School age childcare services - regulation review: feasibility study – final options appraisal

7. Model A – Creating a new specific definition for SACC

7.1 Proposal

Model A proposes that the definition of “daycare of children” in schedule 12 of the PSR Act should be amended and a new separate definition created for SACC.

7.2 Key Elements

This model could enable:

• Review of qualification requirements for the SACC workforce
• Review of job roles and functions in SACC services
• Promotion of the importance and professionalism of SACC services
• Clarity about purpose of SACC

This model would not address:

• Independent oversight and assurance of organised children’s activities
• The lack of parity between SACC and organised children’s activities
• Enabling parents to use UK government childcare tax relief or benefits support for organised children’s activities

7.3 Discussion

SSSC have advised that when a new type of care service is introduced which falls within the scope of SSSC registration, there is a parallel process to develop the job roles and functions which will be needed to support that service, and possibly the requirement to introduce new register groups. This includes consideration of the qualifications, fees and Continuous Professional Learning requirements which would be required by staff working in those roles. A significant proportion of the feedback we have received from the sector is that there are a range of qualifications relevant for SACC services which are not currently accepted for staff working in daycare of children roles. Therefore, we would envisage that creating a new definition for SACC would be an opportunity to identify relevant qualifications that would add most value to SACC services. This could only be done if SACC was to sit as a group separate from daycare of children services.

Feedback from the sector indicates that they are proud of their important role in caring for and supporting school age children and want to be valued for that specific role. By recognising SACC in legislation as a specific type of care service, this would support the Sector by providing them with a sense of identity and demonstrating their professionalism. This would also help to differentiate between SACC services and care services for children under school age, providing greater clarity about their different aims and purpose.

7.4 Conclusion

This model offers an opportunity to directly address a number of the key barriers identified by the SACC sector over a number of years, as SACC would be defined separately from ELC services and it would be the starting point for making changes to SACC workforce requirements. A stronger focus on the uniqueness of SACC and clarity about its aims and purpose may also help to develop a stronger SACC identity with more empowered and confident services. Longer term, it is envisaged that this could make the sector more sustainable and more diverse.

This model will require a change in primary legislation. However, there is already work underway through the IRISR project to review the definitions of care in the PSR Act so aligning these two policy areas has the potential to make best use of resources in both the Scottish Government and the Regulators, especially in terms of managing consultation, analysis and legal work.

It should be noted that this model will not make any changes to the way in which organised children’s activities services are regulated. These services would continue to operate without any independent oversight or quality assurance, and families will still be unable to use UK government childcare tax relief or benefits to pay for them.

7.5 Next Steps required to develop this model

• Undertake wider consultation across the sector and with other stakeholders to establish a clear mandate in creating a separate definition. Possibly as part of the IRISR project.
• Explore how separate definitions for ELC and SACC would impact registration and scrutiny activity including inspection of services and how ELC would be defined in legislation.
• Consider how separate definitions of ELC and SACC would impact the registration of services which deliver both wrap around care for 0-5 year olds and school aged children under one registration.
• Engage with CI to consider whether any new or amended requirements may be needed as part of the scrutiny of the new service type.
• Engage with SSSC to scope out the resource and timescales needed to support the workforce following a move to a new definition.
• Carry out further analysis to estimate the likely costs of implementing this model including timescales for the work to be undertaken.