Close

Submissions

Family Day Care Australia represents our members to government by consulting with the membership and making submissions regarding issues which impact on the family day care sector.

To view Family Day Care Australia’s recent submissions, please click on the links below.

Submission to the Productivity Commission Inquiry into Early Childhood Education and Care “A path to universal early childhood education and care: Draft report”

On Wednesday 14 February 2024, FDCA placed a submission in response to the Productivity Commission’s Inquiry into Early Childhood Education and Care “A path to universal early childhood education and care: Draft report”.

In this submission FDCA calls on the Inquiry to make final recommendations that account for the essential role of family day care within the current landscape, the unique structural elements of the model that underpin its key strengths, the significant potential capabilities beyond existing utilization rates, and which ultimately support the sector’s growth and viability.

Jobs and Skills Australia Capacity Study

On 30 January 2024, FDCA placed a submission in response to the November 2023 consultation paper for the Early Childhood Education and Care (ECEC) Capacity Study, being undertaken by Jobs and Skills Australia (JSA) in partnership with HumanAbility.

In this submission, FDCA seeks assurance from JSA and HumanAbility that the important role of family day care is adequately considered and clearly recognised in the study’s findings, and that recommendations are made that will support the continued growth and viability of the sector.

FDCA Pre-Budget Submission 2024-2025

On 25 January 2024, FDCA submitted our Pre-Budget considerations for 2024-2025 to the Australian Government. The submission recommends four key investment measures to support the continued viability of a sector that is highly valued for its flexible, responsive and affordable ECEC:

  • raise the hourly CCS cap rate for family day care to be on par with that of the centre-based care sector;
  • apply an additional loading of 20% to the recalculated CCS fee cap for non-standard hours care;
  • initiate a direct funding support program (an “Approved Service Engagement Payment”) for family day care approved services to assist in the recruitment, induction and training of new family day care educators; and
  • initiate a direct funding support program (an “Educator Start-up Grant”) for new family day care educators to assist in overcoming some of the financial barriers to entry into the sector in establishing their micro-business.

Submission to the Australian Competition and Consumer Commission’s Childcare Inquiry

In October 2023, FDCA made a submission to the Australian Competition and Consumer Commission’s (ACCC) Childcare Inquiry, following the release of the Inquiry’s final Interim Report. The findings of the ACCC Inquiry will feed into the broader Inquiry into Early Childhood Education and Care being conducted by the Productivity Commission.

In FDCA’s submission, we restate our core advocacy recommendations regarding sector growth and viability and urge the Commission to undertake a closer examination of the issues affecting viability and affordability in the family day care sector, for example the inadequacy of the current inequitable Child Care Subsidy rate that applies to family day care compared to that applying to centre based care.  Furthermore, FDCA highlights the unique role played by the family day care sector in providing families choice and flexibility in quality early childhood education and care across metro, regional, rural and remote Australia, including providing access to non-standard hours ECEC, and catering for specific cohorts of children such as those from culturally and linguistically diverse backgrounds,  for those with additional needs and those living in less advantaged areas.

Submission on the inquiry into Early Childhood Education and Care

On 19 May 2023, FDCA made a submission to the Productivity Commission on the Inquiry into Early Childhood Education and Care.

The Inquiry will make recommendations that will support affordable, accessible, equitable and high-quality ECEC that reduces barriers to workforce participation and supports children’s learning and development, including considering a universal 90 per cent child care subsidy rate.

FDCA Pre-Budget Submission 2023-2024

On 27 January 2023, FDCA submitted our Pre-Budget considerations for 2023-2024 to the Australian Government, a continuation of the priorities outlined in our 2022 Pre-Budget Submission with updated data and information from consultation with members.

FDCA Submission to the Senate Education and Employment Legislation Committee inquiry into Family Assistance Legislation (Cheaper Child Care) Bill 2022

On 17 October 2022 FDCA made a submission to the Senate inquiry into the Family Assistance Legislation (Cheaper Child Care) Bill 2022. In addition to responding to the overall intent and specific points in the draft legislation, we took the opportunity to again highlight the key issues affecting affordability of family day care for parents and viability of the sector as a whole.

You can read our main submission here, which was supplemented by Attachment 1 and an Addendum to our original submission.

FDCA Submission to the Department of Education: Hourly CCS Rate Cap Consultation

Following a survey of members’ views on the key issues, FDCA made a submission to the federal Department of Education’s Hourly CCS Rate Cap consultation in October 2022.

The Hourly rate cap consultation was initiated by the Government to better understand the perspectives of the early childhood education and care sector on:

• The influence of Hourly Rate Caps on affordability, accessibility, quality and sustainability

• How effectively the Hourly Rate Caps operate across all care types

• Any unintended consequences associated with the Hourly Rate Caps.

The Department will use the feedback from the Hourly Rate Cap Consultation to inform the upcoming Competition and Consumer Commission (ACCC) Price Inquiry into the factors that drive child-care prices.

You can read our submission here.

FDCA pre-election commitment requests and responses

In the lead up to the 2022 election, FDCA surveyed members on their views about issues relating to the family day care sector. Based on members’ feedback we developed a set of pre-election commitment requests to send to the major Australian political parties in March 2022.

Our pre-election commitment requests fell under six key policy areas:

-       Affordability and Women’s Workforce Participation

-       Women’s Economic Security

-       Regional Economic Development

-       Flexibility

-       ECEC Workforce Support and Accessibility.

You can read the requests we made and the responses received from the major parties here.

FDCA 2022-2023 Pre-Budget Submission

In January 2022, FDCA lodged a submission with the federal Department of Treasury in advance of the Morrison Government’s 2022-23 budget. Our pre-budget submission, which reflected the consolidated views of members, outlined the case for four key funding priorities that we consider essential to ensuring the long-term viability of the family day care sector:

-       amendments to the calculation of the Child Care Subsidy (CCS) hourly fee cap

-       an additional loading of 20% to the recalculated CCS fee cap for non-standard hours

-       direct funding support to assist in the recruitment, induction and training of new family day care educators

-       direct funding support to new family day care educators to assist in overcoming some of the financial barriers to entry into the sector in establishing their micro-business

You can read our submission here.

Submission to the 2019 Review of the National Quality Framework - Consultation Regulation Impact Statement

Following a survey of our members, FDCA  provided a submission to the 2019 Review of the NQF on 30 April 2021.

As we have emphasised in previous submissions to the Review, FDCA and our members remain supportive of well-considered and reasonable regulatory proposals and proportionate compliance mechanisms that are designed to support a high quality, vibrant and responsive family day care sector.

However, we maintain that it is equally important that regulatory measures do not constrain growth in the sector, so that family day care services are able to continue to meet the needs of families for whom high quality, flexible and affordable child care in a professional home learning environment is their preferred or only choice.

FDCA 2020-21 Pre-Budget Submission to the Commonwealth Government, Department of Treasury

On 31 January 2020, FDCA placed a Pre-Budget submission as a mechanism to support of our sector viability strategy.

The submission is a component of our Sector Viability Strategy and examines the key issues affecting the long-term sustainability of the family day care sector and recommends investment measures to address these issues.

FDCA Submission to the Senate Education and Employment Legislation Committee regarding the Family Assistance Legislation Amendment (Building on the Child Care Package) Bill 2019

On 30 September 2019, FDCA placed a submission to the Senate Education and Employment Legislation Committee regarding the Family Assistance Legislation Amendment (Building on the Child Care Package) Bill 2019 ("the Bill").

The Bill, which was presented to Parliament on 18 September 2019, makes policy refinements and addresses unintended consequences resulting from the implementation of the Child Care Package on 1 July 2018.

FDCA Submission to the 2019 Review of the National Quality Framework

On 28 June 2019, FDCA made a submission to the 2019 Review of the National Quality Framework. The submission is underpinned by FDCA’s strongly held positions that:

  • FDCA does not support any regulatory changes that will further restrict the viability of the family day care sector or limit the capacity for legitimate growth; and
  • Consistency of implementation of the NQF is paramount if the validity of the NQF is to be sustained.

FDCA Submission to the Consultation Regulatory Impact Statement on family day care residences with swimming pools, spas and water features in WA

On 13 May 2019 FDCA made a submission to the WA Dept of Communities in response  to the recently released Consultation Regulatory Impact Statement (CRIS) on family day care residences with swimming pools, spas and water features in WA. The CRIS was developed to canvas proposed changes to regulations and other policy options to address recommendations made by Coroner Sarah Linton following the inquest into the tragic drowning of Lachlan James Mitchell at his family day care service on 9 November 2015.

Expert review of Australia’s vocational education and training system

On 25 January 2019, FDCA made a submission to the Expert Review of Australia’s vocational education and training system. The submission highlights a number of concerns in relation to content and quality of education and training and quality and consistency of information about qualifications and employment outcomes relevant to the family day care sector. It also advocates for incentivising uptake of the Certificate III in Early Childhood Education and Care in regional and remote areas to meet strong and growing demand for early childhood education and care services in those areas.

Submission to the Senate Select Committee on Red Tape Inquiry into the effect of red tape on child care

In early April 2018 FDCA made a submission to the Senate Select Committee on Red Tape regarding the effect of red tape on the child care sector. The submission outlines a number of concerns in relation to administrative burden and red tape in the family day care sector including the significant increase in regulatory burden over recent years, coupled with the decline in operational funding.

Jobs for Families Child Care Package – Submission to the Senate Inquiry March 2017

A Senate Inquiry into the provisions of the Social Services Legislation Amendment (Omnibus Savings and Child Care Reform) Bill 2017 was referred to the Senate Standing Committees on Community Affairs in March 2017. FDCA provided a submission to the Inquiry on behalf of our membership, however as the Bill presented no major amendments to the Jobs for Families Child Care Package legislation, the submission was primarily a reiteration of the key positions initially provided in our submission to the Senate Inquiry into the Family Assistance Legislation Amendment (Jobs for Families Child Care Package) Bill 2016.

Jobs for Families Child Care Package – Submission to the Senate Inquiry September 2016

A Senate Inquiry into the provisions of the Family Assistance Legislation Amendment (Jobs for Families Child Care Package) Bill 2016 was referred to the Senate Education and Employment Legislation Committee in September 2016. FDCA provided a submission to the Senate Inquiry on behalf of our membership, largely through a reiteration of our original submission to the Senate Inquiry into the Jobs for Families Child Care Package Bill 2015. FDCA also appeared at the public hearing to give evidence.

2016 Federal Election Commitments document – June 2016

In the lead up to the 2016 Federal Election, FDCA provided an election commitments document asking each of the major political parties where they stand on the key issues of quality, accessibility, affordability and flexibility in the early childhood education and care sector.

Jobs for Families Child Care Package – Submission to the Senate Inquiry January 2016

An Inquiry into the provisions of the Family Assistance Legislation Amendment (Jobs for Families Child Care Package) Bill 2015 was referred to the Senate Education and Employment Legislation Committee in December 2015. FDCA provided a submission to the Senate Inquiry on behalf of our membership, which provided recommendations based on member consultation.

Jobs for Families Child Care Package – Submission to the Regulation Impact Statement July 2015

Following the introduction of the Family Assistance Legislation Amendment (Jobs for Families Child Care Package) Bill 2015 to make changes to child care fee assistance arrangements, the accompanying Regulation Impact Statement (RIS) was released for consultation by the Department of Social Services. FDCA responded to the options put forward in the RIS in the form of a submission, presenting a number of recommendations regarding elements of the Package.

Submission to the Senate Regulations and Ordinances Committee and the Parliamentary Joint Committee on Human Rights regarding the Child Care Benefit Amendment Determination 2014 (No. 1) – January 2015

FDCA put forward a submission detailing our policy positioning regarding the Child Care Benefit (Eligibility of Child Care Services for Approval and Continued Approval) Amendment Determination 2014 (No. 1), primarily seeking disallowance of the requirement that educators do not obtain a session of care for their children from an educator in any family day care service on a day on which the family day care educator provides any session of care to a child.

Submission to the Education Council Regulation Impact Statement for proposed changes to the National Quality Framework - January 2015

In response to the Council of Australian Governments’ (COAG) Consultation Regulatory Impact Statement, FDCA put forward a submission regarding the proposed changes or ‘options’ for changes to be made to the Education and Care Services National Law Act 2010 and the Education and Care Services National Regulations 2011 as part of the National Quality Framework.

Submission to the Productivity Commission Inquiry into Childcare and Early Childhood Learning Draft Report – September 2014

In response to the recommendations put forward in the Productivity Commission’s Draft Report on Childcare and Early Childhood Learning, FDCA put forward a submission responding directly to draft recommendations and highlighted a number of key matters affecting the family day care sector.