25 August 2017
ACCS has provided advice to the Australian Competition and Consumer Commission on the potential establishment of a very large private provider in the Outside School Hours Services sector. We have drawn on the knowledge of our members and our observations about the dangerous impact of large corporations operating in the long day care sector.
ACCS encourages the Labor Party to think big. We ask that Labor considers a national policy framework that works towards the well-being of all Australia’s children that includes ECEC.
ACCS is particularly pleased with the eligibility criteria requiring not-for-profit status for the recipient agencies. However, we believe that the goals of the Community Child Care Fund would be better served if the Guidelines recognised that some services will not be able to transition to a model of operation that is self-sustaining. Entrenched poverty, long-term unemployment and disadvantage make sustainability without additional government funding impossible in many communities.
ACCS calls on the Senate to reject the Omnibus Bill to protect the interests of the tens of thousands of families and children using community owned and not-for-profit children’s services.
ACCS rejects a proposal from the Commonwealth Education Department to set up a Preferred Provider Scheme as a strategy to improve the quality of training in the Early Childhood Education and Care sector.
We believe that resources are more effectively directed to strengthening the capacity of the regulator ASQA to regulate RTOs.
Our submission sets out ten actions that government and the regulator can take to put poor quality RTOs out of action
ACCS has called on the Senate to vote against the Jobs for Families Child Care Package Bill in its current form.
ACCS recommends to the Senate Education and Employment Legislation Committee to apply the first principle of children’s best interests to its review of the Bill.
ACCS is concerned that increased focus on support for parents working or studying will shift the focus of Australian Government policy away from the best interests of the child and the principle of universal access.
Children’s best interests must be the first principle and underpinning rationale for all deliberations, recommendations to the Australian Government and government policies.
To see more qualified staff in the education and care sector to support the provision of quality education and care that all children and families deserve… cannot be achieved without authentic and ongoing sector engagement.
ACCS has serious concerns about some proposals that are contained in the RIS but also welcomes several proposals.
ACCS welcomes the recommendations for a single subsidy to replace CCB & CCR, increased investment in subsidies for low income families and ongoing funding for universal access to 15 hours of preschool.
ACCS strongly supports the full implementation of the NQF to 2020.
Any decisions regarding children’s services should be made with children’s interests as the first principle.
ACCS welcomes the aspirational nature of the draft criteria.
A key issue that has been challenging the ECEC sector is the low status of the workforce.
ACCS is excited about this timely review by the Productivity Commission. There are significant changes occurring in the early childhood sector through the Council of Australia Governments (COAG) process and the early childhood reforms it is implementing. These changes will impact on the quality assurance frameworks applied to children’s services, the regulations that underpin this frameworks and the early childhood sector workforce that will be implementing these changes…
ACCS wishes to emphasise a key underlying issue facing the early childhood education and care sector – our preferred term for the sector – and that is low status. The low standing of the early childhood education and care workforce impacts on the sector’s ability to recruit and retain staff…
It is crucial that the Regulations are clear and understandable, limiting personal interpretation, misunderstanding and ambiguity.
The Bill provides the opportunity to entrench the intent of key principles of the United Nations Convention on the Rights of the Child (UNCROC) into a separate statutory office which values children as citizens and holders of rights.
ACCS welcomes the Bill’s intent for the Commissioner to coordinate policies, programs and funding across Australia which impact on children and young people (Bill 2010 3.3.c; p3). Such an approach is long overdue and will overarch the current fragmented approach to policy as it relates to children, young people and the families and communities that surround them.
ACCS has always argued that the CCR is a flawed mechanism and calls on the Government to abandon the rebate and roll the funds into increasing CCB fee subsidies for low and middle income families. High income families on $100,000 a year or more receive double the rebate of families on low incomes of under $30,000. Child Care Benefit is a progressive system of support
for families, offering the highest assistance where it is most needed. The rebate undoes all of the good work of CCB…
ACCS supports the amendment which will modify the terminology in the Trades Practises Act 1974 to prevent corporations from directly or indirectly merging or acquiring an asset which would result in ‘material’ lessening of competition in the relevant market.
All formal children’s services should be regulated through the Federal Government thus removing duplication of current state/territory licensing requirements and Federal Government quality assurance.
ACCS believes that government must use both regulatory and public policy levers to ensure that what remains of ABC Learning does not grow again and that no future child care operator can grow to be such a monolith in the children’s services sector. The
government must maintain control in children’s services as the market does not deliver consumer power for families…
There are significant areas of duplication between state/territory licensing and the quality assurance process.
FOR FULL SUBMISSION SEE HEREThe collapse of ABC Learning may have a positive impact – the stability of the not-for-profit sector is not reduced by the collapse of ABC. The not-for-profit sector has the best track record for being committed for the long haul and for being responsive to community needs.