This is the second in a series of short articles to break down, analyse and question the implications of the Draft Strategic Plan for Early Learning 2019-29. In this article we’re looking at Goal 1: Quality is raised for children by improving regulated standards.
Five Key Points from Goal 1:
- Changes to adult:child ratios proposed;
- Significant move towards 100% qualified teachers;
- The role of educators disappears, qualified teachers only;
- Group sizes to be limited, minimum indoor and outdoor activity spaces to increase;
- Low quality ECE operators will be prevented from opening new centres.
This section is all about new regulations that set minimum standards for ECE services. The ideology underpinning this is that regulated standards create conditions for high quality education and care to take place.
1.1 Regulate new adult:child ratios for infants and toddlers
“It’s proposed to increase the ratios of teachers to children to 1:4 for under 2 years olds and 1:5 for 2 year olds.”
Age Under 2 2 3 and over
Current Ratios 1:5 1:10 1:10
Proposed Ratios 1:4 1:5 1:10
It’s widely accepted that better adult to child ratios in ECE services are the strongest predictor of positive education and care provision in teacher-led centres. So this proposed increase in ratios is a fundamentally sound concept and hard to fault from a quality outcomes perspective. The key is going to be the staged implementation of this initiative.
Here’s what’s proposed:
- Start by funding incentives for services to adopt the 1:4 ratio for under two’s (short term);
- Then regulate for the 1:4 ratio for under two’s (medium term);
- Then fund incentives for services to adopt the 1:5 ratio for two year olds (long term);
- Then regulate for 1:5 ratio for two year olds (longer than long term).
The proposed staging above makes sense, but it’s important to put fixed dates around these timeframes to give services time to plan for the staffing and associated changes.
These changes will have financial impacts beyond teacher and ancillary staff salaries, which appear not to have been considered. For example, most Education and Care, Kindergarten and Nga Kohunga Reo centres will have required a resource consent to establish. Most of these consents will have been issued for a specific number of children and staff – eg: 50 children and 8 staff. The proposed changes to the adult:child ratios will require additional teachers. Where these additional staff exceed the number specified in the resource consent, the consent is no longer valid. The resource consent cannot specify a lower number of staff than the centre is licensed for.
Therefore, the resource consent would need to be changed through either a change to conditions of consent (s127 of the RMA 1991) or through a new resource consent application. There is no guarantee that the change of conditions or new consent application would be approved by the Council.
In a worst case scenario, this could result in centres not being able to retain their existing license size and may be required to reduce the number of children they provide for. Even in a best case scenario, most centres will require a change to their resource consent. The cost implications of preparing, submitting and Council assessing such consent application are significant – in the tens of thousands of dollars.
These implications clearly haven’t been considered. Key questions will be; who pays for consent costs and, if licences must be reduced due to Council refusing additional staff, how will centres survive the financial implications of a reduced roll?
1.2 Require early learning services to support secure and consistent relationships for children
This initiative is positive but more information on how this is to occur and how it is to be measured is required.
1.3 Incentivise for 100% and regulate for 80% qualified teachers in teacher-led centres, leading to regulation for 100%
Of all initiatives in the Strategic Plan, this one is the most emotive for centre owners, educators and teachers alike.
“It is proposed to increase the percentage of required staff who are qualified in teacher-led centre-based services from 50% to 80% by 2022 before moving to 100%.”
The implications of this are clear, we will need more qualified teachers. Right now we’re in the midst of a huge teacher shortage so the question is; where do these teachers come from? Government will have to make a huge investment into training more teachers and will have to ensure that centres are adequately funded to provide for these additional qualified teachers.
This initiative will impact existing centres and educators and may lead to great people leaving the sector. For example, an educator with 15 year’s experience in the centre, with a passion for working with children but no formal ECE qualification, would need to be replaced when the 100% regulation was imposed. I’m a firm believer that a passionate experienced educator without formal qualifications would be better than a new graduate with an ECE qualification – quality beats qualification every time. Surely there is room for both, a minimum of 80% qualified and any balance covered by quality educators. As long as the service is meeting or exceeding all quality indicators during the proposed increased monitoring under Goal 1.7, the composition of the team should be left to the centre manager/owner.
The wording of this initiative is also interesting, specifically identifying only “teacher-led centre-based services” as requiring an increase of qualified staff to 80% before moving to 100%. I assume this means that home-based and playcentre services will not have to adhere to this regulation. Would such an approach raise quality across the board or would it lead to greater inequalities between service types?
1.4 Develop advice on group size, the design of physical environments and environmental factors
This initiative proposes to develop new standards for group sizes and the physical centre environment. This would include minimum space per child, heating and noise regulations and regulation design principles.
Advice on these matters would be developed in 2019 and then any changes to regulations would be made. It’s noted that the financial implications of such changes would need to be considered.
So what are the most likely significant changes to regulations?
In my opinion, it’s likely that group sizes will be limited to no more than 20 children per classroom. This is a logical and reasonable size, given that 20 is easily divisible by the proposed adult:child ratios – 1:4; 1:5; and 1:10. A classroom with over 20 children would be less efficient to manage on proposed adult:child ratios, therefore it’s prudent for any new ECE centres currently under design to factor this into final classroom dimensions.
It’s also likely that the indoor activity space minimums prescribed in Schedule 4 of the Education (Early Childhood Services) Regulations 2008 will be increased. I believe that it will end up being 3m2 per child indoors and 6m2 per child outdoors which is a good balance between increasing the quality of physical environments and allowing existing centres to retain a similar licence size.
If the above changes are recommended, adopted and regulated, a significant number of existing centres will be impacted. Whilst many of the new centres I have been involved with have self-selected to build to the above standards, many other existing centres have not. Changes to regulations would mean that such centres would be non-compliant and would have to reduce licence size to meet these standards. For centres already struggling financially, this could be the difference between financial viability or otherwise.
I believe proposed changes to group size and the physical environment (if in-line with the scale of changes I outline above) will ultimately result in higher quality environments for children. The question for government must be how these changes can be implemented in a staged manner and how to ensure that ECE supply isn’t significantly impacted should a large number of centres have to reduce their child capacity due to such changes.
It will be critical for government to include those involved in ECE centre development in any discussions relating to new regulations. Whilst input from academics is valuable, meaningful consultation with those experienced in the commercial, consenting and development side of ECE assets will be critical to avoid unattended consequences of new regulations and financial impacts that could significantly adversely affect a huge number of centres (private and community-based).
1.5 Gazette Te Whariki to support shared expectations
This is a simple one, to gazette the curriculum – Te Whariki. I can’t see any direct negative impacts on centre owners, managers or asset owners arising from this initiative.
1.6 Prevent low quality service providers from opening additional services
To prevent providers with a poor history of performance opening new centre, it is proposed to require an authorisation to expand for any subsequent new service. This initiative makes sense, however the implementation and monitoring of an authorisation process will be complex. Often one owner will own multiple centres under different company names and ensuring no rogue operators slip through the cracks will be challenging for the MoE.
It’s also proposed to limit the amount of probationary licences a service provider could have at any one time to prevent faster expansion than their systems could cope with. It will be interesting to see what this number ends up being. I personally know a few ECE organisations going through significant growth but maintaining excellence in quality, staff retention and business systems. It would be counterintuitive to punish quality service providers like this and a one-size-fits all rule would likely result in such outcomes.
1.7 Increase monitoring of services
If there was one initiative that would be universally popular with quality ECE services it’s this one. For too long services that have been performing poorly have been given chance after chance to change. This new initiative would increase monitoring of services and would introduce a programme of surprise visits by the MoE. Serious concerns about one centre could trigger an automatic review of all of a service providers other licences to check for systemic failures.
Revoking the licence of poor performing centres, where children are at risk, is the most effective way to signal a commitment to raising quality across the board. This initiative is long overdue.
Final Thoughts on Goal 1
The underpinning philosophy in this goal is that regulations provide a framework to ensure quality outcomes are delivered for all children
Each one of the initiatives are sound in concept. However, those that deal with new regulations relating to adult:child ratios, activity space minimums and group size require very careful consideration in terms of timing and implementation. Perhaps it would be wise to require new centres to meet these standards immediately and gradually bring existing quality services up to the new standards over a longer period of time.
The proposal for 100% qualified teachers is, in my opinion, an expression of ideology more than anything else. If a centre can show that it meets all quality standards with at least 80% qualified staff then surely this is appropriate. We simply don’t have enough qualified teachers nor a strategy to get significantly more people into the profession. Until we do, a goal of 100% qualified teachers in the context of this Strategic Plan is just virtue signalling.
I invite you all to share your thoughts, it’s critical that we all have our say – no matter if we agree or not. Most importantly, make sure to share your thoughts formally during the consultation period.