By CELA on 6 May, 2021

The National Quality Framework is a foundation document for our early childhood education and care system. The review of the NQF provides an opportunity to articulate a new quality threshold around our vision for the sector over the next ten years.

CELA’s submission to the National Quality Framework Consultation Regulation Impact Statement addresses a range of issues, including improving the assessment and rating process, safety, and workforce.

By Megan O’Connell, CELA Research and Policy Manager

Our submission draws on your feedback. It is focused on supporting all services to provide quality early childhood education and care to children, and minimising the risk of harm to children. We acknowledge that some of the proposed changes will have cost and resource implications. We will continue to provide you with training and resources and advocate for additional government investment to meet any additional regulatory burdens.

Below are some of the key issues we raise in our submission.

Improving the assessment and rating process

We believe the NQF review provides the opportunity to ensure services are supported to engage in continual quality improvement.
Quality improvement cannot occur in a vacuum – it requires time and resources.
Many members cited the need for improvements to make quality standards simpler and clearer and less open to interpretation.

 “The framework is open to interpretation, and two different assessors can give different ratings”.
CELA NQF CRIS survey respondent


Currently there are no penalties for services who receive a Working Towards rating and fail to make improvements over multiple rating periods. Services who are not meeting standards must be obliged to make improvements over a medium timeframe. A continual quality improvement system must encourage and reward improvement, and have repercussions for services who are continually performing below an optimal standard.

The assessment and rating system needs to provide accurate, up to date ratings in order to support parents to choose quality services. The pace of assessments, up to every five years, is too slow. A significant proportion of services drop down in ratings, or improve, within this period. The system needs to provide reliable assessments within a reasonable period of time (for example every three years) by highly skilled and consistent assessors who observe services over a reasonable period of time.

Safety, health and wellbeing

CELA would welcome the introduction of regulations, supported by guidance, to ensure services develop policies and procedures that minimise the risk of children going missing. This may include requirements for parents to notify services of absences, and clear communication protocols to be put in place between services and schools, including procedures to follow when children do not arrive in a given time period.

CELA notes the serious risk to children, both during and after transportation, and believes a range of measures should be implemented. This includes implementing ratios, the potential of imposing a requirement that a bus has two staff on board, and that the driver or other staff member are trained in areas including anaphylaxis and first aid. We recognise that buses are crucial to supporting children in regional and rural areas to attend early childhood education and care, and that additional government funding will be required to ensure services can meet any new requirements.

Based on your feedback we are advocating that additional attention needs to be paid to sleep and rest requirements, including training for staff who supervise sleeping babies and toddlers. Guidance and requirements for policies and procedures need to have an explicit focus on how and when staff are expected to check on sleeping and resting children, including any use of CCTV. Specifying an educator must continuously supervise sleeping children is problematic in some instances:

“This would require an additional educator in our infants’ rooms to ensure that the infant/children who have more than one sleep per day is monitored during this sleep time. This will take the educator off the floor and therefore the room will be out of ratio.” CELA NQF CRIS survey respondent

CELA notes the risks associated with evacuating children (in particular non-ambulatory children) are significant and the expertise around evacuating a multi-storey building is likely to be found outside of a service. Given this, we would support the mandating of expert oversight in evacuation drills and changes to building and service approvals to ensure the risks to children of multi-storey buildings are considered.


There is abundant research that well trained staff are vital to improving children’s outcomes. A key aim of the NQF is to improve the educational and developmental outcomes for children attending education and care services. Given this, current ratios must be maintained or improved to ensure children’s safety is protected, and that out of school hours care services have qualified staff.

Members’ feedback indicates that workforce issues are pressing but this is not a reason to compromise on quality. Our submission contends that the forthcoming Workforce Strategy must address urgent workforce issues, with attention paid to attraction, development and retention of staff including the centrality of pay and conditions.

Feedback from members reflects concern about program quality dropping If short term relief is extended:

“For a short time, less than 60 days is acceptable. However, long absences will result in the declining quality of the program as well as the cohesiveness of the team in the room. It is also giving too much responsibility that is not equal to their pay rate.”
CELA NQF CRIS survey respondent

You also raised concerns that employers would take advantage of this clause to save money on wages and not pay staff acting at a higher level the full wage.

Further guidance to support services to ensure staff are actively working towards their qualification is essential to support the completion of qualifications. Setting a time limit may prove difficult, given the challenge of balancing part time study with other commitments. However, it should be mandated that staff must be actively working towards their qualifications to be counted towards ratios, and guidance provided on how actively working towards is assessed.

“We already check that staff are actively studying, but there should be a time limit that they can be classed as working towards. It would be interesting to find out how long some people are taking to do their course, and how long they are being used as working towards to meet required ratios, and what type of centres are using working towards qualifications to meet their requirements.”
CELA NQF CRIS survey respondent

Consideration should be given to setting a ratio, to be increased over time, of qualified staff to staff in training.

What happens next?

Governments will consider contributions to the CRIS and develop recommendations as a Decision Regulatory Impact Statement for agreement at the COAG Education Council – a meeting of state, territory and Australian government education ministers. Endorsed options will then be implemented, including through changes to national law and regulation in 2022 and 2023.

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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