Chapter 5 - Impact of Child Care Funding Changes on Families and Children

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Chapter 5 - Impact of Child Care Funding Changes on Families and Children

5.1 The impacts on families, in particular on their ability to pay for child care services, are discussed in this Chapter. For children, evidence pointed to changes in the quality of care provided and changes in arrangements made by parents as a result of affordability issues as the major impacts. The particular problems of providing child care in remote and rural Australia and for disadvantaged children and children with disabilities are also discussed.

Impact on families

5.2 Anecdotal evidence, both from parents and from providers of services, pointed to a range of impacts on families as a result of changes to child care funding. These included:

5.3 The majority of these impacts relate to affordability issues. Many witnesses stated that the most significant impact on families of the changes to funding was on their ability to afford child care. It was generally considered that child care was now more expensive for families because of fee increases in the absence of increases in Government child care support for families. As a result, fewer families were able to afford child care and were removing children from formal care. The Queensland Child Care Coalition (QCCC) survey, for example, indicated that the reason for 21 per cent of the children removed from care in the survey group between 1 July and 30 November 1997, was that care was cheaper elsewhere. This was an increase from 13.5 per cent in the preceding six months. [3]

5.4 It was also asserted that a decline in affordability had hit those on low incomes the hardest, particularly those with more than one child. [4] Mission Australia, for example, stated that some low-income families are now paying a third of their income in child care costs. [5] The SDA, which had supported the removal of the operational subsidy from community-based centres, noted that:

5.5 The affordability of child care for families depends on fees charged for child care services and the capacity of families to pay. The fees charged reflect the underlying cost structures of child care providers (the impact of changes to child care funding on providers has been discussed in Chapter 4). The capacity of families to pay for child care is dependent on their income and assistance provided by government as well as the number of children in care and the hours of care required.

5.6 Government assistance to families is provided through Childcare Assistance and the Childcare Rebate. Childcare Assistance is provided at the maximum rate of 83.04 per cent of a set `ceiling fee' for one child. Higher rates apply when a family has more than one child in care. The ceiling is currently $115 for 50 hours of care a week or $2.30 per hour. Families with one child in full-time care who are eligible for maximum Childcare Assistance pay a minimum of $19.50 [7] (the ceiling fee less 83.04 per cent) plus the `gap fee' (the difference between the ceiling fee and the amount charged by the service provider). Families eligible for partial Childcare Assistance pay the minimum fee plus the `gap fee' plus some portion of the difference between these two, depending on their income level. As at 1 July 1998, a family with one child and an annual income of up to $27,196 per annum will be eligible for maximum Childcare Assistance. The threshold increases by $4,415 per annum for every dependent child under 13 years of age if the family has been assessed as eligible for more than the minimum rate of Family Allowance. [8] There are currently 118,000 families on maximum Childcare Assistance. From 1995 to 1997, the number of families on maximum Childcare Assistance increased from 44 per cent to 47 per cent. [9]

5.7 The Childcare Rebate is paid at two rates, 30 per cent if family income is $70,000 or less for one child in care and 20 per cent for incomes greater than $70,000 for one child in care. Families must pay the first $19.50 of child care costs with the rebate being available for the remainder up to the maximum amount of $28.65 for those on the 30 per cent rate and $19.10 for the 20 per cent rate.

5.8 The changes announced in 1996 were directed at restricting the growth of Government outlays for these two forms of assistance by:

These three measures were expected to result in savings of around $73 million in 1997-98. [10]

5.9 Witnesses also noted that the reduction of the Childcare Rebate from 30 per cent to 20 per cent would impact on those families earning over $70,000. The 20 hour limit for non-work related care also had an impact on affordability for those parents not working.

5.10 Concern was raised that the Childcare Assistance ceiling has remained at $115 per week for two years. This level was seen as increasingly unrealistically low when fee increases have occurred over the last two years and will continue to occur. It now means that the maximum possible combined amount that a family could receive from these two forms of assistance is $124.15 per week for one child regardless of how high the fee is that is paid. For families with one child in care based on the average centre based fee of $155.00, the maximum amount received is $107.50, a gap of $42.50 (as at August 1997). [11]

5.11 Witnesses also noted that the impact of the freezing of the ceiling was exacerbated by the abolition of the $30 disregard when assessing family entitlement to Childcare Assistance. This has resulted in increased contributions by many families, with low-income families more greatly affected, as their dependency on Childcare Assistance is the greatest. [12] An example provided to the Committee was the case of a father of five children. Because of the abolition of the $30 disregard, the `fee assistance percentage went from 32.48% down to 8.42%. In dollar terms over 5 days of care per week, his fees increased from $112.70 pw to $140.30, an increase of $27.60 pw or $1,435.20 per annum'. [13]

5.12 The Department commented that the removal of the disregard aligns the Childcare Assistance income assessment process with Family Payment and allows simpler income testing for Childcare Assistance. Further, since it was originally introduced there have been significant improvements in other forms of Government assistance to families. Most low-income families receiving maximum Childcare Assistance (around 60 per cent of Childcare Assistance families or 46 per cent of all families using Commonwealth funded long day care) were not affected by the removal of the income disregard. [14] The NSW Government, however, indicated that 60 per cent of families were affected to some degree by this change. [15]

5.13 In regard to the 50 hour limit, NACBCS suggested that for the lowest income earners on maximum Childcare Assistance, there was an actual fee increase of $25 per week:

5.14 Witnesses pointed out that the above elements, taken together, resulted in an increasing gap between the cost of child care and the assistance provided by the Government. It was this gap that was seen as `the single most important factor in the withdrawal, total or partial, of children from services' and the basis of the affordability or otherwise of child care services. [17] An example of the combined impact of changes given to the Committee:

5.15 In response to the evidence received on affordability, the Department stated that total government assistance had kept up with inflationary indicators such as the Consumer Price Index (CPI) and Average Weekly Earnings (AWE). For example, in relation to AWE, Government assistance has remained constant from 1991 to 1997 at 15 per cent. With regard to the CPI, Government assistance has increased well above the CPI: between 1992-1997 the CPI increased by 11 per cent while Government assistance increased by 23 per cent. [19]

5.16 A breakdown of these figures for 1996 and 1997 was provided by the Department:

Table 5.1: Government Assistance, CPI and Government Assistance as a proportion of AWE in 1996 and 1997

1996 1997
Government assistance* 2.4% 1.1%
Consumer Price Index* 2.1% -0.3%
Average Weekly Earnings* 3.8% 4.4%
Government Assistance as a proportion of AWE 15.7% 15.2%

*Comparison shows increases over previous year

Government Assistance is combined Childcare Assistance & Rebate that a low income family paying average fee would be entitled to for 1 child in full time care.

Calculations of Government Assistance & AWE as at August each year. CPI as at September

Source: Submission No.894, Additional Information, 28.7.98, p.2 (DHFS).

5.17 The Brotherhood of St Laurence in its report Is child care affordable? examined whether expenditure support had been sufficiently indexed to the costs of care. The Brotherhood concluded that inflation-indexation alone may not be sufficient to keep up with costs, as child care is fairly labour intensive and there is a limited capacity for improvements in productivity. It stated that `in the long run, therefore, its costs will be largely driven by wage costs, which tend to rise slightly faster than inflation (unless child care workers' relative living standards drop)'. [20] The Brotherhood also noted that the income test thresholds for Childcare Assistance rose with inflation until 1997. However, it was then unilaterally reduced `in a way which markedly affected larger families, as the removal of the $30 per week per child “income disregard” was coupled with the reduction in the maximum incomes for receipt of [Childcare Assistance] for these families were also lowered, thereby increasing the withdrawal rate'. The Brotherhood concluded that the impacts of the changes announced in 1996 `will have been to worsen affordability more markedly, particularly for larger families and most particularly for users of community-owned centres'. [21] This last point was supported by research by Families at Work which surveyed New South Wales families. It found that only 27 per cent of families surveyed indicated that they could afford the fee increases in community-based long day care centres. [22]

5.18 The Department provided information on the extent to which funding is assisting families. As shown in Table 5.2, for a single parent family with one child in full-time care for 50 hours per week, the cost of child care, based on the average fee of $159, would represent 33.1 per cent of disposable income. With Government assistance the costs of child care fall to 10.6 per cent of disposable income. For a two parent family, earning $45,000 a year, with two children, before assistance child care costs would represent 43 per cent of disposable income. With Government assistance, this is reduced to 18 per cent of disposable income. Unfortunately, the Department was unable to provide the Committee with a time series showing assistance as a measure of disposable income as `it does not have access to equivalent information for previous years to produce historical tables'. [23]

Table 5.2: Impacts on Single Parent Families disposable Income

Assumptions
Full-time Care/week 50 hrs
Full-time Fee/week per child $159
Family Profile Out of Pocket Child Care Costs Out of Pocket Child Care Costs as a % of Disposable Income Child Care Subsidy
Number of Children Annual Gross Family Income Weekly Gross Family Income Weekly Disposable Income Weekly Child Care Subsidy Before Child Care Subsidies After Child Care Subsidies Before Child Care Subsidies After Child Care Subsidies As a % of Disposable Income As a % of fees
1 $27,000 $519 $481 $108 $159 $51 33.1% 10.6% 22.5% 68.1%
1 $35,000 $673 $560 $95 $159 $64 28.4% 11.5% 16.9% 59.6%
1 $45,000 $865 $672 $78 $159 $81 23.7% 12.1% 11.6% 48.8%
1 $55,000 $1,058 $775 $55 $159 $104 20.5% 13.4% 7.1% 34.8%
1 $65,000 $1,250 $864 $31 $159 $128 18.4% 14.8% 3.6% 19.4%
2 $27,000 $519 $546 $235 $318 $83 58.3% 15.3% 43.0% 73.8%
2 $35,000 $673 $575 $212 $318 $106 55.3% 18.4% 36.9% 66.7%
2 $45,000 $865 $657 $183 $318 $135 48.4% 20.5% 27.9% 57.6%
2 $55,000 $1,058 $790 $154 $318 $164 40.2% 20.7% 19.5% 48.4%
2 $65,000 $1,250 $889 $114 $318 $204 35.8% 22.9% 12.8% 35.8%

NB - Child Care Subsidies include Childcare Assistance and Childcare Rebate and are based on July 1998 parameters

- Weekly Disposable Income refers to the amount of income after income tax and includes non child care Government benefits and rebates

- Assume that families are single parent families.

Source: Budget Estimates 1998-99, Answer to Senate Question on Notice No 184 (DHFS)

Table 5.3: Impacts on Two Parent Families disposable Income

Assumptions
Full-time Care/week 50 hrs
Full-time Fee/week per child $159
Family Profile Out of Pocket Child Care Costs Out of Pocket Child Care Costs as a % of Disposable Income Child Care Subsidy
Number of Children Annual Gross Family Income Weekly Gross Family Income Weekly Disposable Income Weekly Child Care Subsidy Before Child Care Subsidies After Child Care Subsidies Before Child Care Subsidies After Child Care Subsidies As a % of Disposable Income As a % of fees
1 $27,000 $519 $476 $108 $159 $51 33% 11% 23% 68%
1 $35,000 $673 $592 $95 $159 $64 27% 11% 16% 60%
1 $45,000 $865 $722 $78 $159 $81 22% 11% 11% 49%
1 $55,000 $1,058 $853 $55 $159 $104 19% 12% 6% 35%
1 $65,000 $1,250 $973 $31 $159 $128 16% 13% 3% 19%
2 $27,000 $519 $538 $235 $318 $83 59% 15% 44% 74%
2 $35,000 $673 $608 $212 $318 $106 52% 17% 35% 67%
2 $45,000 $865 $738 $183 $318 $135 43% 18% 25% 58%
2 $55,000 $1,058 $868 $154 $318 $164 37% 19% 18% 48%
2 $65,000 $1,250 $989 $114 $318 $204 32% 21% 12% 36%

NB - Child Care Subsidies include Childcare Assistance and Childcare Rebate and are based on July 1998 parameters

- Weekly Disposable Income refers to the amount of income after income tax and includes non child care Government benefits and rebates

- Assume that families are 2 parent families; second parent earns 40% of the total family income.

Source: Budget Estimates 1998-99, Answer to Senate Question on Notice No 184 (DHFS)5.19 The analysis by the Brotherhood of St Laurence of average fees suggested that these fees had risen faster than inflation and faster than Childcare Assistance. It noted that the maximum Childcare Assistance previously covered three-quarters of fees, but by 1997 it covered less than two-thirds: `the resultant “gap fee” has doubled as a result, meaning the total out of pocket payments for lowest-income users had risen by over $20pw, or 50 per cent in real terms'. [24]

5.20 In relation to the cost of child care, the Department provided information on average fees payable for one child in full-time care. Average fees have risen since 1991, with the greatest rise between 1991 and 1992, an 11 per cent increase in community-based centre fees and 12 per cent in private centre fees. [25] Average gap fees in community-based centres increased from $33 in 1996 to $48 in 1998. In private centres the average gap fee increased in the same time period from $35 to $42. [26]

Table 5.4: Average Weekly Fees by Service Type for 1991 to 1998*

1991 1992 1993 1994 1995 1996 1997 1998
Community centres $106 $118 $126 $133 $139 $148 $162 $163
Private centres $104 $116 $124 $133 $142 $150 $152 $157

*Fee as at August each year, except 1998 where fees as at March.

Source: Submission No.894, Revised Appendix 9 (DHFS).

5.21 The Department also provided a breakdown of average fees by State and Territory. Within each jurisdiction community-based centres charged the highest fees with the exception of Queensland and the ACT.

Table 5.5: Average fees by State and Territory, May 1998*

NSW VIC QLD SA WA TAS NT ACT AUST
Community-based $171 $161 $148 $167 $159 $170 $152 $174 $163
Private $161 $156 $152 $161 $154 $169 $145 $173 $157
All centres $164 $157 $151 $164 $155 $170 $149 $173 $155

*Preliminary data.

Source: Submission No.894, Additional Information, 28.7.98 (DHFS); Committee Hansard, 25.6.98, p.627.

With the `ceiling fee' at $115 per week, average gap fees for full-time care for one child ranged from $30 for private centres in the Northern Territory to $59 in the ACT in community-based centres.

5.22 Three further matters were raised concerning fees and their impact on affordability. Firstly, some witnesses noted that fees vary considerably between States and Territories and within States and Territories. In some areas the high costs of items such as land and council rates increased fees charged for care, particularly long day care. As a result, families in high cost areas faced higher child care fees. Further, fees in long day centres are higher than in family day care services.

5.23 The Department's analysis of fees indicated that just over 90 per cent of all centres, both community-based and private, charge a full-time fee of $180 or less. Despite anecdotal evidence, the Department noted that only a small number of families would be paying a gap fee of more than $65. The Department indicated that the pattern of fees had remained relatively constant over time, with some services consistently charging fees above those that the majority of centres are charging.

Table 5.6: Average weekly fee for community-based and private long day centres, May 1998

Fee range Community based Private
$111-120 0% 0%
$121-130 1% 4%
$131-140 4% 11%
$141-150 10% 19%
$151-160 19% 24%*
$161-170 27%* 18%
$171-180 29% 16%
$181-190 6% 5%
$191-200 2% 4%
$201-210 0% 0%

*Average fee

Source: Submission No.894, Additional Information, 25.6.98, Handout 3 (DHFS)

5.24 Secondly, centres indicated that the cost of care between age groups is not uniform. Costs for the care of babies and children under two are higher than for older children because the staff/child ratio is higher for babies than for older children. For example, in Victoria for under-threes, the staff ratio is one to five and the ratio for the over three year olds is one to 15, in NSW the ratio is one to five for under twos. [27] Fees for babies reflected these costs with many centres charging a differential rate based on age. Families with babies in care faced a greater gap fee than families with older children. Some witnesses reported that the cost of care for children 0-2 years of age is now prohibitive for many low to middle-income families. [28] One operator commented:

Witnesses called for the higher costs of caring for babies to be reflected in child care assistance through a differential rate.

5.25 It was also noted that a differential rate would assist in overcoming short falls in available places for babies. [30] In its 1996 report on the management of children's services, the Australian National Audit Office (ANAO) also commented on the single rate of assistance:

The ANAO suggested that there be separate ceilings for babies and older children more in line with actual costs.

5.26 Thirdly, it was noted that some centres now charged for services such as meals, which had previously been absorbed in centre charges. This is however, an additional cost now faced by families. [32]

5.27 The Brotherhood of St Laurence in its analysis of affordability also looked at other pressures on family incomes, noting that inability to afford child care may be as a result of declining disposable income rather than because of price increases. Conversely, increases in income in real terms mean that fee rises are more easily absorbed. The Brotherhood looked at:

5.28 The Brotherhood concluded that average costs of formal child care had increased over several years and that public expenditure support had failed to keep up with this for low-income users. Recent price rises have been felt most sharply by those on low-incomes and who have little prospect of being able to improve them, those whose incomes are under pressure because of a rise in other costs, and those who face very high marginal tax rates on the incomes earned while their children are in care.

5.29 The LHMU also noted that many of its members are low income earners on award wages and unable to absorb increases in child care costs:

5.30 Many other witnesses also supported the view that child care was now only affordable for upper-middle and high-income families. For many low and middle-income families, affordable, good quality child care was no longer accessible. [34] The Salvation Army stated that `it disturbs us that poor children suffer because of a blanket government policy that fails to adequately assess the effects on the poor sector of society'. [35] Others pointed to the emergence of an elitist system, with only the wealthy being able to afford child care: `these families therefore have increased workforce participation opportunities, resulting in greater economic resources for their family. Families who begin with reduced economic resources are further disadvantaged by lack of access to affordable child care service options.' [36]

5.31 A number of suggestions were put to the Committee as to how adverse impacts on low-income earners could be overcome. Many witnesses called for assistance to be targeted at families through the reinstatement of indexation of the fee ceiling. The Brotherhood of St Laurence noted that it would be more beneficial to increase the ceiling for Childcare Assistance as:

5.32 The Brotherhood suggested that to restore affordability for low-income households to 1992 levels, the maximum value of Childcare Assistance would have to be increased to $105 per week. Even at this level, low income earners would still face large out of pocket expenses. The Brotherhood noted `there is a good case for [Childcare Assistance] to be further increased to substantially eliminate `gap fees', which were not widely apparent until the 1990s'. [37] ACOSS recommended that the ceiling be lifted by $25-$30 per week to reduce gap fees, it suggested that this represents about 50 per cent of the current gap fee. [38]

5.33 The Department responded to calls for increasing the ceiling and improving Childcare Assistance by stating that:

5.34 The Department noted that previous experience suggested that when Childcare Assistance was increased families did not always benefit: the probable response to an increase in the level of Childcare Assistance to families is a further increase in fees. As the Department stated the Government can control the fee ceiling and the rate of Childcare Assistance but it cannot control the fees charged by the services. [40] Other witnesses concurred with this view and noted that following access to Government assistance in the early 1990s fees in private centres increased.

5.35 The Department also indicated that to change maximum total assistance would not target low income groups:

5.36 The Brotherhood acknowledged that fee increases may not be passed onto users. It noted `during the early 1990s, fees in private centres seem to have increased markedly upon their obtaining access to CA. However, holding down CA since that time does not appear to have done a great deal to contain fees. It is probably more accurate to see fees growth as reflecting real wage and other cost increases, at least within the community-owned centres'. The Brotherhood suggested that to ensure the increase in assistance was received by families:

5.37 In commenting on the issue of a measure of affordability, the Department stated:

The Department indicated that it was not doing any work at the present time on developing criteria for judging affordability but that `over the next 12 months it is something that we will have to look at'. [44]

5.38 The Department also commented on the view expressed by many witnesses that the underspending in the Children's Services Program reflected a decline in families ability to afford child care. The Department responded that the $117 million underspend was due to a number of factors:

The Department stated that the growth rate of places was slowing but the number of children using those places was slowing even more. Its data was aggregated but the Department believed that there were also children were using care for less hours than they had previously. [46]

Conclusion

5.39 Government assistance provided through child care funding assists parents to more easily meet the costs of child care and is directed to a greater degree to those on the lowest incomes. However, the question arises as to whether this assistance is provided at a level which is effective in ensuring that those seeking care can access it, particularly low-income earners. And if not, what level of affordability should Government support and what mechanisms should be used to deliver increased affordability.

5.40 The Committee received extensive anecdotal evidence that affordability of child care has declined. Witnesses pointed to decreased utilisation of child care services as the result of the compound effect of increased gap fees, freezing of the Childcare Assistance ceiling, and other changes such as the abolition of the $30 deductibility for other children. This evidence was supported by analysis by the Brotherhood of St Laurence which looked at such indicators as trends in average fees, gap fees and government support in relation to inflation. The Brotherhood suggested that to restore affordability to 1992 levels for low income families Childcare Assistance would have to be increased to $105 per week.

5.41 The Department provided the Committee with evidence of the level of assistance provided by the current arrangements and its impact on disposable income (see Tables 5.2, 5.3). However, the Department was unable to provide similar information over an extended time period. Thus, while the Committee could identify the level of benefit accruing under the current arrangements it could not identify trends in the degree of assistance over time in relation to disposable income: whether it had decreased, remained the same or improved. To have had this information would have been of great assistance to the Committee's deliberations.

5.42 The Committee considers that while Government assistance has not increased at the same rate as increases in child care costs for families, the impact on affordability has varied across income ranges. The Committee considers that there has been minimal impact on affordability of child care for high income earners. In relation to changes to affordability for middle-income earners, the Committee received much contradictory anecdotal evidence. The Committee therefore was unable gain a clear impression of the impact on affordability of child care for middle-income families but it would appear, for the moment at least, middle-income earners are able to access child care without too much economic difficulty. However, the Committee considers that there has been a much more significant decline in affordability for low income families, which is having an adverse impact on their ability to access formal child care. The impact has been felt most by families with more than one child.

5.43 The Committee has considered the suggestions for an increase in the fee ceiling and concludes that an increase in the child care ceiling may lead to price increases across the sector, thereby further diminishing affordability for low-income families. However, the Committee considers that there is need to further assist low income families to access child care by increasing the level of assistance provided through the introduction of a `top up' or `supplement' to Childcare Assistance for these families. In particular, the Committee considers that low-income families with more than one child should receive additional assistance.

Recommendation: The Committee recommends that urgent action be taken to better target child care assistance to low income families, particularly those with more than one child, by the introduction of a `top up' or `supplement' to the current rate of Childcare Assistance.

Recommendation: The Committee also recommends that the Department Family and Community Services conduct research to establish criteria to judge affordability levels for families accessing child care as a matter of priority.

Impact on children

5.44 The Committee received a large amount of anecdotal evidence which suggested that children had been adversely affected as a result of the changes in child care funding. Changes both within centres because of cost control and in the choices which families are making about the hours of formal child care they were able to access were cited as evidence that children were not benefiting from the changes to child care funding.

5.45 It was noted by many witnesses that key elements of quality in child care are the staff/child ratio, the qualifications and experience of staff and the degree of stability and consistency, both in terms of carers and in terms of the other children with whom pre-school children engage while in care. [47] Pressures to keep costs down were now mitigating against these three elements of quality, particularly in the area of staffing which may account for up to 80 per cent of the costs of running a child care centre. [48] Changes impacting on the quality of care for children in a centre include:

5.46 Extensive evidence was received concerning the impact on children of the changes listed above. For example, in relation to the casualisation of staff it was stated:

5.47 The reduction in ancillary staff is commented upon in Chapter 6. However, the loss of cooks from centres could have a particular impact for children. It was argued that the loss of trained cooks would lead to a reduction in quality food services available to children in care. The NSW Child Care Nutrition Network emphasised that good nutrition and the development of appropriate eating habits are essential for the future health of our children. Trained cooks are vital to provide varied, well planned meals and snacks as well as appropriate food awareness activities for children. The Network argued that `centres are compromising the nutritional and educational quality of child care meals by reducing the employment of trained cooks'. [50]

5.48 Anecdotal evidence indicated that families were changing their patterns of child care to make it more affordable. This was occurring in a variety of ways:

5.49 Witnesses were concerned with the outcomes for children in relation to the second and third of these options, with `children being forced into a care situation purely on economic basis are not necessarily guaranteed the best and most secure care and education'. [52] The mixing of care arrangements was seen as providing poor continuity and consistency for children, particularly very young children. It was stated that research had indicated that `continuity of care-giving is a critical determining-factor of good quality outcomes for children'. It was also stated that the development of `more complex and unstable arrangements' added to stress within families. [53] The additional benefits of formal care for children from disadvantaged families are discussed below.

5.50 Many witnesses expressed concern about where the children leaving formal care were going. The NACBCS survey indicated that parents were more likely to move children to informal care when centre-based care was considered unaffordable, with 67 per cent of families surveyed leaving centres using informal care. While most states reported increases in the use of informal care, the Childcare Industry Association of Queensland stated that the informal sector had increased some 91.68 per cent in Queensland. Evidence presented to the Committee also indicated that although family day care was an option and fees in family day care were less than in long day care centres, there was no national indication that children were leaving centres were entering family day care. [54] In South Australia for example there is underutilisation of family day care. [55] The Department also noted that between 1995 and 1997 the number of children using family day care had decreased. [56]

5.51 Views were put to the Committee expressing concerns for the wellbeing of children being placed in informal care arrangements. Witnesses pointed to a range of matters including the overcrowding of homes, safety issues, lack of police checks on carers, children's educational and developmental issues and the unregulated nature of the sector. Those working in the OSHC sector particularly noted the increased incidence of children being left uncared for. [57] The QCCC survey reported that parents were now considering allowing older primary children to make their own way home after school and to stay there alone until the parent/s arrived home from work. [58] NOSHA used the expression `telecare' to describe the emergence of children returning to empty homes and being `cared for' by the television with access to the telephone to contact parents to advise that they had arrived safely and if there are any problems. [59]

5.52 Other witnesses pointed to the pressures now being placed on grandparents to mind young children. While some grandparents welcomed the opportunity to look after their grandchildren others felt that they are unable to provide appropriate care. One operator commented:

5.53 There were calls for the legislative regulation of the informal sector, particularly in view of the level of regulation in the formal care sector. Representatives of the Queensland Government informed the Committee that it had prepared draft legislation to regulate informal care and to set standards for informal home-based care. [61]

5.54 Some witnesses called for payments of the Childcare Rebate to families using informal care to cease. The Childcare Industry Association of Queensland stated that it preferred the cessation of payments of the Childcare Rebate to parents who used unregulated care, or that it be limited to `grandma' care. It noted that the Childcare Rebate was paid to carers as long as they were more than 18 years of age and that no checks were conducted as to the good character of the person providing the care or the safety of the premises. At the same time, long day care providers had to submit themselves to strict licensing, federal regulations and accreditation. [62]

5.55 The Department however, noted that data on claimants of the Rebate who use formal and informal care indicated that the proportion of families claiming for informal care, as a proportion of all families claiming the Rebate, has remained relatively constant at around 3 per cent since the introduction of the Rebate in 1994. [63]

5.56 The SDA noted that only 20 per cent of families use formal care. In 1996, the union conducted a survey of its members. Some 84 per cent utilised informal care and `virtually all members surveyed in the SDA survey (95 per cent) said they were happy with their child care arrangements'. The main reason given by families was that they were comfortable having their children cared for by a family member or friend. The SDA concluded that `it is clear from this survey that informal care is widely used for a range of reasons, most of which are unrelated to costs'. [64]

5.57 The Department also indicated that the Government recognised that many families choose to have their children cared for outside the regulated care environment and that many children were cared for by a relative, particularly for children under two years of age. However once a child turned two many parents preferred a more formal child care arrangement. [65]

5.58 The Department stated that it was difficult to obtain recent detailed information about the extent of informal care, however, Australian Bureau of Statistics (ABS) data showed that the number of children using informal care provided by a relative increased from 866,000 in 1993 to 891,000 in 1996. [66] The next ABS survey to be conducted in 1999 will include a category to establish the number of children being cared for by grandparents. The Department indicated that it will be monitoring changes to care arrangements, and that a research priority for 1998-99 will be to better understand the issues affecting child care users. [67]

Conclusion

5.59 The Committee considers that the impact on children of changes to child care funding has not been adequately assessed, in particular any changes to quality of care. The Committee notes that quality of care is maintained through the Quality Improvement and Accreditation System (QIAS) and State and Territory licensing requirements. The Committee strongly supports QIAS. The system has been a major factor contributing to improved quality of child care. At present the Child Care Advisory Council is undertaking a review of QIAS (see para 4.104). The Committee considers that the quality aspects of child care and their impact on children in care are important issues during this time of rapid change in the sector and that the review should be completed as a matter of priority.

5.60 In relation to informal care, the Committee recognises that informal care will always be the most favoured option for many parents. For example, families with very young children often prefer their children to be cared for by a person they know, a relative or friend, in an informal setting. However, the Committee also notes that informal care, by its nature, is largely unregulated and that in some instances it may not provide the same benefits and protection as formal care for children and their families. The Committee notes that legislation has been drafted in Queensland to regulate informal care and set standards for informal home-based care.

5.61 While informal care will be the preferred option for many families, there are other families for whom informal care is not the preferred option but who appear to have been forced to choose informal care because of affordability and access issues. The Committee also considers that formal child care should be available and affordable for those who wish to place their children in this type of care.

Recommendation: The Committee recommends that the review of the Quality Improvement and Accreditation System being undertaken by the Child Care Advisory Council be completed as a matter of priority.

Families in rural and remote areas and disadvantaged families

5.62 Evidence was presented concerning the special needs of families in rural and remote Australia and disadvantaged families.

Rural and remote families

5.63 The problems of distance were highlighted in evidence concerning the needs of rural and remote families. It was noted that often women are on farms, long distances from towns and while there are family day care (FDC) services in the towns, those living out of town may not be able to access them because of the travel required. It was noted that often FDC is the only suitable option for non-town families because of the need for flexibility in arrangements. However, there is competition for FDC places from those living in towns even though there might be a private child care centre which could cater for the needs of town-based families. [68]

5.64 While FDC provides a flexible service, problems were raised concerning variations in quality of services provided. This was a particular problem where inadequate resources within FDC coordination units do not allow for the level of monitoring of outlying carers deemed necessary to maintain quality. Another problem was that short-term or respite care is rarely available in rural and remote areas. Problems were also reported because of fluctuating demand resulting from seasonal employment and transient populations in rural areas. Australian Women in Agriculture indicated that there was a need for more options for child care than those offered by FDC schemes and noted that some alternative models were being trialed.

5.65 The Queensland Churches Child Care also noted that its centres in rural areas are small and may not be able to sustain operations if forced to cut budgets. The services provided by the centres enabled women to work on farms. In many cases in Queensland, both parents are required to work as the impact of the drought precluded the employment of outside labour. [69]

5.66 A further matter raised by Australian Women in Agriculture was the income test for eligibility for assistance. It was stated that because of the nature of farm business many farm families are ineligible for assistance despite being on low or negative incomes. This is common for young farm families building up their farm enterprises who are more likely to have young children. There are also difficulties for families due to the fluctuating nature of farm incomes. [70]

5.67 The Department indicated that there are hardship provisions in the assets test for Childcare Assistance. Where a family is not eligible for Childcare Assistance because the family's assets exceed the limit ($407,250 as at April 1998), but the family has low-income and low levels of liquid assets, the family can be deemed to have passed the assets test for Childcare Assistance. The provisions apply where liquid assets do not exceed $10,000 (couple) or $6,000 (single) and income is below $15,710 for a one child family, increased by $642 per annum for each extra dependent child, and the value of the family's assets does not exceed $604,250. [71]

5.68 The Northern Territory Health Services submitted evidence on the difficulties of providing child care services to remote Australia. It noted that:

5.69 The benefits of providing child care for those in rural and remote Australia were emphasised. These included opportunities for children, who would ordinarily have little contact with other children, to socialise with larger groups of children; to remove children from farm environments which are also dangerous work environments; to allow women to take on work during busy times of the year such as harvest time and to assist parents to gain better parenting skills. [73]

5.70 The Department's Annual Report for 1996-97 indicated that the level of demand met has increased from 57 to 76 per cent in rural areas and from 41 to 59 per cent in remote areas between 1996 and 1997. [74]

Disadvantaged families

5.71 Many submissions and witnesses raised general concerns about the impact of changes to child care funding on the children of low income and disadvantaged families, both rural and urban. It was noted that child care could make substantial long-term improvements in the lives of children and families in crisis or experiencing chronic disadvantage arising from poverty or cultural or linguistic or geographical isolation. Child care can also make a significant difference to abuse and neglect of children and can decrease rates of entry to `institutional care'. Good quality child care can have a significant impact on the future life of children born in poverty. Further, child care is of importance to `socially deprived' children and their families in moving out of poverty by allowing women, many of whom are single parents, to work. [75]

5.72 Professor Alan Hayes, Institute of Early Childhood Studies, noted:

And:

5.73 Other submissions also pointed to the benefits of early intervention through child care programs which can reduce risk factors which lead to criminality and can, in association with other measures, `increase young people's attachment to school, family and community which in turn makes them less likely to engage in criminal and other “problem” behaviours such as drug misuse'. [78]

5.74 Barnardos Australia and the Salvation Army raised a number of specific problems in relation to disadvantaged families. The Salvation Army pointed to its OSHC and Vacation Care programs conducted at Macquarie Fields which helped to protect many children from violence and abuse, both within the family and in the community:

5.75 The Barnardos' submission raised concerns for children which it defined as `socially deprived', that is children who are the concern of State Welfare Departments or other social work services. Barnardos estimated the number of children in this category to be approximately 15,000 based on its definition.

5.76 While acknowledging that there had been some discussion in relation to `socially deprived' children, for example exemption from the 20 hour limit, Barnardos raised the following issues:

5.77 The Salvation Army gave evidence on the general impact of the changes on the services that they provide to disadvantaged groups:

The Army noted that increased assistance for families using OSHC services which may be an improvement for middle-income families, but it stated `it has no bearing on services like ours [at Macquarie Fields] where our service users cannot afford any fees in the first place – our after school care service is free'. [82]

5.78 Both Barnardos and the Salvation Army voiced concern about the closure of centres in low-income and disadvantaged areas. The Salvation Army noted that its centres had suffered as a result of the loss of the operational subsidy and that it could no longer carry bad debts as it had done in the past for very poor and disadvantaged parents. They also suggested that their organisations might have difficulties in the future to sponsor new centres in disadvantaged areas because of the loss of the operational subsidy. Queensland Churches Child Care voiced the same concern in relation to rural and remote ares, noting that the Churches would be reluctant, without substantial capital funding, to support centres in remote areas. [83] The Salvation Army noted that the Government would have to pay additional costs to help other service providers to set up new centres if centres sponsored by organisations like the Salvation Army were to close. [84] It concluded that `it disturbs us that poor children suffer because of a blanket government policy that fails to adequately assess the effects on the poor sector of society'. [85]

5.79 Another matter raised was the proposal to direct payments to parents, not services. It was contended that such a move might undermine viability of services in low income areas. Barnardos noted that their clients included groups affected by a cluster of problems often including mental illness, high debts and extreme domestic dysfunction. Parents in these circumstances find it very difficult to plan for their children's needs by ensuring that their children's child care fees are passed onto the service provider. If child care assistance were to be paid directly to families, such monies will be easily seen as needed for other goods and services. [86] In evidence during Estimates hearings, the Department indicated that the Government would not change the current system and that payments would continue to be made to services. [87]

5.80 The Salvation Army told the Committee that the Commonwealth Government had decided to give its Macquarie Fields centre a recurrent grant matching the operational subsidy that it had lost for its OSHC service in recognition of the unique nature of the service provided by this centre. The Army expressed the view that such grants should be made to other long day care centres which target the poor and called on the Commonwealth to reinstate operational subsidies to all child care centres in socioeconomically disadvantaged areas which clearly target this population group.

5.81 ACOSS raised concerns about disadvantaged children whose parents are outside the labour force and who are therefore subject to the 20 hour limit. ACOSS noted that formal care for these children provides them with opportunities for socialisation and education, and as well, gives respite to parents. ACOSS concluded that non-work related care should be provided on a planned basis, ensuring equitable access to all families who need it. [88]

5.82 This issue was also raised by a long day centre which serviced a remote community. Little Diggers Child Care, a private centre, noted that the parents of many of the children who attended the centre were considered to be `not working'. These parents lived on the opal fields and undertook mining activities. It stated that many lived in very rough conditions: without electricity and running water; with pit toilets and dirt floors. Parents also have literacy problems, are often non-English speaking and other support services such as a SUPS worker are not available. The one pre-school is full and the nearest is 70 kilometres away. The nearest child care centre is over 200 kilometres away. 90 per cent of the parents using the centre are on the highest rate of Childcare Assistance. The centre argued that the children from these families would benefit from increased opportunities provided by child care and the parents from respite care. It recommended that the 20 hour limit be removed where the centre is the only one in the area. [89] The Department advised the Committee secretariat that this centre and other private centres in rural and remote Australia had been exempted from the 20 hour limit.

5.83 Many witnesses raised concerns about the limit of the Disadvantaged Areas Subsidy (DAS) to rural and remote areas. For a centre to receive the DAS, it must meet eligibility criteria including that it must be located in a town or township in a rural or remote statistical area, or in a township on the fringe of an urban area where no other centre based care is available; or is the sole provider of centre based baby places or is the sole provider of overnight centre based care in a rural/remote town. More than 10 per cent of children must be from low or middle-income families, that is families eligible for Childcare Assistance. All centres must obtain financial and management advice which demonstrates a need for on-going funding to maintain viability. DAS is also approved for community centres catering primarily for Aboriginal and Torres Strait Islander children, regardless of location. The Department indicated that 110 centres, including one centre in Adelaide providing the only 24 hour care in the city, had received DAS to March 1998 and 13 ATSI services had received DAS. [90]

5.84 Witnesses pointed out that many urban areas were `disadvantaged'. An example of a disadvantaged area in Melbourne was used:

And:

5.85 Witnesses called for the extension of the Disadvantaged Area Subsidy criteria to ensure that centres servicing disadvantaged urban areas could continue to provide the service to those in need. The LHMU recommended:

5.86 NCOSS also suggested that assistance should be targeted to services in disadvantaged localities. NCOSS proposed that funding should be made available to long day care centres on their capacity to provide a quality service to low income families, similar to the Disadvantaged Schools Program. Funding would need to be at a level that enabled services to provide quality programs through experienced and qualified staff and staffing above regulations. A minimum rate of $500 per place per year was suggested.

5.87 NCOSS indicated that it had some `initial thoughts' about the kinds of criteria which might be used to identify services to receive additional funding. It suggested that criteria for special assistance include a combination of socioeconomic indicators for the locality (for example income levels and levels of public housing) and indicators for users of the service such as numbers of parents eligible for full fee relief, numbers of non-English speaking background or ATSI children; numbers of children with special needs; numbers of sole parent families; places allocated to children deemed by the service to be at risk or in need of full-time, non-work related care. [94]

5.88 The Salvation Army supported the need for special provisions for centres in disadvantaged areas and suggested that further assistance should be provided to the centres where more than 70 per cent of families are on maximum Childcare Assistance. [95]

5.89 Concerns were raised by witnesses about the ability of families with children with disabilities to continue to access high quality programs. [96] It was noted that access may be lost because of:

5.90 The Department noted that from July 1997, funding of $4.1 million is being provided annually to community-based services in disadvantaged areas, particularly in rural and remote areas, to ensure that families in these areas are not further disadvantaged through loss of access to child care. DAS so far provided to centres has been equivalent to 100 per cent of former Commonwealth operational subsidies. Funding is for a three-year period.

5.91 An additional $10 million annually is also provided for the Special Need Subsidy Scheme (SNSS) to support children with high levels of additional needs, particularly children with a disability, who would otherwise not be able to be placed in Commonwealth child care services. [98]

5.92 The Department also noted that 30 centres had received recurrent grants in place of operational subsidies for OSHC services because of the unique nature of the services provided including those to disadvantaged families.

Conclusion

5.93 The Committee notes that the Commonwealth has provided additional funding assistance for community-based services in rural and remote areas and those services with a large Aboriginal and Torres Strait Islander population through the Disadvantaged Area Subsidy. Recurrent grants have been made to OSHC services, for example the Salvation Army centre at Macquarie Fields, which provide a unique service such as care for disadvantaged groups. Exemptions to the 20 hour limit are also available and these have been provided to a number of centres in rural and remote Australia.

5.94 However, the Committee considers that in addition to increased support for low-income families already recommended by the Committee, see paragraph 5.43, there is a need for further assistance for disadvantaged families living in urban areas. The Committee believes that the range of services to which the Disadvantaged Area Subsidy applies is too restrictive. While some centres in urban areas have received DAS funding, for example, a centre providing the only 24 hour care service in Adelaide, the scheme is aimed primarily at centres in rural and remote areas. Many urban centres provide important services and benefits for particularly high-needs families. These services are in addition to those normally provided by child care centres and may include a strong protective element such as that provided by the Salvation Army Centre at Macquarie Fields. The Committee considers that this should be recognised and supported through additional funding as are schools in disadvantaged areas.

5.95 The Committee considers that additional assistance be directed to areas of identified social or economic disadvantage, for example areas of high unemployment or areas where there are high levels of public housing. These features have ramifications for community standards of living, access to human services and costs of community infrastructure. Within these areas, assistance should be targeted at centres where parents are particularly socially or economically disadvantaged. These would include centres with a high proportion of users eligible for maximum Childcare Assistance; a high proportion of sole parents; places allocated to children deemed to be `at risk' and children from non-English speaking backgrounds.

Recommendation: The Committee recommends that additional funding be provided to centres which cater for very high needs families in socially or economically disadvantaged urban areas.

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Footnotes

[1] Work force participation for women is discussed in Chapter 6.

[2] Submission No.411, pp.5,7 (St George Advocates for Children Inc); Submission No.417, p.5 (Monash University); Submission 419, p.8 (National Family Day Care Council of Australia); Submission No.572, p.1 (Hunter Children's Services Forum); Submission No.657, p.14 (Tufnell Child Care Centre); Submission No.862, pp.9, 15 (NSW Government).

[3] Submission No.440, Attachment 4, p.9 (QCCC).

[4] Submission No.891, p.6 (ACOSS).

[5] Mission Australia, Children's Poverty: Lost Expectations, cited in Submission No.862, p.4 (NSW Government).

[6] Committee Hansard, 21.4.98, p.70.

[7] From 1 July 1998, the minimum payment rose to $20.00 as a result of indexing.

[8] AIHW, Australia's Welfare 1997, p.124; Submission No.894, Additional Information, 28.7.98, p.2 (DHFS).

[9] Submission No.894, p.21 (DHFS).

[10] Department of the Parliamentary Library, Background Paper No.9 1997-98, Childcare in Australia: current provision and recent developments, pp.5-6. In reviewing savings, it was also noted that these levels of savings appear to have been calculated from forward estimates 1995-96, p.19.

[11] Submission No.894, Additional Information, 28.7.98, p.1 (DHFS).

[12] Submission No.794, p.3 (Quality Child Care Association of Victoria).

[13] Submission No.273, p.3 (Culburra Beach Children's Centre).

[14] Submission No.894, Additional Information, 28.7.98, p.B3 (DHFS).

[15] Submission No.862, p.29 (NSW Government).

[16] Committee Hansard, p.330.

[17] Submission No.418, Additional Information, 29.5.98 (NCOSS).

[18] Committee Hansard, 16.6.98, p.547.

[19] Submission No.894, p.21 (DHFS).

[20] Tasker, G & Siemon, D, Is child care affordable?, Brotherhood of St Laurence, 1998, p.21.

[21] Is child care affordable?, p.22.

[22] Submission No.863, p.2 (Families at Work).

[23] Submission No.894, Additional Information, 28.7.98, p.A4 (DHFS).

[24] Is child care affordable?, p.24.

[25] Submission No.894, Revised Appendix 9, (DHFS); Committee Hansard, 25.6.98, p.627.

[26] The gap fee is the difference between the `ceiling fee' and the amount charged by the service provider. In both 1996 and 1998 the `ceiling fee' was $115.

[27] Committee Hansard, 21.4.98, pp.92, 131.

[28] Submission No.292, p.5 (Uniting Church Children's Services Forum); Committee Hansard, 22.4.98, p.177.

[29] Committee Hansard, 16.6.98, p.562.

[30] Submission No.273, p. 2 (Culburra Beach Children's Centre).

[31] Australian National Audit Office, Efficiency Audit, Mind the Children, p.xxi.

[32] Committee Hansard, 22.4.98, p.197; 23.4.98, p.243.

[33] Committee Hansard, 25.5.98 p.515.

[34] Submission No.882, p.11 (Uniting Community Services Australia).

[35] Committee Hansard, 23.4.98, p.265.

[36] Submission No.572, p.3 (Hunter Children's Services Forum Inc).

[37] Is child care affordable?, p.37.

[38] Submission No.891, p.11 (ACOSS), see also Submission No.418, Additional Information, 29.5.98, (NCOSS).

[39] Submission No.894, Additional Information, 28.7.98, p.B2 (DHFS).

[40] Committee Hansard, 25.6.98, p.627.

[41] Budget Estimates 1998-99, Community Affairs Legislation Committee, Committee Estimates Hansard, 3.6.98, p.CA135.

[42] Is child care affordable?, p.37.

[43] Budget Estimates 1998-99, Community Affairs Legislation Committee, Committee Estimates Hansard, 3.6.98, p.CA130.

[44] Budget Estimates 1998-99, Community Affairs Legislation Committee, Committee Estimates Hansard, 3.6.98, p.CA133.

[45] Submission No.894, Additional Information, 28.7.98, p.B5 (DHFS).

[46] Committee Hansard, 25.6.98, p.646.

[47] Submission No.731, p.13 (Australian Early Childhood Association); Submission No.762, p.3 (Institute of Early Childhood – Macquarie University).

[48] Committee Hansard, 23.4.98, p.238.

[49] Committee Hansard, 16.6.98, p.599.

[50] Submission No.462, p.2 (NSW Child Care Nutrition Network).

[51] Committee Hansard, 21.4.98, 23.4.98, pp.97, 254; Submission No.887, Appendix 2 (Community Child Care Co-operative Ltd (NSW)).

[52] Submission No.331, p.2 (Association of Child Care Centres of SA Inc).

[53] Submission No.905, p. 6 (South Australian Government)

[54] Committee Hansard, 23.4.98, p.259; see also Submission No.131, p.2 (City of Monash); Submission No.375, p.10 (Maroondah City Council).

[55] Submission No.331, p.4 (Association of Child Care Centres of SA Inc).

[56] Committee Hansard, 25.6.98, p.631.

[57] See for example, Submission No.572, p.1 (Hunter Children's Services Forum).

[58] Submission No.440, Attachment 4, p.9 (QCCC).

[59] Submission No.921, p.5 (NOSHA).

[60] Committee Hansard, 16.6.98, p.524.

[61] Committee Hansard, 16.6.98, p.608.

[62] Submission No.542, p.11 (Childcare Industry Association of Queensland); see also Submission No.331, p.2 (Association of Child Care Centres of SA Inc).

[63] Submission No.894, Additional Information, 28.7.98, p.A5 (DHFS).

[64] Submission No.465, p.21 (SDA).

[65] Committee Hansard, 25.6.98, p.634.

[66] Submission No.894, p.23 (DHFS).

[67] Committee Hansard, 25.6.98, p.634, Budget Estimates 1998-99, Community Affairs Legislation Committee, Answer to Senate Question on Notice, No.198 (DHFS).

[68] Submission No.534, p.4 (Australian Women in Agriculture); see also Submission No.125, p.2 (Mrs H Severin).

[69] Submission No.415, p.7 (Queensland Churches Child Care).

[70] Submission No.534, p.5 Australian Women in Agriculture).

[71] Submission No.894, Additional Information, 14.8.98, (DHFS).

[72] Submission No.881, pp.15-17 (Northern Territory Health Services).

[73] See also Submission No.760, p.2 (Country Children's Services Association of NSW).

[74] DHFS, Annual Report 1996-97, p.142.

[75] See for example, Submission No.905, p.9 (South Australian Government).

[76] Committee Hansard, 22.4.98, p.198.

[77] Committee Hansard, 22.4.98, p.204.

[78] Submission No.416, p.11 (Uniya Jesuit Social Justice Centre).

[79] Committee Hansard, 23.4.98, p.265.

[80] Submission No.532, pp.2-3 (Barnardos Australia).

[81] Committee Hansard, 23.4.98, 263.

[82] Committee Hansard, 23.4.98, p.264.

[83] Submission No.425, p.3 (Queensland Churches Child Care).

[84] Submission No.370, p.2 (Salvation Army).

[85] Committee Hansard, 23.4.98, p.265.

[86] See also Submission No.792 (Little Diggers Child Care Centre).

[87] Budget Estimates 1998-99, Community Affairs Legislation Committee, Committee Hansard, 3.6.98, p.CA157.

[88] Submission No.891, p.7 (ACOSS).

[89] Submission No.792 (Little Diggers Child Care Centre).

[90] Budget Estimates 1998-99, Community Affairs Legislation Committee, Answer to Sentate Question on Notice, Nos 187-191(DHFS).

[91] Committee Hansard, 21.4.98, p.55.

[92] Committee Hansard, 21.4.98, p.68.

[93] Committee Hansard, 23.4.98, p.234.

[94] Submission No.418, Additional Information, 29.5.98, p.2 (NCOSS).

[95] Committee Hansard, 23.4.98, p.278.

[96] Committee Hansard, 22.4.98, p.177.

[97] Submission No.762, p.6 (Institute of Early Childhood).

[98] Submission No.894, p.9 (DHFS).