Submission to the Department of Employment and Social Development on Building a Canada-Wide Early Learning and Child Care System.

Submitted by the Coalition of Child Care Advocates of BC.

September 16, 2024.

Introduction:

The Coalition of Child Care Advocates of BC (CCCABC) is an inclusive, feminist, membership-based organization in British Columbia. We are individuals and groups including parents, grandparents, early childhood educators, child care providers, community organizations, academics and unions. We work collectively, using research, public education and mobilization, to achieve our vision of a high-quality, affordable, accessible, inclusive child care system that serves the public interest - the $10aDay Plan.

In 2011, building on more than 40 years of advocacy, we, the Coalition of Child Care Advocates of BC and our partner, the Early Childhood Educators of BC worked together to create the first "Community Plan for a Public System of Integrated Early Care and Learning" to show the government of British Columbia that a public system of high quality, universal child care was a necessary and effective economic investment, and how to go about building it. Over the years the Plan has been updated and is now known as the $10aDay Plan, in reference to a core recommendation initiated at UBC that full-time child care cost no more than $10 per day, per child.

In response to the $10aDay Campaign and our thousands of amazing supporters – and based largely on our $10aDay Plan – in 2018 the BC Government committed to building a system of quality, affordable, universal child care, calling its own plan ChildCareBC, which included the rollout of a network of $10aDay programs. The federal government then followed suit, providing historic levels of funding to provinces, territories and Indigenous peoples to achieve $10aDay child care across Canada, and the goals set out in the Indigenous Early Learning and Child Care Framework

We welcome the opportunity to share CCCABC’s views and experiences about the key challenges, successes and ongoing supports required to build a Canada-wide Early Learning and Child Care System. While significant progress has been made, more work needs to be done to ensure the ELCC system is able to deliver high-quality, accessible, flexible and inclusive $10aDay ELCC for all families in BC and across Canada.

1.    What does access to high-quality, affordable, flexible, and inclusive ELCC mean to you?

High quality licensed ELCC enhances the well-being and development of children, often with lasting positive impacts into adulthood. Research shows that children who are economically or otherwise disadvantaged benefit the most, but that positive effects depend on high quality services.

Universal and equitable access to reliable licensed child care also gives all parents an opportunity to participate fully in education, training, and employment. Well-designed child care systems support parents with child-rearing and help with work-life balance, and contribute to the broader objective of achieving gender equality.

2.    What do you think a successful Canada-wide ELCC system looks like?

A successful Canada-wide ELCC system requires the transformation of the current market-based approach to child care provision into a universal public system that will make high quality, affordable, inclusive, flexible, culturally safe, regulated early learning and child care accessible to all who want it.

The current market system of child care services stands in contrast to the publicly planned and managed public K-12 education system. The public education system has shortcomings, but we have seen continuous improvements with respect to equitable access and inclusion over many years. This is because children in Canada have a right to public education, and there are mechanisms in place to make the system accountable to communities, parents, and children. Parents do not pay tuition for public education because it is funded through government expenditures. Early childhood educators who work in public education are better paid, receive better benefits and have more favourable working conditions than early childhood educators who work in Canada’s private not-for-profit and for-profit licensed child care sector.

This Canada-wide ELCC system should:

• Provide sufficient public funding directly to licensed ELCC operators in support of high-quality inclusive programs for all.
• Distribute public funding to licensed early learning and child care programs using formulae that ensure staff are properly compensated and support other operational costs to support the delivery of high-quality services pay for other operational costs
• Cap fees for all parents at a maximum of $10aDay for a full-day program (less for part-day care and for low-income households).
• Require that all operators receiving public funds be accountable to governments and the public for the spending of those funds and for supporting the delivery of inclusive, high quality and culturally safe early learning and child care with fees for families capped at $10aDay.
• Ensure that expansion of the system is achieved through the growth of programs operated by public or not-for-profit organizations.

We advocate for the construction of a Canada-wide system of ELCC that honours and respects the Indigenous Early Learning and Child Care Framework, which sees Indigenous “children and families supported by a comprehensive and coordinated system of ELCC policies, programs and services that are led by Indigenous peoples, rooted in Indigenous knowledges, cultures and languages, and supported by strong partnerships of holistic, accessible and flexible programming that is inclusive of the needs and aspirations of Indigenous children and families.”

Any and all decisions federal, provincial and territorial governments make on ELCC must honour and respect the United Nations Declaration on the Rights of Indigenous Peoples, the Calls to Action of the Truth and Reconciliation Commission of Canada, the Calls for Justice issued by the National Inquiry into Missing and Murdered Indigenous Women and Girls, and Jordan’s Principle.

3.    What challenges do you, your community, and/or your organization experience in accessing affordable ELCC?

Accessibility and inclusion

The need for licensed ELCC far exceeds supply across Canada, there are enough licensed child care programs for only 32 per cent of children aged 0 to 12 years as of 2023 (and only 23% in BC as of 2023). The availability is very limited in rural and northern areas but there is also a scarcity of spaces in urban and suburban neighbourhoods. Waiting lists for programs are long. Infant child care is especially difficult to find and that means mothers in the paid labour force must either quit their jobs when their parental leave runs out, or, if their employer allows, take an extended leave without pay.

Accessibility is limited by more than availability of spaces. Other barriers include cost, geographic barriers and the lack of appropriate child care for children with additional needs. All these barriers to access are particularly high for parents and families who experience systemic and intersectional discrimination impacting every aspect of their lives. These include children and families who are Indigenous, Black, racialized, LGBTQ2S+, refugees, recent immigrants, linguistic minorities, and/or those who have disabilities. For many low- to medium-income families, even a small fee is a barrier to accessing services. Geographic distance as well as lack of access to public transport also create barriers for families in some communities.

Children who need additional or specialized learning and care support are often excluded. Children and parents with physical disabilities can face barriers to using or fully participating in licensed child care because facilities are not adequate, or staff have not had access to relevant training. Culture and language can play a role especially if families do not see their culture and language reflected in the pedagogy, or in the staff.

The challenges in availability, accessibility and inclusion are a result of child care in Canada being market-led, with parents holding private responsibility for managing the administrative process of finding and securing child care. At the same time, there is substantial reliance on non-profit groups and entrepreneurs to maintain and develop regulated child care services by securing public or private capital funding for a facility, navigating the licensing process, setting up operations and maintaining them. Across the country, there is wide variation in ECE teacher and staff wages, which creates gaps and inequities in the workforce, but which also impacts the capacity for providers to recruit and retain staff and therefore deliver a high-quality service. When operators cannot retain staff, they face barriers to expansion and, in many cases, are unable to operate at their full licensed capacity, or meet the needs of children with additional needs.

Limited public planning and management of expansion

The reliance on primarily private (non-profit and for-profit) organizations, rather than a government-led approach to planning, limits the creation of new child care services and spaces where they are needed. For-profit operators are more likely to create and locate centres where they will make a profit. Public and not-for-profit centres face challenges in operating in ‘thin’ markets with limited demand if they are not properly funded and resourced. A market-led approach cannot address geographical inequities in access. As a comparison, the expansion of public elementary and secondary schools is planned by the government, taking into account population forecasting and changing demographics in communities. The recent expansion of four- and five-year-old kindergarten across many provinces and territories demonstrates the effectiveness of public planning and management in the expansion of universal access to ELCC services.

Targeted funding and resources to operators in low socioeconomic areas and areas with low population density can partially address the challenges, however, a public planning approach - akin to a public education system - is required to ensure access is truly universal.

When funding through capital grant programs is not 100%, not-for-profit operators have to come up with the difference and that is either too big an obstacle or incentivizes partnerships with private for-profit land developers (and related high rent/lease costs).

Operational costs

For existing operators, inadequate funding formulas that do not cover the true cost of delivering ELCC limit their capacity to deliver high quality care. If services feel uncertain about their financial sustainability, they will have no choice but to reduce costs that are essential to high quality ELCC - including food, resources, physical infrastructure and, perhaps most importantly, staff wages and conditions.

The ELCC workforce – Early Childhood Educators

The current conditions of the child care workforce impede recruitment and particularly retention. These workforce shortages and turnover are a major barrier to expanding licensed child care and to the continued development of high-quality programs across Canada.

Governments must act to address factors that impede the recruitment of qualified early childhood educators, and particularly their retention. As documented in BC, these include:

• Difficult working conditions (such as long hours and unpaid overtime, split shifts in some cases, inadequate paid leave, inadequate paid sick leave, work load, requirement to handle complex learning and care needs of children without sufficient and/or ongoing support)
• Job insecurity and precarious employment
• Barriers to unionization which has proven to be an essential and effective mechanism for employees in other predominantly female occupations and sectors, such as health care and public education, to improve compensation, working conditions, job security, and job satisfaction
• Lack of publicly managed and planned expansion to ensure an adequate supply of qualified early childhood educators where they are needed
• Uneven and in some cases limited access to affordable ECE public post-secondary education and affordable professional development, including paid leave
• Under-developed or weak human resource capacity and policies, including challenges related to the qualifications and support of program leadership
• Limited occupational mobility
• Low morale and sense of government and societal disrespect for the value of ELCC work, as evidenced by all of the above

4.    What priorities would you, your community, and/or your organization like to see addressed by the Canada-wide ELCC system?

It is essential that the Canada-wide ELCC system continues to expand and provide high-quality licensed child care to all families that want it. In order to build a Canada-wide ELCC system that works well for all, CCCABC recommends the following priorities:

a)     Compensate educators fairly and improve working conditions

All levels of government must work together to develop, fund, and implement comprehensive strategies to address this recruitment and retention crisis. The goal must be to properly value the important work of Canada’s educators with competitive wages, comprehensive benefits, and improved working conditions. Structurally, improved staff wages must become part of a centre’s operational budget, not an “add-on” wage enhancement payment. The federal government must increase its annual transfer payments and earmark funds to support concrete and effective strategies as part of the funding agreement action plans.

b)     Make expanding high-quality, climate-resilient, public, non-profit child care facilities a public responsibility— not a private one

As an integral part of transforming child care in Canada, responsibility for planning and managing the supply of regulated ELCC should be assumed by provincial/territorial governments, which may choose to delegate it to other public authorities such as school districts or municipalities.

The federal government must use its spending power and the negotiation of the next set of agreements to ensure a properly funded and publicly managed system. Federal transfers to provinces and territories should be conditional on the provinces and territories developing their own publicly owned child care expansion models and conditional on funding child care programs sufficiently to ensure high quality ELCC services.

Planning and managing the supply includes but is not limited to deciding the type and location of services according to public policy, community need, and public interest and ensuring that they are developed; setting parent fees and staff compensation in accordance with provincial/territorial requirements; carrying out regular public consultations; carrying out regular system evaluations and making results public; collecting data and conducting research and using results to make ongoing system enhancements and improvements.

c)     Implement clear, consistent, operational funding models

Child care funding remains an inconsistent patchwork of parent fee subsidies, wage enhancements, and a variety of grants and payments. Instead, public funds should be used to finance child care programs based on clear and consistent formulas, with parent fees capped at a maximum of $10aDay. This model is the most effective way to ensure both accountability for public funding and a move away from the stigmatizing and ineffective individual parent fee subsidy model.

Provinces and territories must provide evidence that their child care operating funding model is sufficient to keep high-quality programs open. This includes the implementation of formulas that set a goal for fees to be capped at no more than $10aDay (vs. settling for an average of $10aDay, which is an inequitable approach whereby many families still pay too much). Funding formulas should recognize and seek to address geographic and socioeconomic inequities in access to ELCC.

Moving forward, the federal government should use its spending power and partnership with the provinces and territories to put in place the following:

• Provincial/territorial operational funding models with accountability mechanisms to confirm that public funds are effectively and efficiently advancing the public goals of equitable access to high-quality, inclusive programs. Provinces and territories should be required to report on their progress regularly and publicly, using clear and consistent common indicators.
• Increases in the levels of public funding in operational funding models to achieve public goals without increasing parent fees. Increased public funding is essential for improving educator compensation and working conditions, which typically account for 80 to 90 per cent of the budget in non-profit child care programs and are key determinants of program quality, including inclusion.

5.    Are there other initiatives or innovations (e.g., that other governments, organizations, academia, or businesses have introduced or proposed) you think the Department of Employment and Social Development should be exploring to help build the Canada-wide ELCC system?

a)    Workforce initiatives

Supported by their Canada-wide ELCC agreement, the Nova Scotia government has enrolled those working in Nova Scotia’s licensed child care system in the CAAT defined benefit pension plan and an extended dental and health plan through the Health Association of Nova Scotia. Child Care Now applauds the Nova Scotia government for this important policy for the recruitment and retention of the ELCC workforce and recommends the federal government support all provinces and territories to implement similar plans.

There have also been several initiatives to support ECE retention through innovative professional learning models and community-based support system, such as the Association of Early Childhood Educators on Ontario’s Community of Practice model, the Early Childhood Pedagogy Network in BC and the BC Peer Mentoring program. These programs facilitate caring and supportive relationships among the ELCC workforce, which is important for leadership development, pedagogical learning and retention. Programs such as these must be coupled with working conditions that facilitate workforce participation, including paid planning and professional learning time.

b)    Expanding ELCC infrastructure

One innovative initiative introduced in some jurisdictions is modular construction of ELCC facilities. Modular construction offers an expedited process for building infrastructure, either as a temporary or longer-term solution. One example is Manitoba’s Ready-to-Move initiative (RTM), which is a collaboration between the federal and Manitoba governments, First Nations governments, local municipalities, JQ Built (a non-profit Municipal Participation Corporation) and non-profit child care operators. It offers an innovative governance model for using public lands.

In the establishment of a central governance structure, it provides economies of scale and mitigates risk for small and rural communities. Additionally, the RTM initiative involves cooperation among federal, provincial, and municipal or First Nations governing bodies, and has increased awareness of and support for ELCC within local governments. The child care centre remains under public control and ownership.

c)     The housing sector

Federally funded infrastructure programs, particularly housing initiatives, can offer inspiration for the rapid expansion of child care infrastructure. For example, the Infrastructure for Housing Initiative utilizes the Canada Infrastructure Bank’s financing tool to support municipalities and Indigenous communities to build infrastructure. Additionally, the Housing Accelerator Fund incentivizes local governments to remove local barriers to boosting housing supply to speed up the expansion of affordable and inclusive housing. Similar approaches should be used to expand child care infrastructure. We are also encouraged by the recent federal government’s announcement to make federally-owned public lands available for housing and think these public lands should be used to build more affordable, community-based housing with public and not-for-profit operated child care. Parents want their child care to be located close to where they live; it makes sense to build child care alongside all new publicly-funded housing development.

d)    Public planning mechanisms and accountability

Looking internationally, there are examples of system building. System building requires responsibility and accountability at all levels of government. In most Nordic countries, regional and municipal governments are responsible for ensuring there is sufficient supply to meet demand. Child care expansion is built into public planning processes.

Increasingly, governments outside Canada are legislating early learning and child care as a right, or entitlement, which demands greater public accountability and planning at the federal, regional and even local levels. In Sweden, municipalities are legally required to ensure there is a place available for children within 4 months after the place is requested (through a centralized waitlist system). This requires municipalities taking responsibility and planning expansion to meet demand in different locations.

6.    Do you have ideas on how the federal government could support the ELCC Workforce?

The federal government can support the ELCC workforce by requiring all provincial and territorial funding agreements to include a commitment to a comprehensive wage grid and the implementation of a defined- benefit pension plan and extended health and dental benefits for the ELCC workforce. The details of these plans should be developed through formalized processes in each province/territory which engage sector representatives, including ECEs, operators, ECE associations, and relevant stakeholders in developing wage grids and compensation policies.

This would be accompanied by an increase in federal transfers to the provinces and territories under the Canada-wide Early Learning and Child Care Agreements by $7 billion over three years to support full implementation of equitable wage grids, along with improved benefits and working conditions.

The federal government should also establish national standards and guidelines for benefits and pension packages for ELCC workforce in collaboration with provincial and territorial governments, along with relevant stakeholders. These standards should outline the minimum requirements for health and dental benefits, as well as pension plans, ensuring consistency and comparability across the country.

Supplemental Questions

How can the above Budget 2024 measures be best leveraged for expansion of the Canada-wide ELCC system in your, or your organisation’s, experience and/or opinion?

The Budget 2024 measures can be leveraged through a well-designed capital investment program, that ensures accountability mechanisms for provinces/territories and providers accessing funds. Capital funding programs must be accompanied by competitive wage grids and benefits integrated in operational funding formulas that support the ongoing delivery and expansion of high quality $10aDay ELCC programs.

What supports are in place when ELCC providers in your community are trying to increase spaces or start a new ELCC service?

Drawing on work being undertaken by Child Care Now and others, including our own work here in BC, we have learned that there are minimal supports in place when public and not-for-profit ELCC providers are trying to increase spaces or start a new centre. In some provinces and territories, there are capital or start-up grants available. In BC there are grants for capital expenditures, for school districts and non-profits, but no dedicated provincial capital budget, infrastructure or planning support for child care expansion.

In some provinces and territories, innovative initiatives are helping to increase the supply in areas that otherwise would face challenges. One example is the Ready-to-Move initiative in Manitoba that has supported rural and Indigenous communities to create new spaces in a relatively short period of time.

What barriers exist when ELCC providers in your community are trying to increase spaces or start a new ELCC service?

Drawing on work being undertaken by Child Care Now and others, including our own work here in BC, we have learned there are numerous barriers to increase spaces or start a new ELCC service. The most common barriers are:

• Challenges with recruiting and retaining
• Lack of adequate capital funding to build new centres or retrofit existing
• Limited staff resources (or Board members) or the expertise, to work on capital funding applications and manage building
• The lack of adequate or uncertain future operational funding means that providers are hesitant to
• Locating and securing appropriate and affordable land or

How can not-for-profit ELCC providers be better supported in expanding access to ELCC spaces?

We strongly support the need for:

• Increased federal capital funding (and capital budgets) to cover the costs of infrastructure for not-for-profit providers
• Adequate operational funding formulas that support the ongoing delivery of high quality ELCC programs while maintaining maximum fees of $10aDay for families.
• Provincial and territorial investment in competitive wage grids and benefits for staff to ensure a sustainable workforce
• Federal leadership and planning mechanisms at all levels of government to identify areas of need and support local not-for-profits to expand

What design features of the announced measures would be important to you?

• The Child Care Expansion Loan Program should remain restricted to not-for-profit and public providers. It is essential that operational funding formulas are designed in a way that will support providers to repay loans in a sustainable and equitable way (included as an additional expense in their publicly funded operational funding).
• Expansion financed through the federal loan program must be coordinated with expansion initiatives led by provinces and territories. There is no point expanding ELCC through federal loans if the programs receiving loans for capital costs will not also receive operational funding from their province/territory.
• The Child Care Expansion Loan Program should be designed as an opportunity to fill gaps in capital funding, not as a substitute for public funding.
• Priority should be given to capital projects that can be finalized quickly. This includes giving priority funding for hybrid modular construction projects, projects built on public lands, projects initiated by providers who have the capacity to build quickly.
• Projects should be required to incorporate climate resiliency features as outlined in our 2023 Child Care Facility Design Standards

Are there innovative approaches to expansion that have proven successful for the ELCC workforce? If possible, please provide examples of those innovative approaches and tell us why you think they are successful.

As noted above, expanding and supporting the ELCC workforce is essential for the expansion of licensed child care spaces to occur. There needs to be intentional investment and alignment of ELCC workforce planning and development alongside the creation of new child care programs. This may include working with local post-secondary institutions to expand their enrollment, providing mentoring and professional learning opportunities and facilitating leadership development and upskilling of qualifications. Long-term stability and expansion of the sector also requires policies to facilitate retention, including retention of ELCC leaders and managers, such as pension plans.

Has the introduction of wage supports, such as hourly increases, wage floors, wage top ups or wage grids helped to ensure the availability of the ELCC staff required to support expansion of ELCC spaces? Why or why not?

Wage grids - which set out the required wages and pay levels for educators, based on factors such as qualifications and years of service are important for accountability, transparency and equity within licensed child care. Wage top-ups, floors and other supplements do not provide the same level of accountability and do not adequately recognize years of experience and/or educational qualifications. An effective wage grid would create the conditions where educators are recruited and retained in the sector at a level that enables and encourages sector expansion.

As found in the 2020 Next Step report by Early Childhood Educators of BC and the Child Care Advocacy Association of BC, for a wage grid to be effective it must prioritize:

• Competitive wages to recruit and retain qualified educators;
• Higher wages for ECEs with more qualifications and experience;
• Wages that increase over time, keep pace with inflation, and close the gender pay gap; and
• Integrated policy that recognizes and funds child care as a

Wage grids have been identified as an important workforce policy by advocates for many years, but child care advocates have critiqued many of the wage grids announced so far as not meeting the mark to recognize education and experience and compensate the child care workforce competitively.

Conclusion

The Royal Commission on the Status of Women (1970) officially proposed a national child care program. Since then, there’s been three major attempts by federal governments to develop a national child care strategy. The crisis for families is not new but needs to finally get fixed and we celebrate the first steps of progress towards that goal.

Thank you for the opportunity to share our responses to these important questions as the Government of Canada works with Provinces and Territories to build a Canada-wide Early Learning and Child Care system.

We acknowledge with appreciation the work that went into this submission from our colleagues at Child Care Now.

Land acknowledgement from the Coalition of Child Care Advocates of BC

Gratefully living, learning and working on the ancestral lands of over 200 First Nations.

We take action to address barriers to progress, which are grounded in patriarchy, colonialism, and the primacy of business interests. Like other caring sectors, the child care sector is
composed predominantly of underpaid women, often racialized.

We acknowledge the Indigenous leadership that has existed on these lands for millennia and strive to unlearn the colonial practices that were used to oppress the people and ways of being that came before us.

We are working to incorporate intersectional, anti-oppressive, and decolonial approaches to our work. We believe child care is a transformative issue at the core of addressing these barriers. The paradigm shift that emerges when we respect young children and those who care for them is key to ensuring a more equitable and safer world.