Assessment and Compliance Officers. Extending some liability to educators Proposal 4.1 Extending liability to educators Our preferred option is 4.1A no change Changes to prescribed fees Proposal 5.1 Introduce fee for extension of temporary waiver Our preferred option is 5.1B Introduce a fee for the extension of a temporary waiver. It is our belief that a number of services are applying for temporary waivers in relation to staffing as a cost saving mechanism and therefore approve of the proposal to introduce a fee for extension of temporary waivers.

7 Page 7 of 10 Proposal 5.2 Increase in provider approval fee Our preferred option is 5.2B increase Provider Approval fee by 100%, Proposal 5.3 Increase in service approval fee Our preferred option is 5.3A increase Service Approval fee by 100% Proposal 5.3 Increase in annual fee Our preferred option is 5.4A no change National Educator to child ratio for OSHC services Proposal 6.1 OSHC ratios Our preferred option is 6.1B introduce an educator to child ratio for OSHC services We believe a 1:15 ratio is appropriate for school aged care children. Improved oversight of and support within FDC services Proposal 7.1 Approval of FDC across jurisdictions Our preferred option is 7.1B already introduced Proposal 7.2 Limit the number of educators per service Our preferred option is 7.2B already introduced Proposal 7.3 Ratio of FDC co-ordinators to educators

8 Page 8 of 10 Our preferred option is 7.3D - ratio of 1:15 for CDO We believe the ratio must be based on the numbers of Equivalent Full Time Educators not educators per se. Proposal 7.4 Mandating a minimum Certificate III for FDC educators Our preferred option is 7.4B - introduce the minimum Certificate III Proposal 7.5 Educator assistant s activities Our preferred option is 7.5B create an offence Proposal 7.6 Principal office notifications Our preferred option is 7.6B as it has already been mandated Proposal 7.7 Powers of entry Our preferred option is 7.7B as it has already been mandated

9 Page 9 of 10 Other changes which will have a regulatory impact Proposal Number Position Comment Approvals Agree Agree Agree Agree Waivers Agree Supervisors Disagree We believe this is weakening of the existing regulations. The Regulatory Authority in NSW has always had the role of approving the Nominated Supervisor appointed and we believe this should continue. We believe the Approved Provider should be authorised to determine the Responsible Person at any one time Agree Agree Agree Agree Agree Agree We believe rather than nominating a new term the term Responsible Person should be retained in lieu of Certified Supervisor Agree

10 Page 10 of 10 Operational Issues Disagree We disagree strongly that weakens the requirements for services to make adequate arrangements for employing qualified early childhood teachers at all times. Although we note the NSW savings provision we believe this should be extended to all states Agree Agree Compliance, review, monitoring and enforcement Agree Agree Agree Agree. Information sharing Agree Agree Agree Administrative requirements Agree Agree Agree