Between 29 March 2018 and 29 June 2018, the Scottish Government ran a joint consultation with COSLA on the "Early Learning and Childcare Service Model for 2020: Consultation Paper". The consultation document set out a proposed range of criteria that would form the National Standard underpinning a new 'Funding Follows the Child' approach to early learning and childcare (ELC) service provision.
The consultation consisted of a combination of closed and open ended questions covering eight issues. The online consultation was supplemented by eight consultation events facilitated by the Scottish Government ELC Service Models Team at various locations across Scotland where the majority of attendees were ELC service providers.
There were a total of 219 written submissions; 129 from organisations and 90 from individuals. The type of organisations that responded most often were private nurseries (48 respondents), followed by local government respondents (29 respondents) and representative bodies (14 respondents).
This report presents the findings from an analysis of all written submissions and notes from the eight consultation events. The main findings are summarised below.
The process for becoming a funded provider
Respondents highlighted that the process for becoming a funded provider had to be accessible, that there should be a clear application process and guidance to support applicants. It was argued that local authorities had a key role in supporting this process. Respondents raised that the quality inspection process should involve regular, consistent monitoring and that further clarification was required on the respective roles of local authorities and the Care Inspectorate.
Many respondents raised that the funding rate for service providers should be sustainable. Some felt that the funding rate should be standardised, however the higher cost structure of private and third sector providers should be considered.
The partnership between different local authorities and funded providers
Respondents highlighted the importance of regular, effective communication between local authorities and service providers. It was also argued that the relationship should be underpinned by equity, trust and transparency in order for provider neutrality to be realised. The availability of support and training that is equally accessible to all provider types was said to be another guiding principle as well as payment of the living wage. Finally, repondents felt that is was important that all parties worked towards positive outcomes for children, specifically the aims and principles outlined under Getting it Right for Every Child (GIRFEC).
Minimum qualification requirement for childminders
Respondents felt that there were a number of advantages to the proposed minimum qualification requirement for childminders (SCFQF Level 7), including improved knowledge of child development, increased status in the ELC sector and greater opportunities for professional development. Wider benefits of the proposal were argued to be higher quality and more consistent care provision which could be more easily monitored and provide reassurance for parents. Respondents also felt that parity of qualifications across different provider types could aid movement between services and continuity of care.
Some raised concern that the care provided by childminders was already of high quality and that highly qualified, experienced childminders may be inclined to leave the sector, hindering the intended expansion of ELC provision.
Access to funding for training
Of the 187 respondents who answered the question on childminders' ability to access funding for training 55% did not know, 40% felt that funding was available and 5% felt that it was not. In the open text questions, respondents described the funding opportunities that were currently available, however it was argued that these had previously been harder to access for childminders.
Access to flexible training
Almost half (47%) of respondents felt that there were flexible training options available for childminders which they could engage with whilst running their businesses. Respondents emphasised the importance of flexibility for childminders and the need for further exansion of the options available.
Physical environment and outdoor learning
Over half of respondents felt that criteria three of the National Standard captured the ambition for outdoor learning and play to become a defining feature of funded ELC in Scotland. Respondents emphasised the positive impact that outdoor learning and play had on children's development but felt that more clarity was needed on the definition of outdoor play and regularity of access.
The majority of respondents outlined various challenges linked to criteria three including access to outdoor space, health and safety, attitudes of parents, weather conditions and staffing. Suggestions for strengthening outdoor learning and play included investment in capital funding, shared access to outdoor spaces and transport for providers that would have to travel.
The National Standard as a whole
Consistency across funded provider settings
Whilst some respondents welcomed the proposed criteria, most were unsure as to whether the criteria set out in the draft National Standard would ensure consistency across funded provider settings in terms of quality, accessibility, flexibility and affordability and requested more information about each of the criteria. Many felt that the National Standard must be supplemented by sustainable funding rates and that the funding rates, once announced, will be a deciding factor.
Increased choice for parents
Just under half of respondents said that they did not know whether the criteria set out in the draft national standard would support increased choice for parents and carers but most of the remaining respondents felt that it would. It was argued that a provider neutral approach should help to ensure there is increased choice for parents but that this would rely on equal promotion of all ELC funded providers by local authorities. There was some concern that supply and demand could limit choice in certain areas.
Criteria not included
Nearly half of all respondents felt that some criteria had been left out and that a range of issues were not sufficiently addressed or clarified within the draft National Standard. These included audit structures, appeal procedures, involvement of parents and carers and blended models of ELC.
Fair and proportionate for all
Written respondents were asked whether they felt that the proposed criteria were proportionate and fair for all. Most respondents said yes, with 25% saying no. Respondents argued that in order for the implementation of the criteria to be fair and proportionate for all the approach needs to be consistent across the sector and there needs to be a fair funding rate for different provider types. There was concern that partner providers face disadvantages compared to local authority providers in relation to infrastructure, cost and workforce issues and this should be acknowledged when setting the funding rate for private and third sector providers.
Fair and proportionate for childminders
Respondents were largely unsure whether the criteria was fair and proportionate for childminders. Individuals, many of whom may be childminders, were more likely to say that it is not. Respondents raised concern that the smaller size of childminding services and limited capacity would mean that childminders would need more support and some requirements could threaten the sustainability of their businesses.
When asked which areas they would look to be addressed in the technical guidance note for implementing the Living Wage commitment, most respondents used this as an opportunity to raise concern that the Living Wage should apply to all funded and non funded staff in the ELC sector. Respondents felt that the technical guidance note was less of a concern than ensuring the funding rate was high enough to allow providers to pay the Living Wage. There was felt to be a need for clarity on if and how the Living Wage commitment applied to all staff working in the ELC funded sector and concern that implementing the Living Wage could threaten business sustainability.
Inclusion of a probationary period for new settings
Just over half of respondents who answered the question on introducing a probationary period for new services agreed with this proposal, with organisations more likely to agree than individuals. It was argued that a probationary period would support the expansion of funded ELC provision by enabling new services to begin operating but that conditions should be introduced to distinguish between services which are entirely new and established businesses in the non funded sector. Respondents sought clarity on the length of the probationary period and felt that an inspection should be conducted by local authorities within 12 months.
Support during the introduction of the National Standard
When asked about the support that providers would need during the introduction of the National Standard, respondents referred to the need for flexible training that was accessible to all provider types. Respondents also raised the need for unambiguous, realistic funding that is paid in advance and covered all relevant costs. The importance of clear, consistent guidance on implementing the National Standard for all provider types shared ahead of the deadline for expansion was also highlighted. Finally, respondents felt that providers needed support to deal with workforce challenges such as staff retention and the need for upskilling.
Representative and public bodies emphasised the need to support parents to understand the processes underpinning the expansion of ELC funded provision so they could make more informed choices.
Email: Euan Carmichael
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