The Queensland Childrens Activities Network provides the following response to the draft Integrated Quality Assurance Standards and Framework. QCAN maintain an 85% membership base od OSHC services in Queensland. This feedback has been gathered through consultation with our members using our internal system of networks throughout the State.
Integrated CCQA
The idea of an integrated CCQA standard and framework is generally agreed in principle by the OSHC sector in Queensland. Such a system would be seen as beneficial to supporting the development of a common set of overall goals for Children's services throughout Australia.
In saying this however, the integrated system would not in any way devalue the differences in the types of care provided to school age children. Middle childhood represents a time where care provided to children focuses on the persuit of recreation and leisure opportunities. Therefore, it would be highly recommended that seperate indicators be used to measure the quality areas and principles of the integrated system for school age care services. While it is appreciated that there are common overarching goals for childrens services, the ways in which these are met by OSHC services is distinctly different. This needs to be appropriately acknowledged through a document that reflects current understandings and research in middle childhood.
Concerns have been raised in Queensland about OSHC being melted in with Long Daycare through the implementation of an integrated system. Should the distinct differences in the type required to meet the needs of school age children be missed in the integrated system (as they are in the draft document) then the quality of the care for children attending OSHC will significantly decline from it's current level.
Theintegrated document fails to recognize some of the quality areas currently considered important in the operation of the quality school age care service. In particular the lack of community focus of school age children is a concern. Community development and integration is an essential life skill for children to actively experience through school age care. The loss of this quality area is very disappointing and will limit the provision of opportunities for school age children to actively engage in their local and wider communities through participation in OSHC.
Accreditation Level
Many service providers have expressed deep concern regarding the removal of quality levels. The current system has been built on the notion of 'Continuing Improvement'. Should there be no recognition for seevices that achieve a 'high' level of quality, then it is of concern that the level of quality services will rapidly decline with a loss os incentive to work towards achieving good and high level indicators.
Framework
The proposed framework provides limited opportunities for families and children to engage in the accreditation process. School age children are capable of actively partcipating in accreditation and should be acknowledged as a valuable resource in the evaluation and assessment of the service.
it would be desirable to see included in the framework an appeals process that is open and transparent. Such a process would provide the capacity for services to dispute a decision, particularly where there has been inconsistent and unfair assessment in respect of indicator interpretation.
Further information about who is involved in the accreditation decision process is required. The removal of moderation from the process means that the current use of independent expertise which promotes transparency is unfortunately lacking in the proposed framework.
Suspending CCB after the second or subsequent time that the service is not accredited is significantly harsher than that of the current system. (Although, this is generally supported to ensure compliance with the objectives of the quality framework.) Implementing this may be crippling to smaller OSHC services, particularly when located in rural and remote areas without appropriate access to intensive support. Clear guidelines for the provisional accreditation may be able to pick up gaps where support is required and how this can be accessed so that the service can reach the level required fro accreditation.
Spot Checks
While random spot checks are acknowledged as valuable to ensure quality mantainence over the 3 year period, consideration must be given to the other government agencies that may also be conducting spot checks of services. Some of these include, but are not limited to legislation compliance (Qld Regulations); Workplace Health & Safety; Fire Department; Commission for Children, Young People and Child Guardian; CCB etc. Such consideration may include communication between agencies to ensure random spot checks are not planned at the same time. Consideration to the nature of the spot check would be useful also to minimize doubling up on compliance activities.
Transitioning and Timing
Information on transitioning arrangements to the new system would be useful as soon as possible. Consideration is requested to be given to the many changes that school age care services have experienced with the current system and other impending changes to service delivery such as CCMS as legislation in some states. The current level of consideration for the community based sector is very limited.
Support for services
Intensive support for services in transitioning to the new system would be required. This would include resources and guidance around the requirements of the indicators in the integrated system and how these can be met by OSHC services. Significant support inrespect of training, resources and advice would be optimal. Should the expectation for funding fall back onto the PSC in each state, then it would be recommended that a national formula for calculating funding support be developed to ensure equitable access to service specific resources, information and advice across the Nation. Ideally, an allocated amount of time for an evaluation support visit and a not accredited support visit would assist the PSC in determining apropriate levels of funding.
Funding
It appears as though all support is accepted to be provided through the PSC. This may unfairly reduce the freedom of choice to services. Individual services should be able to acess funding which could be used for accessing accreditation support according to their individual identified needs and not those generated as 'key priorities' from the generalised training needs analysis.