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Key Advocacy Points

Please see below for a list of key advocacy points that FDCA has raised with the Department of Education, Skills and Employment.


Issue: Increased enrolments since February

Family day care has seen increased enrolments, with parents seeing family day care as a safer option and/or school aged children being cared for due to school closures. In the new fee relief payment system there is no accounting for or incentive to provide additional or non-standard hours care.

Initial Departmental feedback:

Services will be able to apply for a higher payment level to account for this.

Issue: No incentive to deliver non-standard hours care

Initial Departmental feedback:

The calculation of the average service fee takes into account non-standard hours care provided during the reference fortnight. If you have increased non-standard care delivery since the reference fortnight your service may apply for a higher payment level to account for this.

The Department is also looking at alternative funding mechanisms to incentivise the delivery of additional non-standard hours care to frontline workers.

Issue: Educators on leave when 50% calculated or educators that started in March 2020

Initial Departmental feedback:

Services will be able to apply for a higher payment level to account for this.

Issue: Vacation care

Family day care, in most cases, delivers vacation care during school holidays and would already have bookings in place, which results in higher numbers of children, increased workload and, in normal circumstances, increased remuneration levels.

Initial Departmental feedback:

Services will be able to apply for a higher payment level to account for this. The Department is also considering additional mechanisms to account for this variance.

Issue: JobKeeper eligibility

Not all services and educators will be eligible for JobKeeper. For example:

  1. Council services
  2. Some Not-for-profits that deliver other services
  3. Educators who have been working for less than 12 months
  4. NSW educators who earn less than the threshold required to have an ABN

Initial Departmental feedback:

1 & 2) This is a broader ECEC sector issue that has been flagged across multiple Departments and is currently being considered as a high priority.

3) Under the criteria, educators (sole traders) who have been operating for less than 12 months are eligible.

4) The Department is looking into how best to support educators to access the JobKeeper payment who don't have an ABN.

FDCA Recommendation:

The payment framework is such that in most cases educators and services meet the 30% revenue loss criteria; however, we have requested that the Department instruct the ATO that educators automatically meet the 30% revenue loss criteria for the JobKeeper payment.


Issue: Transition time

The transition time is unworkable given the considerable list of challenges facing the family day care sector as a result of the fee relief announcement.

Initial Departmental feedback:

Services MUST ensure that they submit their session reports by 11.59pm Sunday 5 April 2020 to ensure they receive their current owed CCS and ACCS payments for this report period. Services will receive payment for session report submitted early next week (in arrears).

In addition, also next week, services will receive their first payment under the new funding structure in advance. The combination of having this and the previous reporting period payment at the same time will provide a grace period during which services can navigate the operation of the new funding structure and their disbursement protocols and procedures.

The speed at which the Australian Government has acted to create this new funding structure is due to the increasing severity of the pandemic situation and the risk of broad-scale shutdowns across the ECEC sector, including family day care.

Issue: No incentive to take on new enrolments, such as the children of frontline staff

Initial Departmental feedback:

Services will be able to apply for a higher payment level to account for this.

The Department is also looking at funding mechanisms to incentivise the delivery of sessions to frontline workers.

Issue: JobKeeper payment lag

JobKeeper won’t be paid till May. While backdated, educators' cash flow is affected and without this revenue for April won't be viable for some to continue operating.

Initial Departmental feedback:

The Department of Education, Skills and Employment is discussing this matter with other relevant Department and the ATO as it applies across all sectors.


Issue: Service distribution of payments

Expeditious guidance needs to be provided to services on how best to distribute the payment to educators, in the interest of transparent and equity, taking into account service levies.

Initial Departmental feedback:

The Department is continuing to unpack the detail of the rollout of the new payment system and will provide further information to service providers. FDCA will also continue to provide information as it becomes available and guidance in consultation with the FDCA COVID-19 Advisory Committee.


Issue: Family day care is seeing much higher occupancy rates than long day care

Due to smaller groups and lower risk, occupancy rates have been much higher.

Initial Departmental feedback:

If the payment does not provide adequate funding levels for educators to maintain high occupancy rates, you are able to, at your discretion, reduce hours and/or prioritising care to vulnerable children and children of essential workers.


Issue: Relative Care

Reduced enrolment and attendance will make relative care very complex to manage.

Initial Departmental feedback:

In consultation with FDCA, the Department will consider options in relation to waiving this requirement.


Issue: Educators that provide longer hours of care to a full complement of children will be significantly worse off

Initial Departmental feedback:

If the payment does not provide adequate funding levels for educators to maintain high occupancy rates and more hours, they may need to consider a reduction in hours and/or prioritising care to vulnerable children and children of essential workers to ensure they remain viable.