What is the CRIS document?
Many of you would be aware that in 2019 a review of the NQF took place. In Jan of this year the Consultation Regulation Impact Statement (CRIS) was released. The purpose of this document is to propose changes to the National Law, National Regs, and other guiding materials which all form part of the NQF. ⠀
We have been spending some time going through this document and have already shared some information regarding transitions between school & OSHC, and OSHC & school.⠀
This is a great opportunity to be aware of the proposed changes and also to have a voice when it comes to OSHC services and advocating for quality practice!
This blog post will be focused on another area of the CRIS report, assessment & rating in OSHC!
Assessment & Rating in OSHC
Chapter 6 of the Consultation Regulation Impact Statement (CRIS) delves into how the NQF can be reviewed to support the OSHC sector and its differing needs to the Early Years sector.
An area that has been of concern for the OSHC sector is the Assessment & Rating process and that they are being assessed on the same criteria despite the children in care being at a completely different stage developmentally.
Key concerns:
During the 2019 NQF Review, key OSHC stakeholders advocated for OSHC Services to stay apart of the NQF process but believed the NQF could be better modified to better fit the OSHC context.
Assessment and rating acts as an essential tool to monitor overall compliance and drive continuous quality improvement of education and care services, however, there may be options to streamline assessment and rating against the NQS for OSHC services, and/or making the process more targeted to the specific service type. This is because some elements of the NQS may be less applicable in a school age education and care context, notably around:
– assessment and planning requirements may not be proportionate to the hours of attendance for children, nor reflective of the play and leisure aspect of service provision.
Consultation Regulation Impact Statement (CRIS), page 85
Options for change:
A. No change
B. Modify assessment and rating methodology for services whose main purpose is providing education and care to children over preschool age.
C. Development of additional guidance to support the OSHC sector and regulatory authorities with assessment and rating.
Option B
A streamlined version of assessment and rating would be designed for OSHC services that will continue to ensure compliance with the NQF and the provision of quality education and care while also giving consideration to their alternative learning framework, significantly varying enrolment patterns, and often shorter hours of care compared to other centre-based services.
Consultation Regulation Impact Statement (CRIS), page 86
The document however does give the example of exempting OSHC Services from Standard 1.3 as part of the Assessment & Rating process.
Nationally OSHC Services are more likely to be rated as ‘meeting’ Standard 1.3, with the NQA ITS (September 2020) outlining that 75.6% of Services will achieve this rating. Whilst only 7.1% of Services will receive an ‘exceeding’ rating as opposed to Long Day Care at 21.3% and Pre-schools/Kindergartens at 48.9%.
It is outlined that during A&R, OSHC Services were less likely to meet the requirements of Standard 1.3 when compared to other centre-based education & care services. But in saying this the stats are as follows:
The positives of removing Standard 1.3 from the A&R requirements for OSHC are outlined in the document as:
This would likely increase services’ capacity to focus on the core educational program and practice needs of children attending this service type, including developmental outcomes, nutrition, relaxation and socialisation, while streamlining assessment and planning requirements. It would also decrease the administrative burden associated with preparing documents relevant to Elements 1.3.1 and 1.3.2 for submission to the relevant regulatory authority
Consultation Regulation Impact Statement (CRIS), page 86
However, it is a concern that by removing Standard 1.3 from the A&R process for OSHC, there would be no requirement for an OSHC Service to demonstrate critical reflection to receive a rating of ‘meeting’. It would only be essential for services looking to receive an ‘exceeding’ rating by fulfilling the requirements of the exceeding themes.
If we are to be seen as OSHC professionals and not what many still consider us as ‘babysitters’, should we be reflecting on our professional practice? Should this be a requirement of our work to be critically reflecting?
Option C
This option looks at delivering further guidance to OSHC Services in being able to meet the requirements of the NQS & A&R. This option would also look at developing guidance for Authorised Officers in assessing an OSHC Service.
Further, developing additional guidance for authorised officers and other regulatory staff conducting assessment and rating processes in OSHC services would support the overall capacity of regulatory authorities to acknowledge the distinct characteristics of OSHC services and factor in these characteristics when conducting assessment and rating.
Consultation Regulation Impact Statement (CRIS), page 87
Feedback Sought
WHAT DO YOU THINK?
We would love to hear your thoughts on the options proposed and what you think would support your service and its quality education and care of children.
It is important to note that not one option has to be implemented, a combination of proposed changes could be the best practice option.
