In Focus

Regulatory Spotlight

Providing a child safe environment 

The approved provider of an education and care service must ensure that the service has in place policies and procedures relating to providing a child safe environment (regulation 168) and that they are kept available and followed (regulations 170-171). As per the Education and Care Services National Regulations 2012.

On the 1 December 2023, changes were introduced to bring closer alignment between the National Principles for Child Safe Organisations and the National Quality Framework (NQF). These changes include:

• The addition of volunteers and students to regulation 84 to ensure they are advised of the existence and application of the current child protection law and understand any obligations held under that law.
• Working with Children details are to be included on volunteer and student records under regulation 149.
• Child Safe Environment policies and procedures include matters relating to the promotion of a culture of child safety and wellbeing and the safe use of online environments as per requirements of regulation 168.
• Complaint handling policies and procedures under regulation 168 include a provision of a system that is child focussed and include matters relating to the management of a complaint that alleges a child is exhibiting harmful sexual behaviours.

For further information, please refer to the Australian Children's Education and Care Quality Authority (ACECQA) website for the Information Sheet - Embedding the National Child Safe Principles.

What else should an approved provider consider including in a child safe environment policy?

• How the nominated supervisor, staff, volunteers and students will be trained to recognise and respond to signs and symptoms of abuse or neglect.
       ▪️   consider what resources will be provided, when you will provide these and how you will ensure the person understands them.
       ▪️   if training is part of the induction process, how regularly thereafter will it be repeated?
• Mandatory reporting obligations (from 1 November in WA for child sexual abuse).
• Clear procedures detailing how to make internal (at the service to a responsible person for example) and external (to the Department of Communities) reports for all abuse types and neglect.
• Record keeping requirements to support child protection which align with the recommendations from the Royal Commission into Institutional Responses to Child Sexual Abuse. It is recommended:
       ▪️   records related to child sexual abuse (has or is alleged to have occurred) are kept for 45 years.
       ▪️   records are clear, objective and thorough, maintained in an indexed and secure manner and retained and disposed of in a consistent manner.
• Supervision – how the service will ensure adequate supervision of all children at all times. This may include the use of risk assessments, training, plans, headcounts etc.

What can you do to contribute to a child safe environment?

Approved providers, nominated supervisors and responsible persons:

Ensure the team understands and implements the service’s policies and procedures, to provide a child safe environment.

Regularly communicate about the service’s commitment and collective responsibility for child safety.

Consider how recruitment strategies and induction processes ensure all staff understand what is expected of them in providing a child safe environment.

Use the Child Safe Organisations Knowledge Hub resources to implement the national principles for child safe organisations.

Provide regular training on child protection including recognising and responding to abuse or neglect, mandatory reporting, child safe practice and cultural safety.

Support the implementation of a Protective Behaviours program across your service and provide families with access to this program.

Ensure complaints handling policies and procedures are accessible and available in a variety of formats.  

Educators:

Actively engage in reviews of your service’s policies and procedures and consider them from a child safe perspective. If you don’t understand the requirements, say something to your manager.

Stay up-to-date and informed about your role and your mandatory reporting requirements. Mandatory reporting guide Western Australia.

Embed the intentional teaching of Protective Behaviours in the program across all ages.

If you have concerns about a child’s safety, talk to your manager. If you can’t talk to your manager or supervisor, or you are concerned inadequate action has been taken in response to your concerns, contact the Department of Communities through the Central Intake Team on 1800 273 889 for further guidance.

Quality in Focus  

Unpacking Theme 2

Practice is informed by critical reflection

Am I reflecting or critically reflecting?

Reflection involves educators thinking intentionally about their own and others’ practices, with certain aims or goals in mind.

Critical reflection is:

• a meaning-making process that involves a deeper level of thinking and evaluation.
• It requires engagement with diverse perspectives such as philosophy, theory, ethics and practice and then evaluating these in context, leading to pedagogical decisions and actions that are transformative.

As professionals, educators collaboratively explore, identify and evaluate diverse perspectives with respect to their own settings and contexts. In this way, critical reflection informs future practice (The Early Years Learning Framework (EYLF) and My Time Our Place (MTOP) V2.0).

At the Exceeding level for any Standard, members of the service team must engage in ongoing critical reflection on their practice and decision making as appropriate for their role and responsibilities within the service.

Ask what, where, how, when and why questions:

• why do we do what we do in this way?
• where does our current thinking come from?
• what does the latest research or best practice guidance say about this?
• when was the last time we considered other information, perspectives, etc?
• how does this practice contribute to improved outcomes for all children and families? Or are we disadvantaging some?

Those engaged in critical reflection should:

• consider the theoretical perspectives underpinning their actions and decision-making
• seek different views and opinions and are open to exploring possibilities that they may not have previously considered
• draw on various sources of knowledge and research evidence, and evaluate these sources for their credibility and relevance as well as their ‘fit’ to the context of the service
• consider the rationale behind new ideas and practices to assess if they align with the approved learning framework and the philosophy of the service.

When can you critically reflect?

1. reflect-on-action (i.e., past experience)
2. reflect-in-action (i.e., as an incident happens)
3. reflect-for-action (i.e., actions you may wish to take in future)

Examples of questions authorised officers may use to establish Exceeding Theme 2

1. How is the service critically reflecting on this Standard?

You should consider how you will articulate your critical reflection, how this will be demonstrated in practice and what documentary evidence you have to support this.

2. Who is involved in the critical reflection and how has their knowledge, perspectives and views been considered?

3. Have you considered current research evidence and best practice guidance? If so how and why, and what was the outcome?

4. Have you considered theorists, service philosophy and the Approved Learning Framework? If so how and why, and what was the outcome?

5. Can you share some examples of where and how your practices link back to critical reflection?

Tip: consider how you can provide information from these types of questions in your Quality Improvement Plan within the exceeding theme for the standard. This will enable the officer to plan how they might verify the information via practice observation, targeted questioning and sighting supporting evidence, saving much time at the visit searching for and unpacking potential evidence.

Exceeding case study from Standard 3.1

The design of the facilities is appropriate for the operation of a service.

A 62-place long day care located in metropolitan Perth was recently awarded exceeding for standard 3.1. At the time of the visit the service had just completed a redesign of the entire service. The project was managed by the approved provider who developed a vision created by staff, educators, children, families, and community members. The design was underpinned by the service’s philosophy, including the Reggio Emilia approach and the Early Years Learning Framework, but the most important element was ‘to create an inclusive space where all children could lead their own learning through interactions with nature, materials and each other’. 

Critical reflection occurred at all stages of the project and included:

• Unpacking the service philosophy and the early years learning framework (EYLF) to deeply understand how the design of the service is, or should be underpinned by these guiding documents.
• Focus on research into the importance of nature play and the Reggio Emilia approach where the environment is viewed as the third teacher.
• Engagement with Nature Play WA and their research.
• Engagement with a Director of ECEC services in New Zealand renowned for her work emphasizing the value of natural outdoor environments for language development.
• Work with an occupational therapist during the design process based on the development needs of children to prioritise the inclusion of all children, including wheelchair access and sensory spaces/equipment.
• Consideration of Australian Early Development Census (AEDC) data to identify developmental risks/vulnerabilities to consider how the environments could be adapted to enhance opportunities in physical health and wellbeing, social competence and language and cognitive skills.
• Consultation with children and families regarding how they would like the environments to look and feel. This included capturing children’s voices when reviewing concept plans and getting the children to create their own concept drawings.
• Completion of a Kidsafe audit to critically reflect on safety considerations including supervision.
• Materials used align with philosophy but were also considered from a cost, safety and maintenance perspective.

Educators and staff continue to critically reflect on the effectiveness of the design to find ways to enhance their practice and outcomes for children. All educators were aware of the theoretical influences on the design and how these align with the EYLF and service philosophy. A trainee educator explained to the assessment officer how an area in the kindy room outdoor space was designed by an occupational therapist in collaboration with the kindy staff to accommodate a space for children who need help to co-regulate. During the visit, educators, including the trainee educator, were observed supporting children to access this space and use the basket swing.

What can you take away from this?

Whether you are designing a new service, planning some renovations, or simply critically reflecting on your existing design you can use some of the critical reflection prompts engaged by this service to drive a thorough, meaningful process. It may not necessarily result in any design changes, but it might just reinforce at a deeper level why your current choices are the best possible choice for your service to enhance outcomes for children.

*The identity of the service has been withheld based on their request.

Annual Fees – Frequently Asked Questions

1.  How do I log in to view my invoice?
Following the recent upgrade of the National Quality Agenda (NQA) IT System, providers are required to re-register their existing provider approval on the portal. Register and login.

2.  Where can I find unpaid invoices in the portal? 
Please visit the ‘ACECQA National Quality Agenda IT System - Invoices’ for information on work with invoices. 

3.  What can I do if my screen doesn’t show the invoices search tab? 
Contact your provider to check your level of access.  

4.  Do I still need to pay the annual fees invoice if the service is under voluntary suspension?
Yes, as an approved provider you are required to pay an annual fee for each service approval held, including those services that are suspended. This is set out in section 53 of the Education and Care Services National Law (WA) Act 2012.

5.  Can I pay an invoice over the phone using credit card details?
No, credit card payments over the phone are not accepted. Please proceed with payment through the National Quality Agenda IT System (NQA ITS) portal.

6.  What can I do if I can’t find the email with the link to pay the annual fee invoice?
You still can access the unpaid invoices via invoice search for unpaid invoices in the NQA ITS portal. Please refer to question 2 for further guidance.

7.  Where can I find a breakdown of the annual fees for centre-based services and family day care? 
Please visit ACECQA’s webpage Indexed fees | ACECQA  2024-2025.

Revised checklists are now available to the sector

Authorised officers have begun using revised compliance checklists during unannounced visits. These are now available on the ECRU website for services to access and use as a self-auditing tool or to simply review to know what to expect at a compliance monitoring visit.

Mandatory Reporting Training

Communities are continuing with the roll out of mandatory reporting training (face-to-face/webinar) for early childhood workers. Please review the upcoming sessions via Eventbrite to register.

The training will be delivered by Communities Mandatory Reporting Service and Education and Care Regulatory Unit. This training is an alternative to the online course and will broadly cover the same content, however these sessions are a great opportunity to learn with your colleagues and ask questions.

You can read more about Mandatory Reporting in Western Australia and access an online course that is available for all mandatory reporters.

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