Childminder response to the Govt's 'More Affordable Childcare' plan

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Department for Education
Castle View House
East Lane
Runcorn WA7 2GJ

22 July 2013

Dear Sirs,

Re. More Affordable Childcare

I downloaded a copy of ‘More Affordable Childcare’ with some trepidation, having had a significant number of misgivings about the ‘More Great Childcare’ plan - which I shared at the time in my document which analysed every point made in the plan. I had hoped that the Government, Department for Education, Ms Truss and the MPs to whom I sent my ‘Analysis of the ‘More Great Childcare’ Plan’ might have listened at least in part to childminder’s concerns about agencies and stopped their progress for further consultation with those of us who will actually be affected by them - but I knew in reality that I was, in the words of one contributor to this letter, ‘hoping for too much’.

I sent a 30+ page document to Ms Truss and other MPs regarding ‘More Great Childcare’ - The document was written on behalf of Childminding Forum members. It questioned the plans for childminder agencies in great detail and contained a series of serious concerns from those childminders whose businesses will be affected by the plans. I received a response letter in which I was advised to read ‘More Great Childcare’ for more information.

We fail to understand how the Department for Education can say, in a Freedom of Information request, that only 21 letters against agencies have been received when the introduction to this document clearly states in an opening paragraph - ‘The comments in this document have been made by thousands of colleagues locally, on the Childminding Forum (Childminding Forum - The UK's largest online forum for Registered Childminders) and other social media ... and by other professionals and parents who all believe that the Government proposals will put outcomes for the next generation of our children at risk and adversely affect the sustainability of the majority of early years providers including childminders.’

One of the contributors to this letter wonders if there has been a misunderstanding related to the document above. Clearly the Department for Education counted it as one letter from one childminder, failing to recognise the contributions of all our colleagues. She wonders if it would be beneficial if childminders who did contribute to the document were to send in their own copy to show the strength of feeling against agencies. Please advise if you feel this is a good idea.

Similarly grave concerns about childminder agencies have been raised over recent months by the Department for Education’s own ‘Task and Finish’ group - and in regular articles in the national press, Nursery World and other magazines and publications.

Similarly written evidence to the ‘Public Bill Committee’ states ‘Almost all of the comments in this section were from childminders who opposed the introduction of agencies.’ (Introduction to part 4) - and still we are not being heard!

What assurances do the Government give us that we will be listened to if we are ‘consulted’ again?

Indeed, one of the first things that jumped out at me when reading ‘More affordable childcare’ was this sentence - ‘This report proposes bringing forward legislation to introduce a new childcare registration system at the earliest opportunity, following consultation.’ It is my experience, having replied to every consultation relating to childminders and early years that I have been able to find, that childminder views are being ignored as Ms Truss and Ofsted push ahead with their plans for childminder agencies regardless of the views of those who will have to live with the consequences of the policy - children, childminders and parents.

Re. Agencies for childminders

The vast majority of Ofsted registered childminders (currently 80,000+) say that they neither want nor need agencies. I moderate a Childminding Forum (Childminding Forum - The UK's largest online forum for Registered Childminders) and an Independent Childminders Facebook group with nearly 30,000 childminder members between them and I have yet to meet any childminders who see agencies as a positive move for the children or their families or for the childminder’s own business.

Ms Truss accepted that established childminders neither want nor need agencies when she said that we would not be forced to join agencies, but she is not providing us with any information about how we might continue to operate independently. We do not know how we might continue to be successful without Local Authority support (which is currently being dismantled) - or how we might continue to earn enough money to maintain our businesses when agencies are preparing to register thousands of new childminders without being required to conduct local sufficiency audits.

We would also like to know how we might protect our businesses against the onslaught we are currently getting from Ofsted inspectors who Sir Michael Wilshaw has clearly stated do not want to continue to individually inspect us. As one contributor says, ‘we have deep concerns that our independence will affect outcomes of our future Ofsted inspections’ and nothing has been said or done by Ofsted to reassure us.’

Furthermore, as one of the contributors to this letter points out, there has been much speculation about a cost per inspection for independent childminders to continue being inspected by Ofsted. This has caused childminders much concern over recent months and Ofsted are aware of this because they have been told at various conferences and meetings. Yet, to date, nothing has been clarified.

There are 80,000+ childminders in England and many of us fee that we are being sidelined while the Government pushes ahead to set up agencies to bring thousands more into the workplace. What about those of us who are currently out there, doing the job every day, caring for the children? We feel we deserve much more recognition and respect than we are currently getting.

As a follow on question, a number of contributors are remembering back to last year when Sir Michael Wilshaw from Ofsted said childminders were too expensive to individually register. An ‘individual inspection matters’ campaign was started by NCMA (now Pacey) and some childminders contacted Ofsted to say they would be happy to contribute towards a percentage of the cost of the inspection. This solution appears to have been ignored as the Department for Education pushes ahead with plans for childminder agencies that we neither want nor need.

Re. Other aspects of ‘More Affordable Childcare’ of concern to childminders

Other aspects of the ‘More Affordable Childcare’ plan are also very worrying for established childminders, including -

Points 2.36 onwards re. Local Authority regulation - while it is a positive move that childminders will no longer have to jump through regulatory hoops to access the funded sessions, childminders are very concerned that funded places might be given to new childminders who have not yet been inspected. We presume this is because all new childminders will be registered by an agency. However, we would like it acknowledged and understood that established childminders have worked long and hard to gain their Ofsted grades which allow them to offer funded care.

We would also like the Department for Education to note that even now, with Government making the plans for funding provision clearer, we have Local Authorities saying that the guidance tells them to do things one way - but they are choosing to implement other rules. As one Local Authority told their childminders at a meeting last week, ‘The Government are telling us to do things this way, but here in our Local Authority we have the following rules’. They then went on to talk about a quality assurance programme, a safeguarding audit, accreditation paperwork and many other regulatory barriers.

If these rules raise quality then they should be applauded. If childminders are given support to complete the documentation and the process they have to go through is quick and open to everyone with a ‘good’ or ‘outstanding’ Ofsted grading equally then there are no problems. The concerns start when the funding is withheld from childminders who struggle to complete paperwork or who, in the case of one contributor to this document, have a difference of opinion with their Local Authority, despite being an ‘outstanding’ graded childminder.

As one of the contributors to this letter says, ‘The reason that we are checked and graded is to ensure that the right level of care is afforded to the child for whom the funding is being drawn. A newly registered childminder is an unknown quantity until they have been working with children and have had their first inspection. Of course, the new childminder may be a perfect recruit for the profession but it seems a risk to spend taxpayers money on someone who may not be suited to the job.’

This part of the plan is of great concern to the many parents we have spoken to about ‘More Affordable Childcare’, as well as childminders. They want their child to be looked after by high quality, responsible, trained, insured and well qualified providers but there will always be a cost element involved and they do not want to feel they have no financial alternative but to choose a cheap provider with whom their child might not be safe.

The point that ‘good’ and ‘outstanding’ childminders will have their Local Authority support withdrawn in favour of ‘unsatisfactory’ and ‘satisfactory’ providers is of particular concern to established childminders. We know that LA support is disappearing throughout the country at the moment as funding is being withdrawn and we are aware that many Local Authorities have applied to become childminder agencies. A lot of established childminders are questioning whether this is another more subtle route towards childminder deregulation as originally planned by Ms Truss last year.

A contributor to this letter makes a valid point about how the Government spends its money to support childminders - ‘It is not right that one private business should receive more taxpayer support than another. The taxpayer would not be expected to help one poor electrician to bring him to the same standard as another. Local Authority support should not disappear and it should be a level playing field ie unsatisfactory, satisfactory, good and outstanding providers should all receive the same level of support and those not up to the mark should be de-registered.’

We would also like to respectfully suggest that if you take our support away and then let Ofsted come and inspect us on a set of rules about which we know very little (because we have not received local support), with pre-conceived ideas about what inspection grades independent childminders can achieve, you are setting us up to fail. The scenario we foresee is that Ofsted will grade us lower and then tell us that we must join agencies to get a better grade and more support - subtle deregulation again!

Childminders would like to ask, ‘How can you re-assure the profession that we will be treated equally and fairly by Ofsted and be judged on rules and requirements to which all providers must adhere.’ This is especially worrying for parents and outcomes for the children if agency childminders are not individually inspected by Ofsted.

Inconsistency in inspection is another area that concerns a lot of childminders. One contributor says, ‘inconsistency and confusion only serves to undermine professional and personal confidence; it's very hard to feel motivated to do such an important job when you are pushed from pillar to post.’ Independent childminders would like clarification from Ofsted about exactly what requirements they will expect from us - and a better way of making complaints if we feel unfairly treated by inspectors.

At the moment, many childminders have post-inspection support from their Local Authorities but as LA advisors lose their remit to help childminders we are concerned that this will not be available.

Many childminders do not feel that Local Authorities duplicate the role of Ofsted. The majority of Local Authorities provide a very useful service for childminders because Ofsted often fails in its role for childminders. One inspection visit of 3 hour duration every 3-4 years (or more) is not enough for the majority of childminders and Ofsted does not share information about good practice - Ofsted does not support childminders who are struggling to understand the requirements - Ofsted does not understand local childminder needs.

As one contributor points out, ‘There is little point in finding out after 4 years that our service is not up to standard – the Local Authority advises us during the Ofsted inspection cycle of best practice and changes to legislation. It helps us to find the best training and often provides it for us.’

Further to this comment, another contributor points out that if childminders have to pay for training because it is no longer offered free from our Local Authority, this will be yet another cost we will have to pass on to parents, which will mean the cost of childcare rising even more.

While childminders agree that some Local Authorities have been a little too enthusiastic in their regulatory role, it is only to raise outcomes for the children and this must be celebrated, not vilified. The dismantling of Local Authorities and removal of support from Local Authorities for ‘good’ and ‘outstanding’ graded childminders could lead to deregulation as independent childminders are, in the words of one contributor, ‘being set up to fail’.

This must be urgently clarified by the Department for Education and Ofsted and we must be reassured, especially when promises have been made in ‘More Great Childcare’ that established childminders will not be forced to join an agency - yet some Local Authorities (who intend setting up agencies) are currently telling childminders that they will have no choice but to belong to agencies in the future because Ofsted will grade them harshly for staying independent.

As a follow up question to this, a childminder asked with a certain amount of incredulity, ‘Does the Department for Education really believe that 2 year old children will be better off cared for in a school environment’ rather than a home-from-home, loving, caring family house, with their siblings and children of different ages. Another contributor asked, ‘At what stage are we to allow the next generation to actually be children, rather than pushing them into a strict learning environment from a very early age - which may well backfire in terms of switching them off learning and achieving rather than encouraging them to be the best they can be?’

Point 2.51 - the majority of childminders broadly agree that it is unhelpful to have different regulations in the EYFS 2012 and the Childcare Register 2012 - but this could very easily be resolved with a quick change to a few regulations. To use this as an excuse to make sweeping changes to before and after school care is very worrying and, in our opinion, totally unnecessary.

Point 2.54 relating to criminal record checks (surely these are now called DBS disclosures?) it is very worrying for safeguarding reasons to remove the requirement for these to be in place - and further clarification is urgently needed. Does the Department intend changing the requirement for providers of 3 hour care so they no longer need a DBS check? Has the Government forgotten cases such as Ian Huntley in its attempts to save a bit of time and money?

Section 3.2 - 3.3 of the document talks in detail at the role of Local Authorities in the future. Is the Department for Education aware that a large number of LA support workers have lost their jobs, thousands of childminders across the country have no local support structure whatsoever and a number of Local Authorities have applied to be agencies, although the vast majority of established childminders do not want to join an agency?
Other childminders report that they have not received any support from Local Authorities even though they were entitled to this under the Childcare Act 2006 and despite them being funded over the years to provide this support. They question what Local Authorities have done with the money - and wonder why Local Authorities think they can start up as an agency and childminders who have received no support so far from them might want to join them.

Many childminders ask why the Government cannot standardise the role of Local Authorities across the country so every childminder receives the same level of guidance and support rather than having 152 variations. Local Authorities could be subsided by the Government to provide this service, with childminders paying an affordable sum to all belong to a local support group which is there for every one of them.

Childminders are pulling together during these difficult times, working in partnership with each other and setting up local and national support networks. However, we cannot reach everyone - some childminders do not use the internet, others such as the 30+ Somali minders in Manchester work within their own community and rarely access outside support - except from their Local Authority advisor.

Established childminders want to support each other so that nobody feels forced to join an agency (which was a promise made to us in ‘More Great Childcare’) but we cannot do this effectively without Local Authority help.

Point 3.46 - no requirements for ratios and staff qualifications for wrap around care. Our concern is that this will lead to safeguarding concerns for older children. At the moment the qualifications requirements are more robust for older children as noted in the Childcare Register - now it appears that they simply do not matter any more. Wrap around care sites will not have to register separately which will again lead to serious safeguarding concerns for the children. It will also lead to a rise in unregistered care which could (and many believe ‘will’) be detrimental to outcomes for children.

As a contributor points out, childminders are required to attend regular safeguarding courses, often costing us a lot of money - ‘is the Department for Education now telling us that these have been a waste of our time because anyone can look after children without any qualifications from now on?’

Another direct result of this part of the plan is that it is very likely that it will push up costs for younger children in daytime provision with childminders because if we lose our older children to unregistered (cheaper) care we will have to recoup our income from somewhere. As one contributor pointed out, ‘it will also directly create more competition / undercutting between local childminders, most of whom are already working very hard for much less per hour than the minimum wage!’

Further costs - of most concern are agency fees or, if childminders remain independent - Ofsted registration fees - will have to be passed on to parents as well. This will make the cost of childcare for parents even higher and totally negate any advantages to the agency plan if the aim really is to bring down costs for parents.

Similarly it should be remembered that childminders, like everyone else in the country, are suffering from the ongoing effects of the recession. Essential services such as electricity and gas costs, food and drink, mortgages and rent continue to rise. Many childminders would like the Department for Education to note that they have not put up their costs to parents to reflect these increases in living costs. Does the Department for education really believe that cutting childminder’s incomes will enable them to remain sustainable in these difficult economic times?

Point 3.49 - one of the contributors to this letter points out that, ‘Ofsted are not applying the requirements of the EYFS 2012 correctly. The EYFS 2012 no longer requires detailed learning and development evidence for school aged children yet Ofsted inspectors are still inspecting as if this is still required. This has left childminders confused about the requirements and needs urgent clarification.’

Point 3.50 - plans to allow 3 hours of free childcare including more unregulated care will mean a significant number of childminders losing before and after school children to cheaper unregistered care - and potentially cause safeguarding concerns as children attend unregistered provisions for 3 hours after school care a day.

Apart from the loss of income, as noted above, we are also very concerned about potential safeguarding issues. We strongly believe that there must be a minimum requirement for those providing this care to have insurance, paediatric first aid training, basic training in child development and how to care for children and DBS disclosures.

Furthermore, the Department for Education cannot possibly imagine that people who offer 3 hours care a day are going to do it for free? As one of the contributors to this letter points out, ‘because it will be unregulated care, it is very likely that payments will be undeclared income’. Another contributor notes that ‘this in turn means less NI and tax are paid into the economy at a time when surely every someone counts.’

Point 3.60 - childminders are very concerned about their future sustainability. Extra childminders will be registered by agencies (they will have to register new childminders to ensure they are quickly self funding) and laws are being eased so that schools can offer free education* for 2 year olds. One contributor asks, with some frustration, ‘where does the Department for Education expect us to find our children if they are being slowly taken away from us? Are we going to be left with a few hours of wrap around care (if more than 3 hours are needed) and babies from age 1 to 2?’
*A contributor would like to note that the funded sessions are not ‘free’ - they are often provided to parents at a cost to the childminder because the funding is less than their normal hourly rate and they are not allowed to charge a top-up fee.

Sustainability is a very real problem throughout the country for many childminders because there are not enough children to fill places. New nurseries open up taking hundreds of children - they charge more than childminders but they are not being told to drop their prices! Many ‘good’ and ‘outstanding’ childminders work for significantly less than the minimum wage - colleagues in some parts of Lancashire earn £2.50 per child per hour for pre-school children.

As one contributor points out, these childminders need to be supported - by Ofsted, the Government and Local Authorities. They do not need agencies opening, forcing them to join just to get business, taking a percentage of their already low income and registering hundreds of new childminders on their doorsteps.

Of course, taking this one step further, if a large percentage of currently registered childminders have to stop working due to lack of children because of all the Department’s plans, this will further add to the country’s economic burden as many are parents of young children who will be unable to find suitable alternative work in other roles outside of the home.

Point 3.87 - the Family Information Service has provided a childminder / parent matching service, alongside some very professional private companies, for many years. It works well and the majority of childminders get referrals from FIS. Many established childminders who wish to remain independent are very concerned that this system is under threat at a time when we need it the most, as big business agencies will be aggressively marketing cheap childcare in the very near future.

What guarantees will currently working, well trained, professional independent childminders be given to ensure our sustainability? A large number of Children’s Centres throughout the country are well known for not engaging with childminders - one of our concerns is that if they are given the remit to pass on work, it simply will not happen.

Many childminders are further concerned that this will lead to a multi tiered system - agency childminders, independent Ofsted registered childminders and unregistered carers. This will be confusing for parents and very unsafe for children.

Re. Annexe A

Other notes related to the ‘More Affordable Childcare’ plan Annexe A which are of serious concern to childminders include the following -

Outside space - free flow inside and outside play has only ever been a requirement of some Local Authority advisors and some Ofsted inspectors who expect childminders (and other early years providers) to keep their doors constantly open and take all children outside in all weathers regardless of parent wishes, the child’s individual needs or inclement weather conditions.

As Local Authority support is being dismantled we do not feel it will be an ongoing issue, so we welcome this clarification.

Learning Journeys - these have never been a requirement of the EYFS 2012 - however, it must be recognised that Ofsted inspectors are looking in more and more detail for childminders to show each EYFS aged child’s progress towards the Early Learning Goals. The vast majority of childminders cannot provide this evidence - and share information effectively with parents - unless it is written down. A file called a ‘Learning Journey’ has become the norm for early years providers and is a very valuable document for parents.

I am an outstanding Ofsted registered childminder - and have been graded outstanding at my last 2 inspections. My action at my last inspection was to separate 2 different pieces of information in children’s Learning Journeys onto 2 pieces of paper. This shows in how much detail Ofsted inspectors look at Learning Journey files so they can find fault.

As one of the contributors to this document says, ‘Ofsted need to exactly define what level of paper work they are expecting to see for each child.’ The grading system needs a prompt overhaul, with childminders involved in the consultation process - and listened to by Ofsted. It is not acceptable for new childminders to be given a ‘satisfactory’ Ofsted grade by an inspector in their car, before arriving at their home - as often happens. Another contributor points out that ‘neither should it be acceptable for Ofsted inspectors to lower childminder grades for things not in the statutory framework’.

Written risk assessments are required by a large percentage of Ofsted inspectors. It is all well and good saying in the EYFS 2012 that childminders no longer need to write risk assessments, but Ofsted inspectors continue to downgrade childminders for not complying with requirements about which they have not been advised. For example, a colleague was given an inadequate Ofsted inspection grade recently for failing to write a risk assessment covering a child who had started crawling on the morning of her inspection. Judgements like this explain why childminders are reluctant to throw away their documentation.

Written policies and procedures, while not required by the EYFS 2012, are a requirement of the Childcare Register 2012. For your information, please see footnote on the bottom of page 4 of this Ofsted document -
Ofsted | Factsheet: childcare - Records, policies and notification requirements of the Early Years Register.

We find it worrying that Department for Education and Ofsted have failed to liaise on this and recognise that the majority of childminders are registered to care for over 5s and therefore have to comply with the requirements of different registers.

We would also like to raise concerns that the list of policies and procedures given in the ‘More Affordable Childcare’ document and the one in the Childcare Register requirements are not the same, causing more confusion for already beleaguered childminders!

In conclusion, thank you for taking the time to read our response to the ‘More Affordable Childcare’ plan. We hope we have helped you to see that it is a document which raises a lot of very valid concerns.

Childminders want to engage with Government to help offer the 2 and 3 year entitlement - we want to continue to provide high quality care and education for our youngest children - the vast majority of us want to be Ofsted registered and inspected because we believe this to be the best way of showing parents that we are committed to providing the best possible service.

We fought against deregulation last year and the Department for Education appeared to have listened to us. We do not want to be deregulated by stealth, being forced to join agencies just to remain sustainable or because Ofsted inspectors downgrade us to discourage from remaining independent or because we have lost our Local Authority support and we no longer have any help to manage our provisions to keep them running at their currently high standards. A number of childminders are very concerned that this is what is happening in the ‘More Affordable Childcare’ document.

We are intelligent and committed people who lead and manage small businesses of vital importance within our local communities. We recognise that the Government does not want Ofsted to regulate us any more - but we are not being offered an alternative which has been chosen by us! We are not being listened to and our responses to consultations are being ignored.

We are grateful that some early years groups are speaking for us -

- Pacey state that they have grave concerns about agencies, voiced by their members who do not want agencies thrust upon them and note on their website - ‘Recent research by IPPR, funded by PACEY, showed that only 7 per cent of childminders support the idea of moving away from individual Ofsted inspections towards collective agency assessment, preferring regular inspections for each.’

- UKCMA met with a member of the House of Lords recently to argue our case.

- At a recent 'Chatham House' round table discussion with Ofsted and the wider sector, PLA tell us that they were one of the most outspoken attendees arguing against the case for agencies.

We also know (because they have told us) that the majority of the contributors to Ms Truss’ task and finish group are not in favour of agencies for childminders - because we have asked them for their feedback and they have told us that they are trying to support us against overwhelming pressure from the Department for Education and Ofsted.

We would also like to respectfully remind you that Nick Clegg said (Daily Mirror, 6.5.13) that ratio changes could not go ahead as they would do nothing to cut costs and would put youngsters at risk. We are very concerned that these proposed ‘More Affordable Childcare’ changes will do exactly the same.

We feel that for some reason the Government has chosen childminders (possibly because we are difficult to regulate as we work on our own) to bludgeon with constantly changing regulations, overly harsh actions from Ofsted inspectors, inspection outcomes which often bear no relation to the quality of care and learning which we provide and agencies which, as we said at the start of this letter, we neither want nor need.


Sarah Neville
Ofsted registered independent childminder

With thanks to contributors to this letter including -

Jane Bromfield
Lucy Grieve
Nigel Graven
Jacqui Clinch
Jenny - a childminder from Cheshire East
Simona Mackenzie
Jayne Blount
Maxine Bradford-Sharp
Rick Knight
Emma - a childminder from Manchester
Samantha Stapleton
Tara Malton


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