The consultation document provided respondents with the opportunity to detail any other comments they had in relation to improving inspection of ELC and SAC across Scotland. Various ‘other’ issues were also raised throughout consultation responses and are included below.
Q4.1 and Event Q8. Do you have any additional comments in relation to improving inspection of ELC and school age childcare services in Scotland?
Overall, 118 respondents who submitted written contributions provided a response at this question, while a further 282 comments were received during the events. Despite this significant response rate, however, the vast majority of the comments related to issues already covered elsewhere in the consultation, and are therefore discussed above. Only new issues, or those where significant additional emphasis was provided, are outlined below.
Respect Staff as Professionals
A few highlighted a need to support staff, to treat them as professionals, and to empower them to deliver, both within any inspection framework and more generally. There was a general sense that staff felt ‘overworked and undervalued’:
“Early years practitioners appreciated and paid as professionals, opportunities to progress as Early Years pedagogy rather than seeing teachers as the main educators and practitioners as support staff.” (Individual)
“To promote the advancement of the Empowerment agenda, we would encourage the Scottish Government to conduct a more fundamental review of inspection and scrutiny processes… Reform must be underpinned by cultural change. We would urge the Scottish Government to respond positively to that challenge, demonstrate that it will place its trust in the professionalism of teachers and Early Years practitioners, and adopt a more progressive model of quality assurance - one which is practitioner-led, which features professional collaboration and learning across settings, with time invested to facilitate collaborative processes to support reflection and inform improvement, where required.” (Trade Union)
While support, respect and empowerment was relevant across the sector, it was suggested this was particularly acute for staff in SAC settings and childminders. They felt they were being assessed against nursery/ELC requirements and so it was argued that this could result in staff either leaving the professional altogether, or moving to jobs in ELC:
“Prioritising childminders is essential and failing to improve the level of support offered to them will have negative implications in the future and on the sustainability of the profession.” (Childminder)
Promote Inclusion and Diversity
Similar to the issues for the SAC sector, a number of other specialist providers noted their lack of consideration within the current system or in the proposals for a shared framework. This included those who provided ASN services, the provision of services for deaf children, and Gaelic medium provision.
For example, several respondents and event attendees noted a rise in the number of children with ASN within settings which was not taken into account by inspectors (and which providers felt they were not supported with). One event attendee also noted that ASN OSC was entirely overlooked, but that it required separate consideration as it provided services for those up to age 18/19 and was distinctly different from most other ELC and SAC sectors. Another respondent discussed the lack of provision for deaf children, both in relation to the general lack of national provision and the lack of HMIE and Care Inspectorate inspections of ELC settings for deaf children:
“When I have asked members of HMIE why they don't inspect early years settings with deaf children… they say that is not their area, ask the Care Commission [Inspectorate]. I have never seen any Care Commission [Inspectorate] inspections of these services. This means there remain great differences in practice across the 32 authorities. There are quality standards produced by the Scottish Sensory Centre in 2011 and currently being updated, but the inspectorate has not endorsed them. This leads to variable standards and most authorities don't refer to early years standards, even though this is a crucial age for language development.” (Academic organisation)
Several respondents called for diversity and inclusion to be embedded into any new framework. One urged consultation with Black and Minority Ethnic (BME) communities, learners and practitioners, and BME led and anti-racist organisations, as well as collaboration with those involved in the Race Equality and Anti-Racism in Education Programme, to ensure race equality considerations were adequately addressed. Another advocated for the inclusion of gender equality within the inspection requirements, while two discussed issues for children with ASN (including those with learning disabilities) and stressed the need for any quality indicators to contain ‘inclusion’. Indeed, one argued that this could help to ensure more settings became accessible:
“The proposal for a shared quality framework states that “It would include quality elements relating to care, play, nurture, wellbeing, education, development and learning”… [Our organisation] believes that ‘inclusion’ should be included on this list and must be a key pillar of any new quality framework.” (Sector representative body/membership organisation)
“Relevant to this consultation is the need to consider how a revised inspection framework might meaningfully assess how well providers are meeting their duties in relation to equality and inclusion. While… inspections currently only covers the children who are accessing the provision that is being inspected, we know that many parents of children with learning disabilities are not accessing their funded entitlement because providers are not able to cater for them. If inspections only consider the children in front of them, then those who simply cannot access their entitlement will continue to remain invisible in this conversation.” (Sector representative body/membership organisation)
Several also felt that Gaelic provision and GME needed to be understood and reflected in the inspection process:
“A clear understanding that Scotland delivers education in two languages, either Gaelic or English, should underpin all development. A range of revisions will be necessary to ensure proposals meet the needs of both the GME and EME sectors.” (Other Organisation)
Collaborative Approach to Development
Some respondents and event attendees advocated for practitioners, local authorities and the Association of Directors of Education in Scotland (ADES) to be involved in reviewing and developing any new shared framework. It was felt this was necessary to ensure it took account of all the different sectors, types of providers, local challenges and needs, etc. In addition, it was suggested that feedback should be sought on early implementation.
A few local authorities felt there was a need to be mindful of the difference between regulation and inspection when developing any new framework. A few others argued that stronger links were needed between the two inspectorate bodies and local authorities. Several suggested that the Associate Assessor role was a strength of the HMIE inspection approach, but was considered a missed opportunity in the Care Inspectorate approach:
“At the moment many central local authority and ELC sector staff are utilised as Associate Assessors and actively participate in Education Scotland inspections. This partnership approach builds capacity, shares good practice, is developmental in its inception and leads to whole system improvement. No such professional role exists with the Care Inspectorate at the moment, thus this opportunity is not available.” (Local Authority)
The Care Inspectorate raised several additional points, both within its formal written response, and from comments provided at the events, as follows:
- Joint work between the Care Inspectorate and HMIE should continue in other sectors, such as “inspections of services for children and young people in need of care and protection across community planning partnership areas”, regardless of any changes made to the ELC/SAC inspection framework;
- The wider improvement work the Care Inspectorate undertakes with funded ELC settings was highlighted;
- A renewed emphasis on leadership across the ELC sector was encouraged, and it was suggested that the Care Inspectorate’s “evaluation of leadership could be a supportive diagnostic for those agencies developing and delivering leadership support and resources across the sector”; and
- · Event attendees stressed that the good practice already in place needed to be maintained, for example, the supportive relationships between inspectors and settings, the well-received Care Inspectorate Quality Framework, the focus on children and children’s rights, and ensuring that children’s voices are heard.
A few attendees at the AHDS event discussed the challenges the sector face in implementing the 1140 funded ELC hours. This included the proposal to roll this out to one and two year olds despite the implementation of provision for eligible 2s and all three and four year olds not yet being complete; a lack of training upon introducing provision for eligible two year olds; and that the 1140 hours model did not facilitate time for training, planning or improvement.
Other suggestions offered by a minority of respondents included the perception that inspection should be rooted in pedagogy, and questions about who evaluated or quality assured the inspectorates/inspectors.
Scope of the Proposed Changes
While some respondents used this opportunity to outline support for the development of a shared framework, perceiving this to be an improvement on the current system and a much needed change, others again indicated that they were more in favour of the creation of a single inspectorate responsible for the sector. They felt that the omission of such an option within the consultation, as well as the failure to consider reform of the inspection process itself, or of the statutory functions currently discharged by the relevant inspectorates, was a missed opportunity. It was also noted that changes to legislation were likely to be needed as a result of the wider education reforms, and so provided an opportunity to streamline the inspection landscape for ELC. While this view was shared across respondent groups, those who attended the Trade Union event were more likely to indicate that the changes should be considered alongside and linked to the wider Education Reforms, which offered the opportunity to be more comprehensive and ambitious:
“There is an imperative to revisit a shared scrutiny body in addition to the shared framework. This is a missed opportunity and should have been part of the wider consultation. To have separate agencies scrutinise the core aspects of care and learning experiences is at odds with the policy landscape of a shared vision. Legislative changes should not be a barrier to progress taking place and there should not be any delay in progressing change as highlighted by the sector.” (Local Authority)
“New legislation may well be required to establish the new HMIE and SQA [Scottish Qualifications Authority]. The opportunity should be taken to properly simplify and streamline the inspection landscape for ELC by including this issue in that legislation. The objective should be to have only one inspection body engaging with a particular setting.” (Trade Union)
While others called for changes to be implemented quickly to support practitioners, those attending the Trade Union event were again more likely to suggest that changes should not be rushed. It was felt that the issues facing the sector were more significant and structural, and required a system and cultural shift rather than a shared framework alone. A few also noted the review on regulation of social care delivery, and felt that all such reviews should be considered holistically. Several event attendees (largely from the Trade Union and ADES events) suggested that the current proposals felt like ‘tinkering’ rather than sustainable and effective solutions:
“ The timing for ELC considerations now is the ideal opportunity to make this work more comprehensive. I am worried that we are tinkering around the edges. There are discussions currently underway in any event on a framework for new national bodies, why can the ELC work not be included as part of that? We should have a comprehensive approach to all of this work. ” (Trade Union Event Attendee)
Regardless of the approach taken, respondents stressed the need to keep children at the centre of all changes.
Situation for the SAC Sector
Finally, while not new information, it is worth reiterating the concerns of the SAC sector, given the strength of feeling that was expressed at this question. In addition to those who mentioned this within the formal written contributions, 52 comments were provided at the SOSCN event, most of which focused on the unique challenges for SAC (and for childminders and unfunded providers). These included:
- Having a lack of time and funding to attend training;
- · Having a lack of non-contact time to complete paperwork requirements;
- Rarely occupying dedicated/sole occupancy spaces which providers have full control over (more relevant to SAC);
- Recruitment and staff retention is particularly problematic due to the hours available (more relevant to SAC);
- A lack of funding for new or updated resources or for improvements;
- The amount and nature of the time spent with the children is very different compared to nursery and/or ELC settings (more relevant to SAC and childminders);
- A play based framework would be required rather than one based on education and learning;
- That the funded ELC framework is applied inappropriately to other sectors currently and providers have concerns that this would be exacerbated in any new shared framework (e.g. bringing those not involved in the funded ELC provision within the remit or HMIE and/or imposing educational indicators on settings where these are inappropriate); and
- That there was a need for the value and contribution of childminders and the SAC sector to be acknowledged, for the voices of those within these sectors to be heard, and for change to be appropriate - indeed several indicated that they had been asked for their views several times in the past but perceived that this had not resulted in any meaningful changes.
It was stressed that these issues either needed to be taken into account and reflected in any shared framework, or that a separate inspection framework and processes was required for the different sectors.
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