Early learning and childcare service model for 2020: consultation analysis

Chapter 7 The National Standard as a whole

After outlining the nine proposed criteria of the National Standard, the consultation document asked respondents a range of questions about how they would evaluate the criteria as laid out in the National Standard as a whole, including:

• Whether it ensures that high quality, accessible, flexible and affordable ELC is delivered in all funded provider settings
• Whether it supports increased choice for parents and carers
• Whether there are any criteria not included in the National Standard that would be required to ensure a high-quality service is provided to all children
• Whether it seems fair and proportionate for all
• Whether it seems fair and proportionate for childminders.

Each of these questions will now be discussed in turn.

7.1 Quality, accessibility, flexibility and affordability

Written respondents were asked whether the criteria in the National Standard would ensure consistency across funded provider settings in relation to the quality, accessibility, flexibility and affordability of ELC. Most individuals were unsure whether these criteria would achieve this. Views expressed by organisations were more evenly split between yes, no and not knowing. This pattern didn't differ significantly between organisational types.

Figure 8 – The extent to which respondents agreed that the criteria set out in the National Standard ensure that high quality, accessible, flexible and affordable Early Learning and Childcare is delivered in all funded provider settings
Respondents most often indicated that they did not know whether the National Standard ensures high quality, accessibility, flexibility and affordability

In the open-text comments many respondents indicated that they ticked "Don't know" as an answer to this question as they felt that:

• The still to be determined funding rate is the ultimate deciding factor whether the National Standard ensures high quality, accessibility, flexibility and affordability. It was suggested that the National Standard must be supplemented by a sustainable funding rate, especially for private and third sector providers.
• There needs to be, overall, more information about each of the criteria in order to know whether the National Standard will ensure that high quality, accessible, flexible and affordable ELC services are delivered across all funded provider settings.

Some respondents, however, welcomed the criteria as currently outlined in the National Standard. They felt that, if implemented consistently, they will ensure quality, accessibility, flexibility and affordability across providers.

7.2 Choice for parents

Written respondents were asked whether the criteria will increase choice for parents and carers. Just under half of respondents said that they didn't know. Of the remaining respondents who answered, most said yes. Around 15% of all respondents said no, and only 10% of individuals (some of whom are likely to be parents) answered no.

Figure 9 – The extent to which respondents felt that the draft National Standard supports increased choice for parents
More than twice as many respondents said that the National Standard increases choice for parents than respondents that said that it does not increase parent choice

In the open-text comment to this question, respondents raised the following points:

• It was noted that the provider-neutral and "Funding Follows the Child" approach underlying the National Standard ensures that there is an increased choice for parents.
• Respondents highlighted the need for parents to be informed about the different providers in their local area. Respondents noted that there needs to be an equal promotion of all funded ELC providers by local authorities in order for the choice available to parents to increase.
• Respondents suggested that parents and carers should have flexibility in how they want to make use of the hours of ELC services they are entitled to. This included flexibility in terms of:
  • The numbers of funded hours per day and the blocks of hours they can access (i.e. morning, afternoon, full-time)
  • How to split the hours between different provider types (e.g. blended models)
  • Funded providers being responsive to parents' changing needs and requests for particular hours on certain days.
• It was noted that there should be clear guidelines around flexibility, particular with regards to the number of split placements parents could make use of.
• It was highlighted that parent choice is also subject to demand and supply for different ELC providers in a particular area, e.g. there may be a lack of choice particularly in rural areas. It was suggested that parents' expectations with regards to choice should be managed considering that some providers currently have long waiting lists.
• There was also a concern among respondents that the National Standard and the still to be determined funding rate may lead to some providers pulling out of the market and that this could eventually decrease the choice for parents.

7.3 Criteria not included

Written respondents were asked whether there were any criteria that have been left out. Nearly half of all respondents said that they thought that some criteria had been left out.

Figure 10 – Criteria not included in the National Standard
Nearly half of respondents said that there are criteria not included in the National Standard

In their open-text comments, respondents raised a range of issues that they felt were not sufficiently addressed in the consultation document. Most of the issues were, however, not about missing criteria of the National Standard which providers would need to fulfil, but more operational in nature.

• It was suggested that all funded providers (including local authority providers) should have effective audit structures in place, giving local authorities and the Care Inspectorate the opportunity for regular monitoring.
• Some respondents proposed that there should be an opportunity for providers to appeal against decisions made by local authorities, both decisions with regards to the locally set funding rate for different providers and the decision whether a provider receives a funded status.
• Respondents requested further information on:
  • Blended models of ELC
  • Whether and/or how parents and carers are entitled to funded provision across local authority boundaries, e.g. whether their child can access a funded provider in a local authority different to the one in which they are a resident or whether children can access funded providers in different local authorities in case of a blended model
  • From what exact day children become eligible for funding, e.g. day of their second/third birthday or the day after
• The importance for funded ELC providers to regularly engage with parents and carers was seen as not sufficiently discussed in the consultation document. This included providing parents with information about the benefit of ELC and the range of ELC providers in their areas. Respondents cited evidence that involving parents and carers in their children's learning and education improves children's outcomes.

7.4 Fair and proportionate for all

Written respondents were asked whether they felt that the proposed criteria were proportionate and fair for all. Most respondents said yes, with 25% saying no. Individual written respondents were more likely to say yes than organisations. Of the organisations that answered this question, representative bodies were less likely to say that the criteria seemed fair and proportionate than providers from all sectors and Local Government.

Figure 11 – The extent to which respondents agreed that the criteria within the National Standard seems fair and proportionate for all
Most respondents said that the criteria outlined in the National Standard seem fair and proportionate for all

In the open-text comment, respondents raised the following points:

• The criteria have the potential to be fair and proportionate for all if:
  • they are consistently implemented across local authorities
  • there is a fair funding rate for different providers.
• While not specifically about the criteria of the National Standard, it was suggested that partner providers are at a disadvantage compared to local authority providers with regards to the following:
  • Partner providers have no access to free infrastructure or local authority management and support structures, leading partner providers to have higher costs than local authority providers.
  • Considering that local authorities have, on average, paid their staff higher wage, respondents recalled partner providers experiencing recruitment and staff retention issues and losing staff to local authority settings. Respondents hoped that the introduction of a sustainable funding rate for private and third sector providers would counteract this trend.

7.5 Fair and proportionate for childminders

Written respondents were also asked whether they thought that the criteria seemed proportionate and fair for childminders. More respondents were unsure that the criteria seemed fair and proportionate for childminders specifically. Of those that did know, a smaller proportion thought that they were fair and proportionate for childminders than they did for the question relating to everyone generally. In particular, individual written respondents, of whom some will be childminders, felt least likely that the criteria were fair and proportionate for childminders.

Figure 12 – The extent to which respondents thought that the criteria seem fair and proportionate for childminders
Only about 30% of individuals agreed that the proposed criteria seem fair and proportionate for childminders

In the open-text comments regarding this, the views of respondents were divided, however there was no notable difference in views by respondent type:

• A few felt that the proposed criteria, specifically the variations related to qualifications, seemed fair and proportionate and should increase the status of childminders in the ELC sector. However, respondents raised concerns over the limited capacity of childminders in comparison to other provider types. It was therefore argued that this needed to be acknowledged by local authorities who should offer additional support and flexibility, for example, when it came to completing paperwork. An organisation representing childminders argued that there was work to be done in improving local authorities' understanding of childminding as a service and the need for variations to guarantee that the implementation of the proposed criteria was fair and proportionate.
• A few others felt that the proposed variations for childminders favoured childminders over other provider types and that, in order to be provider neutral, all funded providers should meet the same requirements.
• It was also raised that childminders generally cared for a smaller number of children than other provider types and that some requirements, for example paying the living wage and provision of meals would not be sustainable for their businesses. There was concern that this would either discourage, or lead to the closure of, child minding services which could be particularly detrimental to childcare provision in rural areas.