Submission
SUMMARY
Contrary to the Government's intentions, in the provision of child care services, we favours allowing parents to choose the standards of child care for their children.
The Government's proposed regulations are premised on it displacing parents in the determining how to care for children. The proposals reject the notion that it is parents who are the most efficient custodians of their children's interests and interpose a bureaucracy and a credentialism where none is needed. In doing so they will ensure that prices are increased, to the detriment of the parent-consumer and to the taxpayer who pays an increasing proportion of the costs.
The existing and proposed regulatory arrangements, are founded on a paternalism that says, "The gentlemen and gentlewomen in Spring Street know the citizen's true needs better than the citizen". The Regulatory Impact Statement disguises such sentiments by making claims on the behalf of "the community", which is said to require services of a higher quality. People in general always want higher quality. Most would prefer to drive a BMW rather than a Holden, opt for a fine restaurant rather than Macdonald's, and buy designer clothing rather than ready-to-wear. Few people actually choose the highest quality because they either cannot afford it or prefer to settle for something less and save money.
In the case of child care, the fact is that the customers need to be coerced into using services deemed by the sponsors of the regulation to be those they truly prefer. Other standards of service, many of which have long been in operation, are to be declared illegal. The sponsors do not want to leave it to chance that those responsible for the upbringing of children, the parents, might not share their expert opinion of what is sound practice. They want instead to impose a plethora of requirements on those offering child care services. These requirements are said to improve the quality of the services. Whether or not they do, they will undoubtedly increase the price. The regulatory denial of choice in the quality of services citizens may select is contrary to the concepts of economic and political freedom that the Government claims to espouse.
Our preferred approach to the provision of goods and services allows the free interplay of demand and supply. Such an approach has long been demonstrated to offer the lowest cost goods and services and the diversity of supply that the market commonly requires. Our view is not founded on some ideological prejudice, but on vast experience of how goods and services are provided most efficiently.
DIFFERING OVERALL APPROACHES
The approaches to the provision of child care can follow one of two routes. The first is having government specify in considerable detail:
- who may provide the service,
- the facilities in which it may be provided
- the staff who may support the provider
- the times that the facility may be open
- the age profile of each facility's group of children
- the proportion of staff to children and the nature of that proportion as between staff of different levels of credentialled expertise
- the prices at which the service should be provided.
The alternative is to insist on rigorous publication of information on the centre so that parents can choose the quality they consider appropriate to their needs, preferences and resources.
Child care is an important matter for parents. Choice of centre is not a decision that will be undertaken without major consideration. By its nature, it is a "repeat purchase" and dissatisfaction will lead to changing the supplier. This places pressure on the centre to perform in order to gain and retain its customer base. With open access to the provision of child care services, each centre must continuously strive to provide value. This market based approach allows needs and offerings to be matched without the intercession of a bureaucracy.
The usurping by the State of the need for the parent to exercise control may also lead to a form of "moral hazard". Where a bureaucracy is vested with responsibility to ensure a standard is maintained, it is likely that users will be less vigilant in undertaking these tasks themselves. Users will assume that others are undertaking the scrutiny role that they themselves would previously have performed. This may lead to reduced resources being applied to the scrutiny. It also may mean a less effective scrutiny where those undertaking it are focused on a rule.
MEASURING THE NEED FOR THE PROPOSED STANDARDS
Impact of Credentialism
The increase in the costs that the new regulations will cause is comprehensively demonstrated than in the credentialism that is being specified. Rearing and caring for the young is something that requires no qualifications. It is a natural function of all creatures. Millions of generations have demonstrated that it requires no scholastic preparation.
What is proposed is an extension of present requirements of having qualified staff employed in the Class 2 centres which cater for children in care no more than 10 hours per week and for no more than 10 hours per week. The qualified staff will also have to be in attendance at all times that children are present in the Class 1 centres. A minimum of two staff will need to be in attendance at all times children are present.
Some may argued that child care is part of education and that qualified staff are equally important in this service as in schools themselves. If this is the case, the preferred approach is act directly and to lower the school attendance age.
The adverse impacts of the proposals can be crystalised under three headings:
- First, they deny some of the least privileged members of society an opportunity to use their skills. Although standards for acceptance to obtain the qualifications are not high, they will prove too onerous for many willing carers. For others the need to obtain the credentials and forego paid employment will prove to be financially forbidding. The impact is likely to be on people, especially women, from poor backgrounds, including aboriginals, and migrants. Denying perfectly competent women from such backgrounds opportunities to use their skills to the fullest extent is a cruel and shameful strike by the educated classes who are devising and policing the regulations.
- Secondly, there is the needless cost of services foregone while the qualifications are being acquired. If two years are taken to obtain the diploma, and the normal working period is twenty years, society incurs a cost increase of 10%. Inexplicably, while it draws attention to the cost of HECS, the RIS fails to recognise the deferral of payed employment as a cost. Of course, the cost is retrieved by the credentialled people in terms of their increased remuneration. But that increased remuneration is paid for by the hapless consumer/taxpayer. In the regulations being put forward, the voices of these people are not heard. Most would not have the degree of interest to seek modification of the system, for, unlike those seeking the intensification of the regulations, they are not paid from the public purse to devise new ways of imposing their preferences.
- Thirdly, the regulations will directly increase wage costs. According to the RIS (p.31) credentialled workers are paid 29-50% more than other workers. This must be reflected in fees.
The higher costs will in all likelihood be picked up by governments. But this means foisting the costs onto other taxpayers. There is a case for some modest subsidy to those who would be otherwise be impoverished by not being able to work, but at present arrangements extend some sort of subsidy to the vast bulk of parents.
A revolt of taxpayers is currently underway throughout the western world and it seems likely that the subsidies will come under pressure in future years. At that time it will prove very difficult to dismantle edifice of the excessive qualifications -- people will, in all good faith, have denied themselves income by undertaking unnecessary training. They will resist the opening up of their positions to competitive labour supplies which have had not had to make the sacrifices.
Check on criminal records
If there are 10,000 workers in the industry in Victoria the checks, at $34 each, will cost $340,000. This would be increased if volunteers are also to be checked as they logically should be. Moreover, these checks will not be effective in revealing a record of someone who was intent on hiding their past, as would surely be the case with people who might pose a danger to the children under their care. The checks would therefore be a waste of money.
The regulatory impact statement contemplates, but rejects on the grounds of cost, a fingerprint test. The mere consideration of this option is disturbing from the perspective of civil liberties. While it is appropriate to take stringent care to avoid recruiting criminals in such occupations as the police, fingerprint checks are not the practice elsewhere. Would those who are devising the regulations, those in the inspectorate and those in the Department also agree to be fingerprinted as a condition of their continued employment?
Staff:Child Ratios
The proposals are to increase staffing in the Class 2 centres, bringing them in line with the more stringent requirements in Class 1 centres. Contrary to this approach, we considers that mandatory staffing levels ought to be abandoned. Instead they should be replaced by a requirement that all centres prominently display up to date information on the numbers of children and numbers (and qualifications) of all staff and their hours of operations. This will give parents the opportunity to select the services that suit their situations.
The absurdity of the proposed arrangements is demonstrated in the provisions that will prevent any flexibility in operations even where staff are not available. There are, at present, five centres where staff cannot be recruited due to their geographic isolation and other centres where most of the children are aboriginal and no suitably qualified staff are available. Those centres would be forced to close and the parents denied suitable child care.
While some totalitarian regimes have taken over children at a very early age, our preferred way of rearing children under 6 is for the State to intervene only in circumstances where the child is being abused or neglected. The present arrangements assume the parent is unable to make the correct decisions about their children's well being. The approach is irreconcilable with our notions of democracy and individual responsibility. It will almost certainly engender costs additional to those seeking the services require.
Facilities
The Regulations cover the facilities in great detail. These specify space per child, require natural light outdoor areas, child-specific toilets and wash basins and an ability of staff to observe children at all times. While these requirements are doubtless inspired by well meaning considerations, a moment's reflection leads one to realize that a great many homes fall far short of these standards of appointment.
Should we not, therefore, require such facilities as a pre-condition of people having and bringing up their own children? The logic of requiring such standards in child care standards is that they should be extended to all facilities where children are cared for. Indeed, they are all the more necessary where the child is living in premises for 24 hours per day rather than the 40 hours per week in a centre.
This logic could dictate:
- that children should not be brought up in tall apartment blocks, especially where there is little natural light;
- that nobody should be allowed to have children unless they have first completed the required tertiary qualification;
- that there should be at least two people present to supervise children at all times, especially where there are more than three infants in the family;
- that homes in which children reside should be remodelled to ensure the wash basins and toilets are appropriate for those of small stature and that those using the facilities can be observed at all times.
CONCLUDING COMMENTs
The regulations as proposed represent a solution in search of a problem. They are more exacting in many respects than are those governing the care of sick people.
The excessive costs of the proposed standards are most readily seen once they are compared with those required to bring up children in other situations. The two most obvious comparisons are with the home and schools catering for 6 or 7 year old children.
School records do not require the considerable detail specified in the regulations for child care centres. Nor do schools see the need to keep such exacting details of parents, court orders, languages spoken etc.
Clearly, all these requirements will call forth a policing system. This will offer valuable career opportunities to public servants, many of whom are hostile to private sector provision of child care services. The thousands of regulatory requirements will ensure that no centre could guarantee an unblemished outcome from inspection. This may result in an inspectorate that will apply standards in a discriminatory fashion and pose a constant threat to the livelihood of many entrepreneurs.
If the proposed provisions are in line with the wishes of parents, the Government could set a standard and allow those centres that meet it to promote this to users. Where parents choose not to send their children to these "accredited" centres, this should be their right. If the "accredited" centres are what parents really wish to use, they will displace from the market those that do not meet the standard.
No comments:
Post a Comment