Consultation on Proposed Annual Registration Fees and Post Registration Training and Learning (PRTL) Requirements for Early Education and Child Care Workers

Do you support the proposed fee levels for early education and child care workers?

Yes √ No

If YES, please provide any comments you wish to make on the proposed fee levels.

SPPA accepts in principle the need for a fee to be charged as an annual registration fee and that the proposed initial registration fee is in general set at a reasonable level. However, this acceptance of the proposal is tempered by the following:

There is a lack of clarity in paragraphs 4.2 and 4.3. It is not clear whether workers pay an initial registration fee, plus the additional cost for an Enhanced Disclosure, and pay for re-registration after five years without any intervening payments. Or whether workers pay an initial registration fee and an annual fee thereafter, with the additional cost for Disclosure occurring every five years when they are required to re-apply to the register.

SPPA would like to emphasise that a large proportion of voluntary sector early years and childcare workers are in sessional, low paid work environments. Many in such positions will find it difficult to pay an annual registration fee. It is likely that some in the workforce would not be able to make a claim against tax.

No account has been taken of the amount an individual earns nor does it appear that any pro rata payments have been considered for workers who may only be paid for term time or supply work, but who will still have to be registered.

It is good to read that the Scottish Executive is subsidising the cost of registration fees in the initial stages but SPPA is concerned about the level to which fees might rise when the subsidy ceases. Future level of fees must take account of the workers ability to pay and be commensurate with the level of salary they receive.

Many small voluntary sector employers have felt pressured to pay regulatory fees for their employees, for example, for Disclosure checks, because they feel they cannot ask a low paid employee to pay it themselves. Unless pay and status in the sector is addressed this is likely to continue, adding an ever increasing burden on already stretched budgets for small voluntary sector providers. A consequence of this could be decisions taken by some providers either to close or to deregister thereby nullifying the need for their workforce to qualify and to be registered with SSSC.

Staff in early years and childcare settings who hold childcare positions will already have an Enhanced Disclosure, many of which will have been paid for by the employer. The cost of seeking another Disclosure check is likely again to fall on the employer thereby adding another financial burden on limited financial capacity.

Many professional registration schemes offer the registrants something in return, access to CPD opportunities, legal advice, regular communication etc. It is not clear what the SSSC is offering the individual in return for their payment other than establishing suitability to work in an early years and child care setting.

No rationale is given to explain the £10 difference between the registration fee for a manager/lead practitioner in an early education and childcare setting and a supervisor in an adult residential care setting. What is the basis for this distinction? It could be said to be unfair that a manager/lead practitioner must pay more for registration than his/her counterpart in adult residential care settings.

Concern has been expressed within SPPA that registration may result in voluntary sector workers, particularly older, experienced workers, being lost to the early years and childcare workforce because they are unwilling to do a qualification and become registered. The requirement for registration may have an adverse effect on the retention of staff in voluntary sector provision.

Do you support the proposed PRTL requirements for early education and child care workers?

Yes √ No

If YES, please provide any comments you wish to make on the proposed PRTL requirements.

SPPA welcomes the range and flexibility of opportunities for PRTL and the amount and timescales involved offer reasonable scope for workers and employers to identify and plan learning and development opportunities to meet the requirements of re-registration. However, it has to be born in mind that a large proportion of voluntary sector early years and childcare workers are sessional/term time workers. It is not clear from the proposal whether they are expected to complete 10 days PRTL or whether there is a pro rata requirement commensurate with the hours and days they work.

On behalf of Scottish Pre-school Play Association

Margaret Brunton

Senior Development Officer

Email: margaret.brunton@sppa.org.uk