Opinion-Editorial on Network Management.
Dr Sarah Alexander.
May 12, 2022.
New regulation for Network Management from February next year will cover home-based services, playcentres, and all teacher-led centres including kindergartens and hospital-based services. The Kōhanga Reo National Trust has requested and been granted an exemption.
A proliferation of ECE services and a decline in child participation led to the government looking at how it can save money by managing provision. There is nothing wrong in that.
But there is no talk yet of a panel of assessors independent of the Ministry and the Minister of Education being formed to assess applications for new services. There is no mention of a Code of Conduct for Ministry of Education decision-making and consequences should it breach the Code.
Decisions by the Ministry of Education and the Minister of Education on who can open a new ECE service and where, risk political bias, showing favouritism toward certain service providers or being swayed by the size of any service provider’s financial investment, and being influenced by other considerations. Other considerations may for example include that a corporation or rich individual has finance to take the minister or ministry to court over non-approval whereas a charitable group or a group of parents wanting to set up a local service are unlikely to do so because they cannot afford to.
A second issue is that while there will be a public register showing approved applications, declined applications will not be listed. This will prevent anyone from knowing before they put time and money into preparing an application if an application for a similar service in the same area has already been declined.
It is concerning for transparency and community participation that there is no plan to publicly notify of submissions so communities can raise any objections before a decision is made.
Services to be excluded are kōhanga reo and the Ministry of Education is also in discussions with the Minister to exclude (a) standalone services where all the curriculum is delivered through te reo and (b) services connected with a peak body (but what does it mean by this?)
The Ministry’s proposed priorities for deciding whether to approve a service application are as follows:
- Māori bilingual and immersion services where te reo Māori is used at least 51% of the time as a medium of instruction (instruction in te reo may be defined as direct teacher-led teaching of te reo, so if little actual ‘instruction’ takes place anyway because a play-based child-led programme is provided than it should be easy for most ECE services to tick this box).
- Hapū/iwi-owned services.
- Services with a distinct Māori identity and culture
- Pacific bilingual and immersion services that may also provide Pacific cultural contexts for early learning (note the priority is early learning and not also education, spiritual development, and care)
- Pacific language and/or cultural services (this covers all those that do not meet the MoE’s definition of being a bilingual service)
- Language immersion services (non-English/Māori/Pacific) where another language is spoken at least 51% of the time.
- Services well equipped for learning support needs (assuming this means health needs and disability needs as well?)
- Services well equipped for migrants and former refugees (would this include long-term migrants and for how long?)
- Services planned to operate on a new school site (why not also include existing school sites where the school itself seeks to set up an ECE service/s?)
- Organisations funded by Targeted Assistance for Participation (TAP) (These are mostly rural, Māori, or Pacifica)
But, the Ministry may still approve an application that does not meet any of the above priorities! Those applying to open a service in areas where there is not a big over-supply of services already (or in areas where population growth is predicted regardless of whether parents would feel comfortable with their child in the proposed service and actually use it as opposed to say a service that is close to work) can be approved without meeting any one of the above proposed priorities.
The Ministry of Education is consulting on which services to exclude from ‘network management’ and priorities for approving applications for new services. Consultation closes at midnight on June, 2nd, 2022. For details and the ministry’s questionnaire, click here.
Let’s Rethink the Network Management Priorities
The purpose of network management according to the Ministry is to “help ensure all children have access to quality early learning settings and prevent unintended consequences of over-supply” (regulatory impact statement, Nov 2021, p. 2)
Then why didn’t the Ministry do its home-work better and detail what it expects a quality early learning setting (or more correctly a quality early childhood education service) to look like and be?
Priorities and conditions
The Ministry could be setting priorities based on service characteristics that enhance child safety – for example, why not encourage applications for services in single storey buildings or ground floor centres only.
Conditions placed on new licences could for example cover microsystem variables of quality such as maximum group size of children with the same teachers consistently placed with the same group of children. Other conditions could cover mesosystem aspects or connections such as that the service actively involves parents as partners in children’s learning, or that services under private ownership must also have a committee of parents with whom management decisions are shared and agreed.
There is a very real chance of hindering progress on the EL Action Plan unless new services are approved only if they are able to meet higher than current regulatory standards on things such as group size, teacher-child ratios, space per child, and having only early childhood trained and qualified teaching staff.
Services that should be allowed to proceed to apply for a licence and not be included in Network Management
In addition to kōhanga reo, services that the Ministry should exclude from network management are:
- Services located on-site in workplaces for employees and owned and operated by the workplace.
- Full language immersion services that are non-English.
- Services using NZ Sign Language as the primary means of communication, including in teaching, caring for children, and social interaction among children and adults.
- Services relying on parent participation as part of the adult-child ratio for at least 50% of opening hours, including Playcentres.
- Services providing early intervention support exclusively for children with high learning, social, and physical needs and their families.
- Services managed by schools and/ or parent committees on existing and new school grounds.
What are your thoughts and suggestions for the Ministry of Education and Minister? A reminder that the Ministry is seeking feedback up to midnight on June, 2nd, 2022. Go to the Ministry’s questionnaire, here.