AECEO Submission on proposed regulatory amendments to the CCEYA

In responding to the consultation on the proposed regulatory changes to the Child Care and Early Years Act
(CCEYA), the AECEO consulted with our members and the early learning and child care (ELCC) sector to
raise the voice of ECEs, early years staff, and families and address specific areas of concern identified by the
profession.

The AECEO recommends the Ministry of Education:

  • Does not proceed with the following proposed regulatory changes:

o A1. Schedule 2 – Requirements for Age Groupings, Ratios, Maximum Group Size, and
Proportion of Qualified Staff;
o A3. Authorized Recreational and Skill Build Programs;
o B1. Qualified Employees;
o B2. Short-Term Supply Staff; and
o B3. Qualification Requirements for Child Care Centre Supervisors

  • Abandon the consideration of an registry of unlicensed home child care providers

Instead, we reassert the following recommendations from the consultation period which were not reflected in
the current regulatory posting. The Ministry of Education should:

  • Ensure professional pay and decent work for early childhood educators by enshrining in legislation a
    provincial wage scale, a mechanism for ongoing consultation with the EC workforce, an Early
    Childhood Workforce Learning Framework, and enhanced staff:child ratios.
  • Rethink quality by embedding relational and ethical understandings of quality into legislation and
    increasing the required number of qualified staff in ELCC programs.
  • Ensure access to culturally relevant pedagogy and programming by legislating recognition and respect
    for local and cultural knowledge and pedagogy and ensuring appropriate funding and authority to First
    Nations, Inuit and Metis and Francophone communities and programs.
  • Begin to address systemic Anti-Black racism through legislated pre-service and in-service education,
    anti-racist policies and practice, and a further review of the CCEYA through an Anti-Racist lens as
    recommended by the Community of Black ECEs.
  • Develop a comprehensive, interdisciplinary inclusion strategy that adopts the policy recommendations
    of the Inclusive Early Childhood Service System Project.
  • Implement base-funding to licensed centre-based care and home child care agencies and introduce a
    moratorium on new for-profit development as a first step towards a universal child care system.2

The position of the AECEO is informed by consultation with our members and the ECEC sector, facilitated
through meetings, email responses, and a community survey of over 2400 educators and families.

Click HERE to read our full submission.