20 December 2024

Hon Erica Stanford
Minister of Education
Parliament Buildings

Tēnā koe Minister

Curriculum matters

We write to express our concern about the recommendations set out in the Ministry of Regulation’s Regulatory Review of Early Childhood Education released on Wednesday 18 December. We believe if implemented, the recommendations will undermine the quality and safety of ECE services.

The Associate Minister of Education has accepted the recommendations and advised he will bring the proposed changes to the first Cabinet meeting next year. We ask you to intervene to ensure the sector provides feedback on the recommendations prior to Cabinet considerations.

Specifically, we are alarmed to read the recommendations relating to the ECE curriculum Te Whāriki, and to teacher qualifications.

Curriculum undermined – recommendation 9

The report recommends 11 of the 13 licensing criteria relating to curriculum, be removed.

Currently, services must demonstrate they meet those criteria in order to be licensed and receive public funding. The proposed change would mean the requirements are optional.

The criteria cover a range of matters including respecting the right for children to be confident in their own culture, demonstrating understanding of children’s learning, pedagogical knowledge and current teaching practice, and providing language-rich environments and learning experiences to extend learning. It is this expectation of professional practice that has made our curriculum Te Whāriki world class, internationally acclaimed and Aotearoa New Zealand seen as a world leader in early childhood education.

To make the criteria optional is untenable. Your goal to strengthen learning outcomes for children is directly undermined, and the benefits of the government’s investment in ECE vastly diminished as a result.

Teacher qualifications – recommendation 10

The report recommends qualification requirements are made more flexible, and ‘strike the right balance’ between quality and availability particularly for services in rural and lower socio-economic areas, Māori and Pasifika services, and home-based services.

Currently in regulation, only 50% of staff have to hold a teaching qualification. Data shows over 2/3 of staff in the sector are qualified teachers. The Ministry of Education’s strategic plan for early childhood education is to increase the number of qualified teachers to reach 100% qualified teaching workforce – an objective based on sound research evidence underpinning the provision of high quality education.

The report suggests there could be a mix of degree qualified teachers and certificated staff. ‘Striking the right balance’ suggests lower standards for services in certain communities. That is simply not good enough and would not be tolerated elsewhere in the education system or in the wider public sector.

Review - defacto policy setting

Regulations exist to support and give effect to government policies – not the other way round. The review recommends changes to policy settings – that is not its brief. Regulations should support the implementation and monitoring of evidenced-based policy settings, that have been carefully considered and widely consulted on - not drive policy.

The regulatory review cannot be condoned as a defacto policy setting exercise. We want to make sure the outcome of the review enhances the provision of early childhood education services and reflects all we know from the research, on the settings for and benefits of high quality early childhood education.

We trust you will consider our request to engage and consult with the sector on the report’s recommendations prior to consideration by Cabinet. ECE is too important to be left to chance we need to get it right for every child in every community – a goal we know you also share.

Ngā mihi nui

Sherryll Wilson
Chief Executive Kidsfirst Kindergartens
on behalf of Kindergartens Aotearoa