Response to the consultation on Childminding Agencies and changes to LA role   1 comment

So less than one month before Childminder Agencies become law and the Government have published their response to the consultation on childminder agencies and changes to Local Authority Role.


If you have not seen it yet PLEASE CLICK HERE

The first thing I want to comment on is the number of respondents – the total of 678 responses is very low and in particular the stated response of 59 childminders plus 13 network childminders (so 62 childminders in total) is disappointing

However there are 105 responses of which it is stated a large % did not state which group they fitted into – so some of those may have been childminders –

Even so with just 678 respondents and less than half that amount for each specific question, the Government should be looking into why so few people respond – and to ensure their consultations do provide effective feedback, I think the Government need to consider other methods – and a key one would be counting the individual responses that go into making  up an organisations response. They could also think about using a more friendly format such as surveys that could be provided via social media and so on.


However, it is my personal opinion that many do not bother to fill in Government consultations because quite frankly they are a pointless exercise with the Government taking very little, or no notice of the opinions expressed.

So will this consultation be any different? Will the Government listen to and more importantly act on the views expressed?

There is only one way to find out – and that is to look at the document and see what the Government response is.

So Question One (on page 6) Number of hours CPD required

50% did agree with the Government that the suggested number of hours CPD for agency childminders was about right – so on the face of it – it would appear the Government have got it right

However 34% said it was too low – and  another 11% were not sure – so actually 45% did not agree that the suggested number of hours CPD was right.

Personally I would have thought this was enough evidence to  consult further – especially when considering the concerns expressed.

Why do I suggest this?

Well take a look for yourselves .. there were 352 responses to this question – so that means that almost  half of the consultation respondents did not answer this question. Is that because they did not have enough information / understanding about childminder CPD?

Those that did answer the question had concerns  and many were expressed about the quality of the training opportunities / CPD that would be provided.  I agree because it would be possible to put on one or two workshops , or send out information via a newsletter – perhaps suggested reading;  and easily provide evidence of 16 hours CPD, because as we all recognise CPD is not just attendance at training.

Concerns were expressed about if the 16 hours were per childminder or per agency

Concern was expressed about if the suggested 16 hours CPD, included statutory requirements for training – which if you think about it – First Aid alone would count for 12 hours in the year that it had to be renewed, or 4 hours a year if averaged out over the validity of the certificate.

These expressed concerns are pretty much the concerns that I personally expressed – and so although I don’t know – I would guess that these concerns were expressed by those who understand childminding and CPD

So what is the Government response to the views expressed for question one about number of hours of CPD?

Well the good new;s is that they will make it clear that it is 16 hours CPD per year for early years childminders and 8 hours for later years childminders

The neither here or there news; is that the Government will be ‘building on the requirements / expectations around CPD  within the guidance document

The bad news; is they are not even going to consider increasing the number of hours CPD requirement

Very disappointing and a wasted opportunity

For a start – Why less hours for a later years childminder?  Why are they not prepared to make it statutory for CPD to be in addition to statutory training requirements? Why have they not said that that Ok we will start at 16 hours for all childminders – and then increase to 18 hours and then 20 hours over the next two years?

Surely if the Government want to increase the quality of childminders and the outcomes for children – they need to use increased requirements for CPD, to support this?

Maybe the Government should find out how many hours CPD the childminders who have good and outstanding grades actually do in a year? Certainly speaking just for myself  – I do more than 16 hours CPD in the average month – in fact I often do more than 16 hours in a week,  if you take into account all things I do that are CPD. And I am sure many of my childminding colleagues would be able to confirm that they also do more than 16 hours CPD in a typical month and that many would say that their yearly CPD total is in excess of 100 hours.

Think about it 16 hours a year is under 2 hours per month – which would be fine if talking about accredited training – but it is not ! If using the term CPD – maybe the Government have a different understanding of CPD to me?

Question two (on page 7)  Number of hours support time 

337 responses to this question – so again around half of the consultation respondents did not answer this question – and again I have to ask why?

46% agreed with the Government – but 39% did not agree – and if you add the 11% not sure you actual have more at 50%  NOT agreeing  with the Government – so you would have thought that further consultation would be required.

A look at the concerns expressed shows that those who did answer this question has a lot of concerns and unanswered questions; for example;

Was  support time  inclusive of CPD hours or separate?

Did support time include newsletters and admin hours?

Respondents were generally in favour of face to face meetings as support time

So what is the Government response to the views expressed for question two about number of  support hours ?


Again there is a difference in the requirement for early years childminders and later years childminders – and I have to ask why – in my opinion if anyone is looking after children – the requirements should be the same.

So the good news is that the Government have taken some notice in that they are changing the wording from  support time  – to – practice support with a focus on CPD requirements

Hang on a minute – go back to concerns expressed for question one – respondents were concerned  if CPD would be of an appropriate quality; in question two they expressed concern that support time might  include newsletters and things that did not include face to face time.

So unless I really have not understood the Governments response – they have just muddied the waters even more and given the go ahead for practice support and CPD to be almost the same thing – which in my opinion will lead to confusion about hours required (Is it practice support ? / is it CPD?) and so will we see the same hours counted twice –  so  counted for CPD and counted for Practice Support?

It seems the Government do not share my  understanding  CPD because they would know that practice support is CPD!

If they had asked for my advice, I would have advised them to have X number of face to face CPD support which would have included training workshops and home visits put on by the agency – and X number of hours of non face to face CPD  to include online training, webinars,  and X number of hours face to face training from outside trainers (so not all ‘in house’) and  a requirement for specific  non face to face CPD support which would have included newsletters, emailing info such as links to articles. But they didn’t ask me – and I have to ask who did they ask – where did they get information / ideas from. Complicated maybe but then CPD can be in many forms and if not wide ranging,  it has downfalls and therefore might not be effective or of high quality.

So the good news is not really good news – is bad news.

The Government do say they are going to build on the requirements in the guidance documents – but I have a problem with that – guidance documents are just that for guidance, so different agencies will apply different bits or even not at all – leading to inconsistencies.

Question three (on page 8) Requirement for ONE home visit after agency assessment


As with questions one and two only about 50% of respondents answered this question – 348 to be precise

54% of those who responded said that they disagreed with the Government that agencies only needed to do one home visit per year after initial assessment and a further 13% were not sure .

Respondents thought that home visit could improve the quality of the provision – I personally agree with this from my experience as network coordinator . Others thought it would be acceptable to scale back visits once the childminder had been assessed – I disagree, it is regular and unannounced visits that work, not planned annual visits. You need to get to know the childminders and their practice really well, you need to understand their issues and their personal issues that impact on their childminding, you need to discuss things in detail – you can not do this is one planned visit – all you can do in one planned visit is gain a snap shot – and tick a few boxes that prove nothing.

Respondents said that each childminder would have different needs – and for a huge number of reasons and so there should be flexibility. I agree but I also think the minimum number of visits should be three per year – if the purpose of the visits is to support and drive up quality and outcomes.

So what is the Government response to the views expressed for question  three about number of home visits?

Well, the government are going to continue to state that there is a minimum requirement for one home visit but will put in the guidance document that agencies may do more visits if they want to.

I am personally really disappointed about this – as the one aspect of  childminder agencies that had potential to improve quality, has been reduced to a tokenism of one visit a year.

In taking this action the government have provided opportunity for yet more inconsistencies between agencies with regard to quality and services.


Question four  (on page 9) Legal requirements for agencies registering with Ofsted

Even less people responded to this question (278) those agreeing and disagreeing were almost the same at 41% and 42% – although there was a larger % of not sure (17%)

Concerns were expressedthat  the draft regulations  were not clear or detailed enough – particularly around moving between agencies and independent  Ofsted registration, about childminder assistants

Concerns were expressed about safeguarding , complaints, child protection  if childminders changed agencies

Concerns were expressed about the quality of agencies and their staff, about inconsistencies between agencies – and about a conflict of interests if providing support and quality assurance. My personal thought about this conflict of interest, is that there is also a conflict as the childminders will be paying for these services and agencies will not want to ‘upset’ their customers.


So what is the Government response to the views expressed for question four legal requirements for agencies registration with Ofsted?

In may not come as a surprise but the Government do not think they need to make ANY changes to the requirements – and will just provide some guidance  – my comments about guidance documents have already been stated.


So that is it, for the part of the consultation that looked at childminder agencies – personally I am very, very disappointed – but sorry to have to say NOT SURPRISED – was there any point in personally spending time completing this consultation? NO


Moving on to Part B that looked at the role of the Local Authority

Question five (on page 11) Anything preventing Local Authorities from meeting duty to secure funded places

258 people responded and views were equal between agree, disagree and not sure

Concerns were expressed about quality and sustainability and what would happen if agency was  judged below good, and therefore impacted on all agency childminders providing EYE.

Concerns about funding childminders in an agency that has not been graded

Concerns about LA not having a support role

So what is the Government response to the views expressed for question five about LA duty to provide sufficient EYE places?

There is some clarification around information sharing – which is welcome – and I hope works in practice. Personally I have found there are nearly always issues around information sharing between organisation – even if only over the amount of time this takes

However basically the Government are confident that the measures there are putting in place are sufficient – despite 2/3rds either disagreeing or not being sure that they are!


Question six (on page 13) Providers for whom may be significant impact

279  responded – the majority thought there would be a negative impact on some providers

The concerns show that most thought that independent childminders would feel a negative impact especially through the loss of LA support

Some thought that higher quality agency childminders could be negatively impacted on, if the agency as a whole was not of high quality / received a low Ofsted judgement

So what is the Government response to the views expressed for question six about impact on providers?

To be honest it is a bit depressing reading it – as the Government do not give any information to suggest that my personal understanding of the draft regulations was incorrect or that they are going to address my personal concerns – or those of others completing the consultation.

In fact for me personally the Governments response has made things worse because there is a line that says LA’s may impose a reasonable charge for services they supply (Information, advice, training. It also states that agency childminders will not have LA support as the agency will provide it.

So – in my personal opinion  this means we could at some point in the future have a situation where only those who can afford support will get it  – both agency childminders and independent childminders – and where does that leave us in terms of safeguarding ?

Dangerous waters – very dangerous waters.

Question seven (on page 15) Groups of children/ parents for whom a significant impact

As with question six, the majority thought that some would be negatively impacted by the proposals – 47% of respondents – which if you add the don’t knows – we have 70% who are not agreeing with the Government (and I acknowledge that the ‘don’t knows – could go either way – but for now they do not agree with the Government) – so surely further consultation is needed?

Concerns were mainly around the issue of quality of the CMA- and therefore the quality of EYE provision and the provision for children with additional needs


So what is the Government response to the views expressed for question seven about impact on children /parents?

To be honest – not sure I understand their response,  as it seems to come under ‘opt out of responsibility’ and pass to others. They talk about high quality but appear unwilling to put in place measures to ensure all children are able to access high quality places – and that something is done if this is not the case

But maybe it is my lack of understanding – so if it is – Please can someone explain

Question eight (on page 16) Practical advice in statutory requirements

It just says over 100 people responded and said they would like greater clarity

So what is the Government response to the views expressed for question eight about practical advice?

Guess what? Yes it will be in the guidance document!

Question nine (on page 17) Is guidance clear about LA statutory duties?

The majority did agree that guidance was clear BUT add together those who disagree and those who don’t know and you have a different picture – because these people add up to slightly more than the agree group – so is more clarification needed

So what is the Government response to the views expressed for question nine about guidance for LA statutory duties?

Oh yes – you are right – further guidance will be provided in the guidance document – welcome but open todifferent  interpretation and implementation



The rest of the Governments response is about creationism as science and extremist views – and I am not going to comment on this in this particular  blog,

Posted August 10, 2014 by psw260259 in My thoughts on current childcare issues

One response to “Response to the consultation on Childminding Agencies and changes to LA role

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  1. You are right Penny, I read this and thought “This is a waste of time filling it in. They have already decided what is happening and this is just a sop to us so they can say they “consulted””

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