Unpacking the ‘Return to CCS’ package – A look at the roadmap

Federal Minister for Education Dan Tehan has confirmed that the ECEC Relief Package will be switched off on 12 July 2020 and the sector will return to the Child Care Subsidy (CCS) system on 13 July 2020. The transition will be supported by a number of additional measures designed to help the sector, workforce and families manage the journey back to CCS. 

This article aims to break down the key elements of the transition roadmap, identify the specific supports that have been provided for services, educators and families before examining some of the administrative requirements needed to ensure all stakeholders are able to participate fully. 

The Department of Education, Skills and Employment (DESE) has created a useful frequently asked questions article outlining the key tenets of the new policies, rules and conditions. 

What are the key elements of the Transition Road Map?

The transition from the ECEC relief package back to the CCS system will play out over a period of around 12 weeks between 12 July to 4 October after which a reversion to a more normal operating environment will commence. 

1. ECEC Relief Package will cease on 12 July 2020 meaning that “free childcare” is over. No more business continuity payments will be received from the Government and no more applications for exceptional circumstances funding will be allowed. In addition, absence days will return to 42 from 62. 
2. CCS will resume on 13 July 2020 with services having the ability to charge fees and will be obliged to recover gap fees as usual. In addition, services will be able to submit session reports and also if required submit or amend session reports for periods prior to 6 April 2020.
3. New Transition payment will begin being paid to services from 13 July 2020 to 27 September in lieu of the cessation of Jobkeeper payments from 20 July 2020 (see below) and will be paid on top of CCS and Gap payments received from families. 
4. Relaxed activity test requirements will be extended to families who experience a reduction of hours worked relative to pre COVID-19 will commence on 13 July 2020 and end on 4 October 2020.

After the 4 October there is an expectation that the early childhood education and care (ECEC) operating environment will have normalised along with the broader Australian economy after which support measures for ECEC will not be required.

What are the “Support Measures” that have been extended to services, educators and families?

The road map has been designed to facilitate a transition away from crisis measures to a post COVID-19 environment and to achieve this aim consideration has been given to each of the three key stakeholders in the ECEC sector namely; services, educators and families to ensure they are adequately supported along the way. 

The key support measures for ECEC services are: 

1. The Transition Payment – The Transition Payment which will be calculated as up to 25 per cent of revenues in the reference period or to the existing hourly rate cap, whichever is lower. It will be paid weekly up to 27 September with the last two payments in the period brought forward and paid as a lump sum. The payment is designed to help services mitigate against the loss of families over the “free childcare” to “paid childcare” transition and also for the loss of JobKeeper payments scheduled a week after implementation. 
2. Allowable Absence Provisions will be brought forward – From 13 July 2020 families can receive CCS for absences up to seven days before a child’s first physical appearance at a service and seven days after a child’s last physical appearance to a service where they have been booked in for care, for a set of predetermined reasons. This amendment will provide operators with more security around securing allowable absences under certain circumstances.    

Services will be expected to maintain fee and service offerings at the same level as the reference period in March and also commit to not reducing average employee levels after the JobKeeper payments are withdrawn and for the duration of the transition period. 

The key support measure for the ECEC workforce is:

1. As a condition of receiving the Transition Payment average numbers of employees must be maintained – Operators who receive the Transition Payment must guarantee that educator employment levels must be maintained for the duration of the Transition Period. This will protect the workforce from operators shedding staff once the JobKeeper payments are ceased. 

This measure was specifically called out in Mr Tehan’s release where he noted “Services will need to guarantee employment levels to protect staff who will move off the JobKeeper Payment.”

The key support measures for families are:

1. Activity test requirements will be relaxed – From 13 July 2020 to 4 October 2020 the CCS activity test requirements will be relaxed. The new rules will enable individuals who can no longer engage in the same number of hours of work, training, study or other activity that they did prior to the COVID-19 crisis to access 100 hours of subsidised care per fortnight for up to 12 weeks. This measure will support family’s ability to access subsidised care if their activity circumstances have fallen but will require income estimation from families to qualify plus will be capped at 85 per cent. 
2. Fees will be capped at pre COVID-19 levels – As a condition of Transition Payment receipts services will not be allowed to increase fees to above reference period levels, change their service offerings and/or add new administrative fees. This rule is in place for the duration of the transition period and will protect families from fee increases or other adverse value adjustments. 

Families will be able to advise Services Australia that they meet the new Activity Test requirements from 13 July 2020 with the results being backdated for up to 28 days. 

What do services need to do to be ready for the change over?

The key focus for services in the run up to 13 July 2020 is to ensure that enrolment information is up to date and to encourage families to ensure that their details are up to date in their Centrelink online accounts through myGov or Express Plus Centrelink mobile app. 

It is understood that services will be notified closer to the date of any further actions that may be required pre-switch over.