Government Submissions

Most recent submissions/reports listed first: 

Submission: National Review of Teacher Registration - Early Childhood Education

Following attendance at the AITSL Forum, Montessori Australia has prepared a brief response to the National Review of Teacher Registration - Early Childhood Education. Overall, we believe there should be a nationally consistent approach with ACECQA, AITSL, regulatory bodies and authorities and that teacher registration should be a national process, not carried out at the state level, to support consistency.  The submission covers the following points:

• Elements of Registration
• Teacher Quality
• Improvements
• Nationally consistent approaches
• Teacher standards and application to ECT registration

Submitted: 4 June 2018

Download the Montessori Submission

Submission: Social and Cultural Determinants of Indigenous Health

The Montessori Children's Foundation made the following key recommendations:

• Provide significant and secure funding support to enable the expansion of Montessori early childhood programs in Aboriginal and Torres Strait Islander communities.
• Urgently develop mechanisms that will enable those wanting to train as Montessori teachers to have their Montessori training counted as part of their Bachelor of Education studies.
• Investigate how greater numbers of public schools may be able to make the choice to offer Montessori programs either as a part, or as the whole of their pedagogic approach.
• Foster and support the growth of capacity building initiatives such as the Puuya Foundation has undertaken, and facilitate the involvement of other key partner organisations. 

Submitted: 5 May 2017

Download the Montessori Submission

Submission: Productivity Commission Draft Report into Childcare and Early Childhood Learning

MAF has prepared a short submission in response to the July Productivity Commission Draft Report into Childcare and Early Childhood Learning. We were also able to contribute to the public enquiry through input to the ACECQA National Forum and the NSW Children's Services Forum.

Our submission covers the following points:

• The focus on children’s rights, their needs and interests is missing from the framing of the recommendations of the enquiry.
• The workforce participation of women rather than the needs and interests of children is placed at the forefront of policy framework for ECEC.
• The report privileges the needs and desires of employer groups over the needs and interests of children.
• There is a fundamental disregard for the progress we have made in the last 30 years in recognising the interrelationship between care and education.
• CCB should be made available for all children irrespective of family income levels.
• The possible exclusion of some service types (such as preschools) from the NQF.
• The removal of tax benefits for not-for-profit services who provide a large proportion of the education and care of young children.
• The emergence of a division between “child care” for children under 3 and “preschool education” for children over 3.
• The potential impact of a deemed rate of care on families and services that could cause significant disadvantage those in high cost provision in rural and remote locations.
• The lack of provision of a plan to ensure supply of education and care meets demand.
• The possible exclusion of children from vulnerable families to early education by the imposition of the proposed 24 hour work/activity test per fortnight.
• Nannies should be linked to an approved service to ensure quality provision and to ensure they are supported to achieve quality outcomes for children.

Submitted: 6 September 2014  

Consultation - Reduction of command and control - Australian Education Act 2013

This submission is in response to Minister Pyne's letter to the Montessori Australia Foundation seeking our comments on where we perceive the Australian Education Act 2013 or the associated Regulation afford an overreach of Commonwealth powers and involve unnecessary reporting to the Commonwealth in this regard.

Small independent schools have the same regulatory burdens as larger independent schools but do not have the same administrative capacity to meet increasing and constantly changing administrative and reporting requirements especially when these overlap with two different legislative jurisdictions. Many areas of the Act are overly prescriptive and can usually be dealt with in a collaborative way between jurisdictions. 

Whilst understanding the need for accountability and quality control, we would support any reduction in regulatory burden that would enable schools to focus on the provision of high quality teaching and learning and reduce administrative costs. There are many overlapping regulatory requirements between States/Territories, the Commonwealth Government and different Acts and Regulations with which Montessori schools have to comply.

Specific input was provided regarding various sections of the Act. 

Submitted: 23 June 2014 

Senate Select Committee Submission on School Funding  

This submission responded to the following points

• Value of independent schooling
• Current and new funding arrangements
• Distribution of Funds
• Montessori schools and students with disabilities
• Agreement on 3% increase
• Recommendations for future funding arrangements

Submitted: 20 March 2014

Productivity Commission Childcare and Early Childhood Learning

 This submission responded to the following points:  

• Support for implementation of National Quality Framework
• Affordability of childcare
• Qualifications
• Government support by State, Territory and Local Governments
• Key support measures for childcare services
• Options for regulatory reform
• Initiatives of government to address workforce changes 

Submitted: 31 January 2014  

Beyond Gonski: Reviewing the Evidence on Quality Schooling 

Following the release of the Gonski Report, the Public Policy Institutue (PPI) was commissioned by the Independent Schools Council of Australia (ISCA) to prepare a response paper, authored by Scott Prasser and Helen Tracey. The paper was presented at a meeting attended by Christine Harrison, Presdient, Montessori Australia Foundation. She provides an update on the meeting and its bearing on the Montessori sector.  

Circulated: Montessori Australia Foundation eBulletin 2013 Edition 1

Parliamentary Inquiry into the Australian Education Bill 2012  

This submission outlines the Montessori sector's response to the Parlimentary Inquiry in the areas of Quality Education, Transparancy and Accountability, Diversity and Choice, School and Student Assessment Benchmarks, and School Funding.

Submitted: 30 September 2011

Comments to ACECQA Regarding Draft Criteria for Excellent Rating

This report offers comments from the Montessori sector to the Australian Children's Education and Care Quality Authority (ACECQA) on the draft criteria for Excellent Ratings for childcare centres under the National Quality Standards national quality rating and assessment process. 

Circulated: 28 February 2012 

Montessori Report on the Gonski Briefing

This report summarises the briefing on the Gonski Review of Funding. 

Circulated: 20 February 2012

Review of Funding for Schooling - Response to Commissioned Research

On 31 August 2011, the Review of Funding for Schooling released its Paper on Commissioned Research and the following four research report

• Feasibility of a National Schooling Recurrent Resource Standard
• Assessing existing funding models for schooling in Australia
• Schooling Challenges and Opportunities
• Assessment of current process for targeting of schools funding to disadvantaged students  

The Montessori sector affirms our belief that any model for funding of non-government schools should be equitable, transparent and treat all schools and systems in the non-government sector consistently. Funding arrangements for feepaying independent schools should encourage, not discourage, parental investment in their child's schooling. We concur with the independent school sector that it is critical that any proposed funding model be based on robust, reliable and up-to-date data. 

Submitted: 30 September 2011  

ACARA Submission: Recognition of Montessori National Curriculum

Submission to ACARA for the Recognition of Curriculum Framework to meet the requirements of the Australian Curriculum

Submitted: 17 June 2011

MAF, MCF and TSIREC Meeting with Minister Peter Garrett

Meeting date: 6 July 2011 

Key points of discussion were: 

• The importance of endorsement of the three year age range in Montessori settings and provision of advice to state education authorities to that effect.
• The Minister's support for recognition of the Montessori National Curriculum including the Montessori Early Years Learning Programme (MEYLP)
• Recognition of Montessori qualifications
• Issues and challenges relating to the MySchool and MyChild websites
• The success of the Strait Start programs in the Torres Strait Islands

The importance of the continued support of the Minister and the government for the TSIREC/MCF partnership in the Torres Strait to allow additional support for the existing programme, expansion due to community demand in other areas of the Torres Strait and North Queensland.

Submitted: 17 June 2011

National Quality Framework Regulations Exposure Draft

In response to the DEEWR National Quality Framework Regulations Exposure Draft the Montessori submission highlighted key areas of concern for the Montessori sector including: 

• Educator to child ratios 
• Requirements for early childhood teach
• Approval and determination of qualifications
• Declared approved learning frameworks
• Qualifications and Experience of Assessors
• Supervisor Certificate
• Assessment and Ratings
• Policies and Procedures
• Review of Funding for Schooling: Emerging Issues Paper 2010 

Submitted: 31 March 2011 

In response to the DEEWR Review of Funding for Schooling Emerging Issues Paper the Montessori submission specified:  

• Any changes to government funding arrangements should leave no Montessori school or student worse off in real te
• Any funding arrangements should be simple to administer, transparent and offer stability and predictability
• Montessori school enrolments are projected to increase significantly over the next decade. They will provide a significant contribution towards the future recurrent and capital costs of school education in Australia. We firmly agree with the independent sector that governments must encourage and appropriately support independent schools in order to leverage this contribution.
• Montessori schools are chosen by many parents because of their ability to support students with special learning needs, including students with disabilities. These students must be resourced appropriately regardless of the type of school they attend.
• We support the right of parents to exercise their entitlement to choose the type of schooling for their children. Montessori schools are often chosen because of their sense of community and ability for families to become more involved in their child's education.
• Small, community based schools such as Montessori schools show a significant commitment to transparent and effective governance with many school boards made up wholly of parents. There is a high degree of accountability to stakeholders who are fee-paying parents, founders and other financial supporters.
• Montessori schools draw their enrolments from all income groups. Many of our schools offer low fees and serve lower SES communities that are the fastest growing group of independent schools thus increasing the load on our schools.

Our schools need to work with stability and predictability of funding arrangements to facilitate financial planning and management. We would like to see funding legislated for at least four years as per the current quadrennial arrangements. The value of recurrent, capital and targeted grants should be maintained in real terms by appropriate supplementation.

MAF Meeting with DEEWR Early Childhood Development Group 

Meeting Date: 25 November 2010 

Key points of discussion were:

• Overview of Montessori in Australia and Overseas
• Presentation on Elements of Quality Montessori ECEC Centres
• Recognition of Montessori Early Years Learning Framework
• Recognition of Montessori Qualifications
• Assessment of Montessori Programmes under the NQS
• Montessori Programmes in Indigenous Communities

Submitted: 22 November 2010

MCEECDYA National Biennial Forum 2010

Education for the Future: Improving Student Learning and School Performance

The Australian Education Ministers' 2010 Biennial Forum to be held in Canberra on 15 October will showcase innovative and creative best-practice initiatives that are improving student outcomes, transforming schools and shaping the education environment into the future.

The forum will bring together over 300 of Australia's educational leaders and practitioners from all jurisdictions and sectors for a range of highly engaging interactive presentations and discussions. It will report progress being made on the goals of the Melbourne Declaration on Educational Goals for Young Australians, while also providing a platform for considering 'schooling for tomorrow'. 

MAF is pleased to have been invited to the Forum and to have been asked to submit a paper and project summaries to be published on the Forum's website. 

• Developing sustainable partnerships with Aboriginal and Torres Strait Islander leaders and communities to improve early childhood infrastruct
• Montessori Parent Support Initiative as the key to lifelong learning
• Hands on learning and experiences in Montessori Adolescent Programs as valuing the contributions of young people to a peaceful and sustainable society 

http://www.schoolsforum2010.edu.au

Early Childhood Development Strategy

Both MAF and MCF strongly support the Early Childhood Development Strategy and, especially as a consequence of our work in remote Indigenous communities, we are convinced that parent support and education are a vital part of supporting improved developmental outcomes for vulnerable children.

Specific recommendation were made in regard to:  

• Strengthening universal maternal, child and family health services
• Engaging parents and community in understanding the importance of early childhood
• Improving early childhood infrastructure
• Financial Health Assessment Framework Review (FHAF) Submission to DEEWRs

Submitted: 4 December 2009

Regulation Impact Statement for Early Childhood Education and Care Quality Reforms 

Issues of concern to the Montessori Sector, explored in more detail in the body of the submission, are summarised below.

• Accreditation and regulation
  How accreditation and regulation will be implemented and by whom for diverse services which require assessors to have expert knowledge both of the regulations and of the nature of the methodology and contexts of particular services.
• 1:3 ratio for children to 24 months
  Implementation should be achieved earlier than 2020
• A clearer focus on children from birth to age three
  There is a need for a much stronger focus in the RIS on this most critical period of children’s development
• Equity in diverse communities
  The need for financial investment, and investment in capacity building, especially in remote Indigenous communities, to ensure equity of access high quality services.
• Staff qualifications
  Will staff with a Certificate lll qualification be accorded “qualified status” in relation to the prescribed child-to-staff ratios?
  Achievability within stated timelines of requirements to employ early childhood trained teacher.
  Further clarification of the ways in which RPL will work in relation to those teachers with Montessori diplomas but without and early childhood degree; and to those currently employed as Montessori assistants with Montessori assistant training.
• Rating a service as excellent
  Might some services be precluded from obtaining a rating of “Excellence” because of size or location resulting in diminished access to resourcing or partnerships?
  Appropriate arrangements for the assessment of Montessori early childhood education and care services.
• 3 year groupings
  The new regulations must accommodate the 3 year age cohorts in Montessori services; clarification needed in relation to child-to-staff ratios, group sizes and funding.
• 15 hour universal access
  Clarification of the issue of the 15 hour program being able to be embedded in the 3-6 program in Montessori centres in ways which do not disrupt the usual functioning of Montessori programs.
• Costs and funding
  The conclusions of the cost-benefit analysis are questioned, and concerns exist that families will ultimately bear any additional costs, risking the withdrawal of some children from early childhood services, and risking the viability of some centres.

It is imperative that the access of all families to CCB, including those who access services which do not meet the criterion of opening 48 weeks per year, is addressed if the National Quality Agenda is to incorporate current licensing and accreditation systems, and all families are to be supported in their right to choose services for their children. 

Submitted: 31 August 2009 

Schools Assistance Act Regulations

The Montessori sector supports the intention of the Act to foster transparency in reporting to parents so that they have “useful information about how their child and their school are performing… to assist them in making the right choice of school” (Clause 16). We support the provision of plain language student reports to parents. However, we do not support the requirement that such reports employ an A to E or equivalent scale. Nor do we support reporting that shows a student’s achievement relative to the performance of his/her peer group. We argue that our current methods of reporting both provide to parents “useful information about how their child and their school are performing”, and provide it in ways which are consistent with the Montessori philosophy that the parents of our students have consciously chosen for their children’s education.

Submitted: 22 May 2009

Victorian Children’s Services Regulations 2009

The Montessori Sector supports the directions of the Draft regulations, and is grateful for the opportunity to comment on issues of concern to our staff and parents. In particular, we seek the following: 

Consideration of official recognition of the equivalence of a Montessori Diploma to the two-year Diploma in Children’s Services which can be articulated to an early childhood education degree, and /or an arrangement based on recognition of prior learning which takes on-the-job learning into account; and we seek a meeting in the near future with DEECD officials to pursue these matters.

• Consideration of recognition of the equivalence between Montessori Assistants Training and the Certificate III in Children’s Services and/or consideration of special dispensation for Montessori Assistants Training to be recognised as constituting appropriate entry level qualifications for working in Montessori settings only. These are matters we would also like to pursue in the abovementioned meeting we seek with DEECD official.
• The opportunity to provide an orientation to DEECD officers and ministerial advisers regarding the operation of Montessori early childhood education and care services to provide a clear context for considerations of recognition of Montessori training. 
• Special dispensation in regard to the occasional entry of children to the Montessori three to six program before their third birthdays without the requirement to meet the proposed adult-child ratio of 1:4 for children under three. 
• Further discussion with DEECD officers with a view to resolving anomalies in relation to both the “double” qualifications requirement and funding arrangements for children whose parents wish them to complete the full 3 to 6 cycle in Montessori services.

Submitted: 23 March 2009

National Curriculum Feedback

Submitted: 24 February 2009

NSW Children’s Services Regulations Review

The Montessori sector supports the opportunity provided by the review to reduce the complexity of the regulatory framework for the delivery of children’s services while improving quality and outcomes, and asks for particular consideration of the following issues:

• The relaxation of group sizes and total child numbers in early childhood services.
• Recognition of Montessori qualifications.
• Recognition of the distinct role of the assistant in Montessori services, and the validity of our approach to ensuring assistants work to appropriate professional standards.
• MAF seeks inclusion on the Industry Reference Group.

 Submitted: 11 December 2008

Early Years Learning Framework

• We are confident that the Framework will provide sufficient scope and direction for the Montessori approach to learning in the early years to maintain its integrity, and that the Framework makes an important contribution to highlighting key elements of quality learning for all early childhood education and care service
• We would argue strongly for the use of simpler and more accessible language, and for each section to be very clearly focused and sequenced to make meanings as clear as poss
• We would also urge that the section on Values and Guiding Principles be clarified, that its language be simplified and that clearer linkages are made between principle and practice.
• Most importantly, we would urge that a greater focus be given to children’s drive for self-direction and self-development, and the implications of this for creating learning environments and employing pedagogies which respects and respond to the demonstrated needs and interests of individual children.

Submitted: 10 December 2008

Schools Assistance Bill Administrative Guidelines

• Recognition of Montessori National Curriculum
• Requested exemption from comparative reporting. The following clause was included in the Administrative Guidelines following our submission “Individual parents may wish to withdraw their child from comparative reporting or assessment conditions that they feel are inappropriate for their child. This is a matter for consideration by individual parents and must be requested in writing to the school.”
• The Montessori sector is seeking representation on the Australian Curriculum, Assessment and Reporting Authority given the unique nature of the Montessori educational philosophy and practice.

Submitted: 28 November 2008

ECEC National Quality Framework

The Montessori sectors seeks:  

• Recognition that the Montessori curriculum exemplifies an effective pathway for realisation of the objectives set out in the National Quality Framework for ECEC discussion paper.
• Recognition that the Montessori pedagogy, materials and classroom management together provide a well-established and well-integrated working illustration of a differentiated play-based curriculum, incorporating content and activities appropriately based on child development.
• Ways to ensure that Montessori training can be articulated with existing training pathways for early childhood teachers to meet National Quality Framework standards.
• Support for and protection of the mixed-age groups (3-6) with which Montessori programs work.
• Delivery of the government guarantee for four year olds in the context of the Montessori mixed-age group (3-6) program.
• Partnerships in early childhood education and care for children with special needs.
• Partnerships in Indigenous early childhood education and care.

 Submitted: 19 September 2008