Submission on 80% ECE Qualified or School Qualified Teachers and the Person Responsible Requirement

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Toddler in a highchair eating and teacher holding an infant in lunch-room.

Regulation Changes on Recognised Qualifications for Teaching in ECE.
October 22, 2021.

Current regulations

Under current regulations, for staff to be counted as qualified teachers in teacher-led services they must hold a recognised ECE qualification.

recognised qualification means, —in relation to a licensed service recognised as a teacher led service (as defined in regulation 44(4)) and the requirement under regulation 44(1)(a) and item 2 of Schedule 1 that 50% of required staff must hold a recognised qualification, an early childhood teaching qualification recognised by the Teaching Council of Aotearoa New Zealand for registration purposes.

What is happening?

The Ministry of Education has signalled interest in making the qualification of primary school teaching a legally recognised qualification for teaching and caring for infants and toddlers in a licensed early childcare and education service.

It intends implementing either one of the following options.

Option 1: Regulate for 50% ECE teachers and 30% primary school teachers. This would be for the purpose of licensing only, so children can still be in a centre with no ECE qualified teacher present.

Option 2: Regulate for 80% ‘teachers’ who may all be primary school trained, in centres on average over a 4-month period.

Option 3: 50% ECE qualified teachers in centres when children are present. (This is the better option to preserve ECE training as providing the basis for recognised qualifications – but at only 50% Option 3 falls short of the plan to regulate for 80%)

What else you need to know

Parliament’s Regulation Review Committee tasked the Ministry to improve the Person Responsible regulation, but the Ministry has not consulted specifically on the qualification recognised for a Person Responsible. (You may remember that at the end of 2019 the Minister of Education had promised Cabinet that allowing people who were not ECE trained but were trained to teach the primary school curriculum in a school setting with older children to be a Person Responsible in an ECE centre would be a temporary allowance. The allowance was made at the time for political reasons, without evidence).

Our submission

Implications of the Ministry’s proposed options 1 and 2

Since primary school teachers are as well trained as secondary school teachers, pilots, and qualified baristas to work with under-5s and their parents in ECE settings, the change proposed by the Ministry of Education will support arguments in future to enable other qualifications that are not in ECE to be recognised. 

This might be a good thing if for example, it means the valuing of staff who have training and skills in child health, such as Plunket Nurses.

But recognising primary school teacher training, or any other professional qualifications not related to infants and young children, as an adequate replacement for, or even equivalent to early childhood teacher training goes directly against the knowledge base on what is best for quality for children.

The research literature is clear on this – to deliver better outcomes for children, the adults providing non-parental care and education must be well educated, and skilled with qualifications directly relevant to early childhood. 

It also goes against a strong background of political advocacy for recognition of early childhood teacher training and qualifications.  Examples of advocacy include:

  • Pathways to the Future/Ngā Huarahi Arataki, the 10-year plan for early childhood had as one of its key goals to lift the proportion of teachers holding an ECE recognised diploma or degree and teacher registration. 
  • The Office of the Children’s Commissioner inquiry (2011) into the standard of education and care of infants and toddlers found that “teachers understood the rationale for well-educated and knowledgeable staff that held early childhood qualifications and the necessary skills for working with infants and toddlers. Some reported examples of ECS that were reducing professional development for their staff and when qualified teachers left, they were being replaced by untrained staff” (p. 157).  It recommended policies mitigate the risks that arise for infants and toddlers from their vulnerability and stage of development through ensuring they have staff who are knowledgeable and skilled in early childhood teaching.

Given these implications:

Do you think it is right that the Ministry is sneaking in a change in regulation in the definition of recognised qualifications for staff in teacher-led services to include primary school teacher qualifications under proposals for regulating for 80% qualified teachers? 

Do you think the Ministry of Education should be treating primary school teacher training as appropriate training for staff working with children from birth to 5 years and their parents and caregivers, and not require non-ECE trained teachers to upgrade their qualification to ECE? 

So what can you do?

Quickly send an email to the Ministry of Education, email: earlylearning.regulatoryreview@education.govt.nz

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