Consultation response: School age childcare: a new legal definition

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Please give a reason for your answer:

We acknowledge that we have been directly involved in consideration of the future regulation of school age childcare services, including the recent feasibility study conducted jointly with the Scottish Government, and continue to discuss progression of the work with Government.

We consider it important that the definition has the primary purpose of care. This will distinguish the difference between school age childcare (SACC) services that provide an element of care and those that are activity based, for example, play schemes. In our experience, play provision may involve an element of care, however, this could be measured through factual questions about the primary purpose alongside regulation. We would use our quality improvement framework with quality indicators to measure the quality of play and children’s experiences.

Please suggest an age range and your reasons for this:

In thinking about the age range, consideration needs to be given to the situation where some children may not be attending school at the age of four or five. Children can be deferred for a wide variety of reasons, including children with additional support needs (ASN). Rather than specifying an age range, consideration could be given to wording that encompasses what families need.

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Please give reasons for your answer. If you have suggested that the hours should be increased or reduced, please say by how much:

We would suggest that if aiming to meet the needs of working families, SACC services need to be accessible to cover working hours. In our experience, some providers provide breakfast clubs or cover for in-service days and school holidays.

The times services are operational can also vary, and those operating under the two-hour time frame are not required to register with the Care Inspectorate. Exemption to regulation in any instance could compromise the quality of experience and the safety and wellbeing of children and young people.

Furthermore, lack of focus on the quality of staffing could result in children and young people not being protected due to a lack of skills and experience. Finally, we would caution that qualified staff may opt to move to other parts of the sector

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Please provide more details. If you would need extra information before you can answer this question please tell us what you would need to know.:

We note that there would be a potential additional cost should a service need to register each part of the service separately. In addition, any difference in staff qualifications could create challenges. For instance, staff deployment across the setting should staff hold different qualifications.

Please provide further details about the examples or case studies and where we can access them:

Consideration could be given to the Scottish Football Association Extra Time programme and examining the outcomes and lessons learned.

Please provide further details about the data sources and the type of information they contain.:

We would suggest that consideration could be given to the data held by the Care Inspectorate around enforcement, requirements or low evaluations.

Please provide more information.:

As we understand it, SACC services do not see themselves as daycare of children services (or early learning and childcare (ELC)). Expectations for an ELC setting refers to much younger children, with an emphasis on care, play, and learning. SACC services may have children aged five and over and may not have an ‘education’ element. In our experience, SACC services may have a stronger emphasis on play, friendships, social skills and relationships. If there is a change in definition, this could result in different levels of qualifications required for the role. Consideration should be given to any potential impact on ELC services as a result.