Thursday, 5 June 2025
Dear Kate,
Thank you again for your feedback and for taking the time to advocate for . I appreciate your commitment and understand your concerns. However, I would like to clarify a few important considerations regarding our service and its capabilities.
I acknowledge the supports, the buildings, and the internal facilities provided for in his early learning facilities this year and I fully understanding the vast differences between the care they can provide and the care we can provide.
Different Regulatory Frameworks
Early learning services operate under a different regulatory framework than Out of School Hours (OOSH) care. Early Learning services are under EYLF. OOSH is under MTOP. As such, the care they provide differs significantly. Regulations that apply to long day care and family day care services do not necessarily apply to OOSH services. This is why OOSH services, including ours, are permitted to operate in school classrooms and halls-spaces that would not meet the licensing requirements for long day care services.
- Facilities and Toileting Requirements Our current facility is not equipped to house a designated nappy changing area. Under the relevant regulations, Regulation 112 to be precise, any nappy-changing space must ensure privacy and dignity, especially for older children. Unfortunately, our room lacks both the privacy and the physical space to accommodate an adult-sized nappy-changing table or provide appropriate toileting support. ’s toileting needs, while important, fall outside the scope of care we can safely and respectfully provide.
- Staffing and Capacity Limitations Our vacation care program often operates with small numbers ranging from 5 to 15 children-and there are times when only one staff member is on duty. This directly impacts our ability to offer the level of individualised supervision and support would require. Our policies on toileting and additional needs (attached) clearly outline our inclusion capacity and limitations.
Please refer to our Additional Needs Policy, which begins on page 16 of our Policy Manual. The section most relevant to your enquiry can be found under “Service Limitations” on page 24.
Additionally, you may wish to review our Toileting Policy, located on page 874, which also outlines important considerations related to your enquiry.
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Funding and Financial Constraints While KU Supports can provide some funding, it does not fully cover the staffing costs required for adequate supervision in ’s case. Our staff are paid above-award wages, and KU funding would cover only a portion of this cost. As the service provider, I am not able to absorb the financial shortfall this would create.
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Additional Risk of Absconding on service site As outlined in my previous correspondence, the significant risk of absconding is a key factor in our decision to decline enrolment. Our service has clear limitations in the level of care and supervision we can provide, and the presence of a child who is at high risk of absconding exceeds what we can safely accommodate.
Frequent absconding presents serious safety, developmental, and legal concerns. It compromises our ability to maintain appropriate supervision ratios, increases the likelihood of accidents or incidents, and introduces potential breaches of child protection obligations. Furthermore, it may place the service at risk of non-compliance with childcare regulations and licensing requirements. Again pointing to our low numbers and attendances, the financial burden placed on the service to provide additional staff is not economically viable.
For these reasons, we are not able to accept an enrolment where such risks cannot be reasonably mitigated within the scope of our facility and staffing resources.
I genuinely support your efforts to secure the best care for . However, in this instance, we are not equipped to meet his needs within our service setting. I recommend exploring care options through his NDIS funding, which can provide support for holiday periods within your home or via a more suitable service.
If you would like further clarification or are not satisfied with this response, you are welcome to contact the Department of Education’s Early Childhood Education and Care Directorate (ECECD) on 1800 619113. They can further explain the scope and discretion providers have based on their individual circumstances and facilities. Please understand that this is not a case of discrimination but rather a practical and regulatory limitation.
Thank you for your understanding.
Kind Regards,
Larissa /ssah
Directorol Sorvicos
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