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Regulatory Impact Statement Response to Early Childhood Education and Care Reforms - NSW OSHC Sector Response. August 2009
Building the Education Revolution (BER) Network of Community Activities as the NSW Peak Body for OSHC has increasing concerns regarding the implementation of the Building Education Revolution funding in NSW and its effect on OSHC services. Network's Position Paper on BER. September 2009 Read the media coverage of this issue in our OOSH in the News section >>
On the Road to Regulations For OOSH “Network supports the introduction of regulation to the sector but we are aware that for many services this is not the case. OOSH services have been overwhelmed with change since 1997 as a result of changes implemented by the federal government. Many services are exhausted and morale is low, we therefore urge the Government to proceed with caution, taking the implementation of regulation in slow manageable stages." In May 2006 the Minister for Community Services announced the introduction of regulations into Out of School Hours Services with plans to commence consultation by late 2006. Network of Community Activities as the peak body for the OOSH Sector in NSW has met with both the Minister for Community Services and the project reference groups to ensure that they are adequately briefed on the unique needs of the OOSH sector. The introduction of regulations will be a challenging and exciting time for services. It is envisaged in early talks that the legislation will NOT be an extension of the Long Day Care regulations. It is also planned that the regulations will very much resemble the National Standards and NOT be based on an onerous amount of paperwork and red tape. Regulations will form the baseline from which all services will be required to operate. For the safety and security of all children and to ensure that viable and quality services are not undermined by unscrupulous “cash in hand” backyard operators regulation IS essential Action To Date A meeting of the Network OOSH Reference group was held on Wednesday 29 November and DOCS representatives met with regional representatives from the sector to brief them on the work of the project to date and accept the feedback from the representatives on the nature and scope of regulations. In November the Department of Community Services released a discussion paper and draft legislation that reqiures all services to register. 19 submissions were received in regards to this legislation with only one dissenting voice among them. The legislation was subsequently passed and services will now be required to register. Network negotiated in March for a working group of practitioners to review the registrations forms for the regulations and provide feedback. These forms are due for release in the coming weeks and services will have until July 1 to register. Jenny Gratton (SHARE, Summer Hill), Sue Kemp (SPLASH, Ashbury) and Wendy Castalleo (Abbotsford Community Centre) kindly donated their time to participating in a feedback meeting at DOCS Ashfield. This consultation will assist to ensure that the forms going to the services are ‘user friendly’ and their input did result in a simplification of the paperwork services will be required to complete in the initial stage. Except from Networks Submission to DOCS Discussion Paper & Draft legislation
Next Steps for Regulation
Network of Community Activities will be posting regular updates on the regulations on it’s website www.netoosh.org.au throughout 2007.
An Integrated Quality System for Children’s Services Strengthening quality or diluting it? “Network supports the notion that there are common elements across all services types and that these can be highlighted through the delivery of a single model. However, we are concerned that the system, currently recognised as the best in the world will be watered down and become ineffective if the elements exclusive to the different sectors are not identified and retained. The OSHC sector has been working through the OSHCQA system and to date results have been positive with a noticeable improvement in service delivery, quality and professional pride. We ask that you acknowledge this commitment that the sector has shown by ensuring wide consultation and information dissemination is undertaken.” The Minister for Families, Community Services and Indigenous Affairs, the Hon Mal Brough MP, announced in May 2006 that an integrated Child Care Quality Assurance (CCQA) system would be created. A National Child Care Quality Assurance Advisory Group has been established by the Department of Families, Community Services and Indigenous Affairs (FaCSIA). The role of the National Advisory Group is to provide feedback and advice to FaCSIA and the Minister, in respect of the development of the integrated CCQA system. Robyn Monro Miller from Network has been appointed to this reference group representing the National Out of School Hours Association (NOSHA). Any QA system that is developed must include the OOSH context .And that.....will be the greatest challenge not just for the OOSH Sector and NCAC but for the early childhood sector, because changes to make a system ‘ streamlined” and encompassing all sectors place in jeopardy the efficacy of the achieving a quality system that meets all needs. The first draft of the standards for the integrated CCQA system is now available for discussion. The integrated CCQA standards will apply to child care services including family day care, long day care and outside school hours care. You can now download a copy of the Draft Standards (which now includes a preamble) and Framework Guide from the FaCSIA Website. The link is below: You will note the Standards are not classified according to levels of quality (eg Satisfactory, Good Quality and High Quality). There is only one level of quality in the draft standards – the standard required for Accreditation. This is the standard that delivers quality child care for every child, everyday. Indicators that apply to a specific service type are clearly noted. Please note these standards are DRAFT only. Preambles will be developed for each Quality Area/Principle to further explain and place context around the indicators. Network is concernd that the new system will not meet the unique needs of services nor reflect the diversity of children’s services. A number of other peak groups share this concern. Services will be kept informed and will be advised of new developments.
Child Care Management System (CCMS) The Child Care Management System (CCMS) will be piloted in the second half of 2007 in Long Day Care and Family Day Care and implemented progressively from January 2008. It is anticipated that OOSH will have the system implemented in mid 2008, pending the outcomes of trialling and grants being allocated to services to upgrade software and provide access to computers. There are three goals underpinning the new Child care Management System. These are
In short, the new CCMS is about managing Child Care Benefit on line. This poses a number of issues for many OOSH services and the Minster is yet to fully address how these will be managed. The consultation process in late 2006, and more recently feedback from the CCMS Industry Reference Group, provided valuable input into the ongoing development of CCMS. Here is an update on a few of these. Enrolment Advance The service Is eligiblbe for an enrolment advance of funds for each child however the Minister has agreed that services will be able to elect not to receive Enrolment Advances if they choose for each child. Provision of CCB Percentages The Minister has agreed to the CCB percentage being made available to services, together with other eligibility information at the point at which an enrolment is confirmed, this will be done by logging into the computer system. Absences
Application of CCB Eligible Hours The Minister has decided that in order to provide a greater level of certainty to services, they should be able to ask parents if they are attending multiple services and, if so, for the parent to nominate the number of eligible hours they wish to claim at each service and that this information will be recorded on CCMS to assist with the calculation of CCB. Following on from industry consultations and feedback, FaCSIA is undertaking further work on the following issues:
FACSIA is currently working on information products to go to all child care services about CCMS. These will be discussed with the CCMS Industry Reference Group later this month. Network remains concerned with the potential increase in administration and requirement for computer literacy and access to computers. However, services should not be alarmed at this stage as the Governments $10 million dollar investment in the process may not proceed if there is a change in Minister or Government. With an election imminent by the end of the year this is one initiative that may be modified or scrapped before it reaches us!
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