By CELA on 29 Mar, 2021

CELA has analysed the National Quality Framework Consultation Regulation Impact Statement (CRIS) which covers a wide range of areas for improvement on which your opinion is sought.

We are specifically seeking your feedback on three key areas, which will be covered in a series of three Amplify articles.

This week we take you through what the NQF CRIS is trying to achieve, and ask for your opinion on the topic of the workforce.

The review of the National Quality Framework is a significant milestone in the quality journey for early childhood education and care.

It has been nearly ten years since the National Quality Framework commenced in 2012 to align regulatory arrangements and provide a system of standards and ratings. Since this time most services have been rated against the quality standards, and the overall level of ratings has improved over time.

The review commenced with an issues paper in 2019 but was placed on hold due to COVID-19. A Consultation Regulation Impact Statement (CRIS) has been released, which contains a wide range of issues on which your opinion is sought by the end of April.

The CRIS covers eight key areas for improvement – highlighting problems, potential solutions and the implications of these solutions.

These areas are:

  • Safety, health and wellbeing;
  • Royal Commission into Institutional Responses to Child Sexual Abuse;
  • Family daycare;
  • Centre-based care;
  • Out of school hours care;
  • Workforce;
  • Understanding of quality ratings by families;
  • Changes in fees within the NQF system and,
  • Oversight and governance of services and providers

Why your opinion is vital

CELA has analysed the CRIS and we are seeking your feedback on three key areas related to the Workforce, The Royal Commission into Institutional Responses to Child Sexual Abuse, and Safety.

We will summarise and discuss these issues in a series of three Amplify articles over the next three weeks, and provide a survey for each area so that we can gather your input.

We will bring together our sector insights and what you have told us to shape a response to the CRIS.

Now is the time to ensure our sector is well placed to deliver on the vision contained in the NQF of continuous improvement in the provision of quality education and care, and improving outcomes for children.

We believe there is an opportunity to be more ambitious than the CRIS proposes, and to enhance the National Quality Framework to ensure that all services are supported and driven to engage in continual quality improvement and that the workforce is supported in its vital role.

Before we dive into the specific topic of the workforce, we welcome your feedback on any issues related to the NQF. Please feel free to share your overall thoughts by answering the questions in this short two-question survey which asks:

  • How can the National Quality Framework be strengthened to support quality early childhood education?
  • What changes would you like to see in a revised NQF?


Share your thoughts


Workforce issues continue to impact early childhood education and care services across the country. Workforce shortages may impact the quality of care and/or the number of places available for children.

1.Restrictions on short term relief for early childhood educators

The CRIS notes that if an ECT is absent in the short term, they can be replaced by a diploma or primary teacher qualification holder for 60 days in a 12 month period.

Potential solutions

Options proposed include whether this flexibility should be extended to cover diploma and Certificate III educators if it should be increased to 80 days, as well as whether NSW’s requirement for third and fourth  ECTs could be met by suitably qualified persons such as school teachers.

Our concerns

CELA is concerned that the response to the workforce shortage is a proposed weakening of the qualifications requirements rather than ensuring that all a workforce is built and supported to meet children’s education and care requirements. The workforce strategy under development must address this shortage.

CELA notes the existing 60-day limit is generous and means that a child undertakes most of their preschool program without a trained teacher. Further, CELA is concerned that the focus of this change appears to be on cost savings to services, and parents, at the expense of ensuring the quality of service provision. We are also concerned that enabling certificate III staff to backfill diploma staff could see a reduction in quality.

Have your say

Please consider the following questions (a survey link will be provided at the end of the article):

  • What do you think is a reasonable absence time period for short term backfill?
  • What do you think would be the impact of allowing Certificate III staff to fill a short term diploma educator absence?
  • What is your view on using suitably qualified staff to meet additional ECT ratios in NSW?

Educators who are working actively towards

In Centre based care at least 50% of educators are required to have or be working towards a diploma level qualification with other staff counted in ratios required to be at least working towards a Certificate III.

Potential solutions

Options proposed include setting a proportion of staff that must be qualified, setting time limits on how long educators can work towards and setting guidance or introducing thresholds around satisfactory progress.

Setting a minimum proportion of educators holding a qualification may support quality provision for children, whilst providing guidance to providers to ensure other staff in training make progress may support completion. It is acknowledged this may bring to the fore services who do not have fully trained staff at present and increase the level of waivers.

Our concerns

There is currently no time limit on actively working towards nor requirements on what satisfactory progress through a course is.

Have your say

Please consider the following questions which you can answer in the survey link below, along with the previous questions on restrictions on short term relief.

  • How would these proposals affect your service?
  • What proportion of staff do you believe should be fully trained at present, and should this escalate over time?
  • What guidance would assist you to ensure staff progress in their qualifications


Share your thoughts

**Please note that we are happy for you to respond to as many or as few questions as you like, there is no requirement to answer every question in the survey**

About CELA

Community Early Learning Australia is a not for profit organisation with a focus on amplifying the value of early learning for every child across Australia - representing our members and uniting our sector as a force for quality education and care.

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