Consultation Response Form
Consultation closing date: 25 March 2013
Your comments must reach us by that date.

Consultation on Early Education andChildcare Staff Deployment

Consultation Response Form

THIS FORM IS NOT INTERACTIVE. If you wish to respond electronically please use the online response facility available on the Department for Education e-consultation website ().

Information provided in response to this consultation, including personal information, may be subject to publication or disclosure in accordance with the access to information regimes, primarily the Freedom of Information Act 2000 and the Data Protection Act 1998.

If you want all, or any part, of your response to be treated as confidential, please explain why you consider it to be confidential.

If a request for disclosure of the information you have provided is received, your explanation about why you consider it to be confidential will be taken into account, but no assurance can be given that confidentiality can be maintained. An automatic confidentiality disclaimer generated by your IT system will not, of itself, be regarded as binding on the Department.

The Department will process your personal data (name and address and any other identifying material) in accordance with the Data Protection Act 1998, and in the majority of circumstances, this will mean that your personal data will not be disclosed to third parties.

Please tick if you want us to keep your response confidential. /
Reason for confidentiality:
Name / Jane Evans,
Vicki Lant, and Jonathan Rallings
Organisation (if applicable) / Barnardo’s
Address: / Tanners Lane,
Barkingside,
Essex,
IG6 1QG

If you have a query relating to the consultation process you can contact the CYPFD Teamby telephone: 0370 000 2288 or via the Department's 'Contact Us'page.

Please tick one category that best describes you as a respondent

/ Parent/Carer / / Childminder / / Nursery
/ Playgroup / / Play/Activity provider / / Representative of childcare or early years intermediary organisation
/ SEN Provider / / Maintained School / / IndependentSchool
/ Breakfast/Afterschool Club / / Local Authority / x / Other please specify below
/ Please Specify:
Barnardo’s is the second largest non municipal provider of sure start children’s centres, running 132 across England. This expertise, together with our position as the largest UK based children’s charity working with vulnerable and disadvantaged children and their families, enables us to speak with authority about the needs of very young children and their families especially those from disadvantaged homes.

INTRODUCTION

When answering the following questions please refer to the consultation document herewhich sets out the detail of our proposals.

Questions 1 and 2 are for childcare providers/employers/employees to answer, and question 3 onwards are for all respondents to answer.

FOR PROVIDERS/EMPLOYERS/EMPLOYEES

We need more, better qualified staff working in childcare to ensure our children get the best possible care. We recognise, however, that recruiting and retaining well qualified staff is not always easy or possible.

1a) What challenges, if any, do you face in recruiting and retaining highly qualified staff?

/ Comments:
Pay rates in this sector are low, leading to a tension between recruiting the best qualified staff whilst maintaining a viable business model. In addition the cost to early years practitioners of upgrading their own skills and qualifications can be high. There is a need to readily access Skills Funding Agency monies in order to support people improving their qualifications at levels 2 and 3 with targeted leadership resources at the higher levels. Not all senior staff in early years settings are qualified to take on an assessor role.

1b) What suggestions do you have for how this could be made easier?

/ Comments:
Staff need time and flexibility to study. They need to feel rewarded by the work itself and knowing they can make a difference.
Access to available training resources (Skills Funding Agency or Adult Loans) should be clearly signposted in a designated area on the DfE web site. This site could also be used to inspire a culture of self-improvement.
Staff need support, including financial support, to take up skills training and higher qualification. The vast majority of salaries paid to childcare workers arenot sufficient to sustain funding for courses by the individual.

Evidence suggests that the number of staff needed in nurseries forces providers to pay low wages for less well qualified staff in order to keep costs to parents down, rather than recruit more experienced and highly-paid staff.

2 Is this a decision you have faced with your business and what could the Government do to address this?

/ Comments: While quality is the paramount issue in early years child care, caution needs to be applied if allowing a relaxation in the ratios in early years’ settings. Evidence shows that disadvantaged children benefit from settings where they can have one-to-one interactionswith well-qualified staff.
There are potential health and safety issues in small groups, as a relaxed ratio does not allow for cover in an emergency – for example an accompanied hospital visit.
Contingency should be allowed for emergencies.
Where price is an issue, such as in deprived areas, there is a risk of running a two tier system, where those that can pay will opt for more staff to infants, but those that cannot afford this will make do with fewer. This has the potential for increasing the gap in cognitive development which emerges at 22 months of age.

FOR ALL

In nursery classes for 3- and 4-year-olds where a qualified graduate is working with the children, it is already possible to run groups on the basis of one adult to thirteen children. Yet too few providers, especially in the private and voluntary sector, take advantage of this flexibility, despite the evidence about the benefits that this graduate leadership can have for children.

3 How might providers be encouraged to make greater use of graduate-led groups for children aged three and over?

/ Comments:
Barnardo’s welcomes the drive for high quality early years and childcare provision,especially for vulnerable and disadvantaged children. We agree that the training of staff is the most crucial factor in ensuring quality of provision and that in certain situations – for example out-of-school provision on a school site where other adults are likely to be on the premises in an emergency – that making ratios more flexible may be helpful.
However we are less certain of the relationship between quality and ratios for the youngest most vulnerable children who benefit most from individual attention which they may not be receiving in a chaotic home life. Last year Barnardo’s published its report Mind The Gap (Evans, Mathers, Rallings; Barnardo’s, 2012) which suggested the Government might consider ‘stretching’ the Pupil Premium entitlement to cover three and four year olds. Such a move would have a minimal impact on schools’ funding, but allow a wealth of possibilities for settings to support the intentions of More Great Childcare. For example conditions could be attached that where a pre-school child receives pupil premium the money could be used to fund smaller groups to provide a programme of early intervention for the most vulnerable children, whilst allowing settings to broaden the groups for the education of other, more advantaged children. We would urge the Government to explore how this idea might interact with other proposals.
Unfortunately we are not convinced,though, that the relaxation of ratios will lead to higher pay for staff or reduced costs for parents, given many providers are already operating at very tight margins. Graduates in the early years also receive substantially less pay than graduates in other fields and have fewer opportunities for progression. The proposed Early Years Professional qualification must attract Qualified Teacher Status to allow professional progression in line with the nature of the qualification. Unless these issues are addressed it will continue to remain difficult to attract the best graduates into early years work.

Alongside our plans to improve qualifications for people working in childcare, the Government proposes that, where staff are suitably qualified, they can look after:

  • no more than four children aged under two to each adult; and
  • no more than six two-year old children to each adult.

4 What qualifications do you think staff should have to allow them to operate with these more flexible arrangements?For instance, we could require settings to meet one of the following criteria in order to be able to operate higher ratios:

  • 70 per cent of staff qualified to at least Level 3;
  • 100 per cent of staff qualified to at least Level 3;
  • 100 per cent of staff have at least a C in English and Maths;
  • At least one graduate in the setting plus 70 per cent of other staff qualified to at least Level 3; or
  • Ratios based on the individuals working with children - so that only a staff member with a Level 3 qualification and/or English and Maths GCSE can use the higher ratio

Please note these examples are not exhaustive and we would welcome other suggestions.

/ Comments:
Barnardo’s believes that ratios should not be tied to individual staff, but allow some room for flexibility of staffing. Whilst we recognise the need that every childcare practitioner should be working towards achieving a qualification, we would like to see room for including volunteers and trainees. ‘On the job’ training is currently a valuable route for many people into the profession - often those who may have not achieved the requisite qualifications at school, but who have proved adept at childcare through experience of bringing up their own children and wish to enter work in the field. In-job training is also an accessible way for staff to upgrade their qualifications.
For this reason we would prefer the ratios to be based on at least one graduate in the setting plus 70 per cent of other staff qualified to at least level 3 – allowing 30 percent for those who have not achieved the highest academic standards in the past, but who are suited to the work, to develop skills, qualifications and progression opportunities.

We are proposing that, while not exceeding more than 6 children in total, childminders should have more flexibility to care for up to four children under the age of five, including no more than two children under 12 months.

5 What difference do you think this will make to the childminding profession and what benefits do you think parents will get?

/ Comments:
Barnardo’s does not have direct experience of childminding yet so we are not best placed to answer this question. We would draw attention to our concerns raised in Q.3 that the needs of the most vulnerable children are met and that pupil premium might be used to reach childminders offering the EYFS.
We are about to embark on a new pilot funded by the department to recruit and train childminders through our portfolio with Children’s Centres. We hope to be able to feedback more on this issue as this project progresses.

6 Are there any other elements of our proposals that you wish to comment on specifically?

x / Yes / / No / / Not Sure
/ Comments:
Barnardo’s agrees that there needs to be clarity for settings over who they are answerable to. As the regulator, Ofsted should be the single most important arbiter of quality, not the local authority. However, any moves to downgrade the role of the council must acknowledge the crucial role that local authorities play in providing continuous quality and improvement support to early years and childcare settings outside of the inspection regime.
It is not clear where this quality assurance will come from if the funding is removed from local authorities. Barnardo’s feels that it is not sufficient to rely on inspections every four years to assure quality; quality improvement and monitoring are continuous processes and in this respect a Local Authority can provide a separate challenge to providers without setting onerous stipulations.
Additionally Local Authorities have a duty in law to secure sufficient childcare and to ensure that it is accessible to all those who might need it. The balance of provision in the local area is critical especially where there are poor public transport links, and in areas of deprivation. The Local Authority needs to retain this oversight and this will require funding.

7 Please let us have your views on responding to this consultation (e.g. the number and type of questions, was it easy to find, understand, complete etc.)

/ Comments:

Thank you for taking the time to let us have your views. We do not intend to acknowledge individual responses unless you place an 'X' in the box below.

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Here at the Department for Education we carry out our research on many different topics and consultations. As your views are valuable to us, would it be alright if we were to contact you again from time to time either for research or to send through consultation documents?


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All DfE public consultations are required to meetthe Cabinet Office Principles on Consultation

The key Consultation Principles are:

  • departments will follow a range of timescales rather than defaulting to a 12-week period, particularly where extensive engagement has occurred before
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Responses should be completed on-line or emailed to the relevant consultation email box. However, if you have any comments on how DfE consultations are conducted, please contact Carole Edge, DfE Consultation Coordinator, tel: 0370 000 2288 / email:

Thank you for taking time to respond to this consultation.

Completed questionnaires and other responses should be sent to the address shown below by 25 March 2013

Send by post to: CSDSD Team, Department for Education, Area 1C, Castle View House, East Lane, Runcorn, Cheshire, WA7 2GJ.

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