Wales Pre-school Providers Association (Wales PPA) is a national charity and membership organisation that promotes and supports bilingual pre-school care, education and learning through play across Wales.  The Association was established over 30 years ago and during this  

Wales PPA have addressed the points in the consultation letter that are appropriate to the sector. 

The childcare sector in Wales is regulated by Care and Social Services Wales and practitioners are required to be skilled and qualified. Providers of the Welsh Government’s Early Entitlement for 3 to 4 year olds to access pre school Foundation Phase provision is regulated by ESTYN 

 

·         whether Bill will establish a genuinely age 0-25 system 

Although the bill encompasses the 0-3 age range and identifies Local Authorities as the responsible body for providing support to children and their families who have identified needs in this age group, it is not clear how far reaching the responsibilities are and how they would be met or financed. This age group are below school age and only able to access preschool or childcare within the third sector or private provision , some children can access Flying Start but this is not a universal service and is dependant on postcodes. There needs to be clarity on what kind of service a child with an IDP could access and how this would be funded.  

 It is common that a child’s needs will be first identified when they attend a Day Nursery or playgroup.  In the Bill,  it is unclear what the route to referral would be for these children and what the responsibilities of the childcare provision are outside of their own internal ALN policies  it is also unclear as to what financial structure would be in place to support this from the Local Authority.  At present this varies from authority to authority.  

It is a positive step that an IDP is not reliant on diagnosis but on need. however if needs are identified early in a child’s life then  a clearer definition of a child’s right to access services and support within private and third sector childcare and early years education provision would be helpful. We find that when the issues are diagnosed early in the child’s life, families are often facing a period of time where they are isolated from their peer groups and have to adjust/come to terms with the issues they are dealing with. For example conditions such as autistic spectrum disorders can take a long time to be diagnosed but the child presents very early on with learning and behavioural difficulties and can be identified as having a need for an IDP.  

·         the provisions for collaboration and multi-agency working, and to what extent these are adequate 

 We would welcome further detail about the provision for collaboration and multi-agency working within the early years.   There are examples of good working practice for example, some Local Authorities have strong partnerships with  private and third sector early years providers  and have set up Additional Needs schemes with Umbrella organisations such as Wales PPA which bring together and bridge the gap between birth to education. A good example of this is the model used in Newport, Newport City Council have continued to fund the Additional Needs Referral Scheme managed by Wales PPA. This supports children in the private and third sector as well as   children wishing to access their statutory early education entitlement and play opportunities in the non-maintained sector. This type of scheme is not universal throughout Wales so there  is  a lack of consistency across authorities, Outlined below is the model that is currently used in Newport for pre-school children 

The scheme funds an Additional Needs Co-ordinator who receives the initial referral (usually from a Health Professional or childcare setting) and investigates the individual child’s circumstances and needs. This is then presented to the multi-agency panel made up of representatives from the local authority, health (Portage), specialist paediatric nurse leading the Social Services Children with Disabilities Team, Additional Needs Advisory Teacher, LEA’s Inclusion Team manager, Wales PPA’s regional manager, Newport Flying Start manager, MudiadMeithrin, LEA’s Early Years Business Manager etc. At the panel meeting, the case for the child is discussed and a care package agreed (dependant on funding available). Parental consent is paramount and this includes referral to other support services if required. The agreed funding pays for the extra support needed from a staff member within the childcare provision. Children will only be placed in provisions registered by Care and Social Services Inspectorate of Wales (Care and Social Services Inspectorate Wales) and each provision will have to satisfy a further list of criteria ensuring that the child is support by a qualified and experienced member of staff, regular reviews are completed by the Additional Learning Needs Coordinator and transitions forms are competed when the child leaves the scheme to ensure that the next provision or school that the child attends has all the relevant information to help the child settle into the next place. The benefits of the scheme are well recognised throughout the authority, with professionals referring into the scheme and especially among the parents whose children have had the additional support the scheme offers 

·         whether there is enough clarity about the process for developing and maintaining Individual Development Plans (IDPs) and whose responsibility this will be; 

If childcare in the private and third sector  are used to support IDP then who would be responsible for the training, resources and  the associated financial impact on the sector?  The bill could explore this and clarify this so that responsibilities are clear 

·         the capacity of the workforce to deliver the new arrangements; 

The bill asks that the  within Additional Needs Coordinator Education settings should be suitably qualified and that this qualification should be also applicable to the  Additional Needs Coordinator  appointed by the Local Authority for the Early Years. However,  this does not take into account  the different skill set that is required by an Early Years Additional Needs Coordinator for children who are not in early years  education and whose family needs a more holistic approach. For example coordinators for a preschool child would tend to spend significant time with the parents to guide them through the early stages of diagnosis, so this should not be a “one size fits all” qualification.  It is also important to identify where funding for  training for those Additional Needs Coordinators who would work outside of the education system would come from.