Children and Families Bill

Memorandum submitted by Carol Innes (CF 58)


1. I have been a Registered Childminder since 1994 (other than a short break when we moved house) and have Level 3 three qualifications in Children's Care, Learning and Development and also in Playwork and Beach School. I was graded outstanding at my most recent Ofsted inspection, in 2011. I have been approved as part of a Quality Assurance Childminding Network and am accredited to provide funded education for three- and four-year-olds and funded places for vulnerable two-year-olds. I undertake regular training to update skills and knowledge in areas such as First Aid and Safeguarding Children, and to develop my understanding of different methods of working which will enrich the children's time with me and improve the way I help them to develop.

2. I am very concerned about Section 4 of the Children and Families Bill (and related schedules), in particular the proposed introduction of Childminder Agencies. I consider that Childminding Agencies are likely to be bad for children and bad for Childminders. There is very little information at present about how these agencies would work. However, the more I consider them the less it appears that this issue has been thought through.

3. Business Issues I understand that some Childminders registered with agencies may be employed, whilst others may be self-employed. Either option raises a number of business issues:

3.1 Tax, accounts, allowable expenses, minimum wage, payment for hours available but children not placed; holiday and sick pay, pensions; payment for time spent training (Childminders currently are mainly unpaid during training, but this could be an issue if they were employed by an agency).

3.2 Would training be free or could your agency charge what they like? This could be a particular issue in relation to mandatory training such as first aid?).

3.3 Would the agency act as Special Educational Needs co-ordinator and Safeguarding co-ordinator? Who would report concerns and make judgements regarding level of concern and any risk to child? What about self-evaluation forms; Criminal Records Bureau checks (children becoming 16, new people living in house)?

3.4 The Bill suggests that if an agency fails for any reason then the Childminders concerned would become registered directly with Ofsted as an interim measure. However, whilst this would allow continuity for the Childminder and children concerned, I understand that the Agency would have been providing insurance and training. What then happens regarding insurance for those Childminders and essential training such as First Aid? Also, would contracts with parents be with the Agency? In which case the Childminder could have difficulty getting payments – especially if parents paid by direct debit or vouchers etc.

3.5 ‘More Great Childcare’ says that Childminder Agencies would take on administrative tasks such as arranging insurance and paying registration fees! Undertaking these small tasks once a year takes next to no time. The paperwork which takes the time are the children's records (because unlike school staff we do not have paid non-contact time), but personally I enjoy doing these and agencies could not do them because they would have no knowledge of the children's development. Other paperwork which has taken up a lot of time in the last 12 months has been due to commenting on proposed changes, eg to the EYFS and now this Bill, and getting used to new statutory requirements and developmental goals, having just become familiar with the original EYFS!

4. Costs, Fees and Quality 'More Good Childcare' was supposed to be about raising quality and giving parents more choice! I do not see these proposals doing either, nor do I see them reducing costs.

4.1 Options for the agency to make their profits (other than charging for training/other 'services provided') would appear to be by charging parents, or by taking a slice of Childminders' fees, neither of which would meet the government's stated aim of reducing the cost of childcare.

4.2 Will the agencies perhaps insist on 'their' Childminders taking children up to the maximum ratios in order to maximise profits? (In company with many other experienced childcarers I strongly disagree with the changes to ratios proposed in ‘More Great Childcare’ but appreciate that this is not part of the Children and Families Bill.)

4.3 Childhood is a precious time and young children need individual attention to allow them the best experiences. I will maintain my current ratios but have big concerns about some childcare settings/agencies who may be more interested in maximising profits.

4.4 Currently Childminders may be satisfactory, good or outstanding. If an agency requires all its Childminders to meet the kind of standards to be good or outstanding this could be good for quality. However, if they wanted more Childminders on their books they would no doubt relax their quality requirements and be happy with satisfactory. Would they pay all Childminders the same, regardless of standards? How would this affect provision of funded places? This could drive quality down.

4.5 If only the agency and a sample of Childminders are inspected this will not tell parents anything about the quality of care in each individual Childminder's setting. It would presumably give some sort of 'average' grading. Personally I do not aim to provide an 'average' Childminding service; I aim to provide an outstanding service for the children I mind, and their parents, with high quality, individualised care.

4.6 The children in this country deserve the very best childcare and research shows that high quality care with an individual Childminder meets the needs of very young children better than group settings can hope to do. The government should be encouraging Childminders to continue to deliver this high quality care, not demoralising those who meet the highest standards or encouraging those who may have lower standards to care for too many children.

5. Other Effects on Children

5.1 Ms Truss suggests that when Childminders are ill/on holiday the agency would place the children with another Childminder. This may help the parents, if they are happy for their child to be cared for by someone they don't know, possibly (in a rural area like ours) several miles away from usual. How would the individual needs of these children be understood and met on such an ad-hoc basis? When I take on a new child I arrange a gradual settling-in process to meet the needs and personality of each particular child. To dump a young child with a carer they do not know could cause horrendous trauma.

5.2 How much choice would parents have regarding which Childminder their child was placed with? Choosing who cares for your children is a very important and individual thing and it is vital that parents and Childminder, as well as the child, feel comfortable with each other.

5.3 As mentioned above, I currently offer the Early Years Entitlement of Funded Education and funded places for two-year-olds. It is unclear how these will be offered if Childminder agencies go ahead. Very young children are better off in small settings. High quality Childminders develop excellent relationships with the children and their parents and provide individualised care, with resources and activities in line with the children's own interests and to encourage their development. Indeed a study (The early Education Pilot for Two Year Old Children: Age Five Follow-up) recently carried out for the Department for Education has apparently found that "comparing children in the pilot group who attended high quality settings with those who attended adequate or low quality settings found that the high quality group 'scored significantly higher' in the communication, language and literacy and creative development early learning goals." and "the report says, 'This provides some evidence that high quality settings made a positive difference to children who attended the pilot.'" [Gaunt, Nursery World, 7 March 2013]

6. I understand that, at present, the plan is to allow Childminders to choose to remain independent and this is the option I will definitely choose. However, there are still many concerns regarding this, eg will we still be able to access training from the local authority? Will we eventually be forced into agencies or out of the profession? Will Annual Registration Fees be increased and will there be any additional fees for individual inspections? I currently charge parents £3.20 per hour per child (inclusive of food, drinks, outings and all other resources) during term time; £3.50 per hour during school holidays. East Yorkshire is not a 'high fee' area for childcare, and I live in a very rural area. I do not make a large profit. My 'outstanding' Ofsted grading was the result of a great deal of hard work over the years to improve the Childminding service I offer to parents and to the children I care for. I am proud of my outstanding grade and of the quality of my Childminding provision. I have expended a great deal to achieve this: time, money, and effort, putting new resources into place and designing/writing all the paperwork, training, reflecting, planning and implementing changes to ensure I go beyond the minimum requirements of the Early Years Foundation Stage. I know a number of other Childminders in this area who have similar standards and across the country there is a big proportion of high quality Childminders who are feeling very threatened by this issue. Please remove the ill-thought-out proposal of Childminder agencies from this Bill.

Thank you for taking the time to read my comments

Yours faithfully

Carol E Innes

Registered Childminder

A summary is included on the next page


1. I am an experienced, qualified Registered Childminder judged outstanding by Ofsted.

2. I have grave concerns about the proposal to introduce Childminder agencies.

3. The many business issues do not appear to have been thought through.

4. Costs, Fees and Quality: Proposed agencies seem unlikely to raise quality, give parents more choice or reduce costs. I am concerned that agencies may want childminders to work to maximum ratios in order to maximise profits. Agencies may have a detrimental e ffect on quality. Concerns regarding Ofsted inspection of the agency and not inspecting all the settings. Need for high quality care for our children.

5. Other Effects on Children: concerns about placing children with people they don’t know; parental choice and relationship of child with Childminder; need for individualised care. High quality settings (as opposed to adequate/satisfactory settings) make a difference to outcomes for children.

6. I am very concerned about my own business, which currently provides high quality childcare for young children. I request that the proposal for Childminder agencies be removed from the Bill.

March 2013

Prepared 22nd March 2013