February, 2014

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Dear Minister Sandals,

The AECEO is the professional association for early childhood educators in Ontario. As it is our mission to act on behalf of Ontario’s registered early childhood educators (RECEs) our response to your request for feedback on the Proposal to Amend Regulation 262 will therefore focus on issues of particular concern to RECE professionals.

It is our recommendation that a full, comprehensive and holistic policy development process, one which encompasses the workforce, be undertaken before any regulation changes are decided on or implemented. The revision process must include community engagement and research based decision making. 

That said; there are specific concerns around quality and safety that have emerged for RECEs.

Changes to Adult: Child Ratios

The current proposals work to reduce the proportion of professional staff working in programs serving the youngest children and we believe, at the very least, will lead to institutionalized care for children with no educational component. 

Additionally, RECEs across Ontario are very concerned about the capacity of staff to keep children safe under the new ratios. The changes may save money, but this should not, and must not, be allowed to trump safety and at the very least what must be in place is for Ontario to guarantee the safety of Ontario’s children.

A new DNA must reflect a policy of “quality early childhood learning and care” supported by adequate public funding as opposed to a policy of minimum standards operating within a market approach to child care services. Ontario’s early childhood educators are committed to providing high quality learning and care environments for young children.

We suggest that changes to ratios and group size must be considered within the context of other policy elements — early childhood professional education, pedagogy, facility considerations, safety and financing—that is, within a full policy process with a goal of real transformation. 

Human Resources Strategy

The 2007 report of the Ontario Ministry of Children and Youth Services Expert Panel on Quality and Human Resources identified the following four critical “building blocks” for creating a province-wide system of quality child care service:

1. Effective policies, sustained funding and appropriate infrastructure
2. Properly paid, registered and committed educators
3. Evidence-informed age appropriate programs and practices
4. Parents who are partners in their children’s early learning (p.8)

The AECEO maintains that without adequate staffing by well-trained registered early childhood educators, a quality early childhood system cannot be built and stabilized in Ontario.  A coordinated human resources plan with well-articulated short, mid and long term goals will ensure that Ontario has a knowledgeable and appropriately compensated ECE workforce necessary to support the development of quality programs. The implementation of a human resources plan as part of a modernized child care system will attract and retain trained and committed professionals and significantly improve program quality.

Reducing the number of RECEs in the ratio setting disregards decades of research and evidence on brain development and the need to have individuals with very specific knowledge and training who can translate this research into practice.  It is an omission to not recognize educational qualifications as an aspect of quality.

Furthermore, the implications of having fewer qualified staff members, who are required by their regulatory body to adhere to professional standards, will put RECEs in a conflict with their employers and with the Code of Ethics and Standards of Practice

You cannot have quality early childhood education without a registered early childhood educator staff team. From an AECEO perspective, all staff in the room should be registered early childhood educators.

Over the last 60 plus years, AECEO’s members have worked with the provincial government, municipalities, service managers, and families to build a child care system in Ontario. These professionals have adapted and innovated to meet the growing child care needs of families and children and to respond to new research and ideas in early childhood education. Early childhood educators in Ontario remain today a committed workforce who want a modernized child care system and who want to work with the Ministry of Education on its implementation.

Indeed, modernization of child care in Ontario will be driven on the ground by dedicated early childhood educators

Only through a full and complete policy development process will early learning and child care be transformed into the accessible high quality program envisioned in your ministry’s Modernization paper.

On December 2, 2014, Bill 10, the Child Care Modernization Act, 2014, passed third reading in the Ontario legislature.

The legislation will strengthen oversight of the province's unlicensed child care sector and increase access to licensed child care options for families. In addition, it will allow the province to immediately shut down a child care provider when a child's safety is at risk.

The Child Care Modernization Act also:

• Gives the province the authority to issue administrative penalties of up to $100,000 per infraction by a child care provider.
• Increases the maximum penalty for illegal offences under the act from $2,000 to $250,000.
• Increases the number of children a licensed home-based child care provider can care for from five to six.
• Clarifies what programs and activities are exempt from licensing requirements, including care provided by relatives, babysitters, nannies and camps that provide programs for school-age children.
• Requires all private schools that care for more than five children under the age of four to be licensed as a child care centre.
• Amends the Education Act to ensure school boards offer before- and after-school programs for 6 to12 year-olds where there is sufficient demand.

The government of Ontario announced the release of new legislation that addresses the modernization of child care.