Modernizing Child Care Continued: Submissions

Modernizing Child Care Continued: Submissions

The Ministry of Education’s discussion paper on Modernizing Child Care in Ontario: Sharing Conversations, Strengthening Partnerships, Working Together is a intended to begin a conversation with child care partners and families on:

  • a long-term vision for child care

  • targeted objectives to support this vision

Please see full report here >

On September 27, all submissions to the Ministry of Education were due.

Please see the Middle Childhood Matters Coalition’s response below.

In addition, check out other submissions by some of our member community agencies as well as other child care focused groups. If you have a response that relates to Middle Childhood, please email us at

Response from MCMCT

A response from the Middle Childhood Matters Coalition Toronto to the Province of Ontario’s Discussion Paper entitled Modernizing Child Care in Ontario.

Middle Childhood Matters Coalition Toronto represents over 35 member agencies including City of Toronto, Children’s Services, Sick Kids Hospital and the YMCA.  We bring organizations and families together to highlight the importance of 6-12 in a child’s life while promoting out-of-school time programming.

We welcome the opportunity to participate in the public invitation to share in conversations, strengthen partnerships and work together towards a high-quality, accessible and coordinated Early Learning and Care system for all children in Ontario.

As a group that focuses on the lack of services for school-aged children – ages 6 to 12, we, members of the Middle Childhood Matters Coalition Toronto, are concerned that this paper does not recognize the full spectrum of childhood. There is a focus on Early Learning and Care throughout this paper without enough attention paid to school-aged children.

This paper begins with many references to Full-day Kindergarten and the government’s progress in making strides in providing Early Learning and Child Care.  It does not address the immediate problems that parents face when their children reach Grade 1 and will no longer have access to the same quality of child care as being rolled out for Full Day Kindergarten children.

School-aged children have been neglected throughout this paper and their needs appear as an after-thought as they are only specifically mentioned once.  The modernization of child care needs to come with the recognition that childhood does not end at 6.  Instead, children require somewhere safe and caring to be when they cannot be supervised by their parents.  Research suggests that between the ages of 6-12 the ideal place for these children is an out-of-school time program.

The Middle Childhood Matters Coalition Toronto believes that a clear definition of the ages of children included in the definition of Early Learning and Care is essential in a plan to modernize child care.  It is our contention that children require the supervision of caring adults and developmentally appropriate space and programming at least until they reach the age of twelve.  We would like to be assured that modernization plans include plans to create a regulated seamless day for school-aged children and their parents and to provide high quality programs during school holidays and corresponding regulated child care programs for parents who must work evenings and weekends.

We support the long-term vision expressed in the discussion document and would have liked to have seen this vision stated at the very beginning of the paper.  In this way the elements described in the vision could have been clearly and simple explained with references to research and facts that support the proposed modernization plans.

The Long Term Vision for Child Care is worth repeating

The Government of Ontario’s long-term vision to build a high quality, accessible and coordinated early learning and child care system for children before they start school and for school aged children.  The system will focus on learning in safe and caring play-based environments, on healthy physical, social, emotional and cognitive development, and on early identification for children in need of supports.  Where possible, services will be located in or linked with schools to enhance seamlessness for children and families.

Throughout the section of Guiding Principles the word “quality” is used in almost every principle.  It would be helpful if there was a brief description of the research that has been and will be used to determine what “quality” means in Early Learning and Care for children from birth to age 12.

We are also concerned about the differing standards of quality for licensed versus unregulated care.  We believe that given a choice parents would prefer to leave their children in a regulated or monitored environment unless the children are left with a close family member or friend. The fact is that there are not enough licensed care facilities for the number of families needing care and that most of the licensed care has inflexible hours and is not responsive to the needs of working families. To accommodate parents and caregivers, the Province should move forward with its plans to modernize the licensing and regulation of Early Learning and Care for school-aged children. Building on licensed home child care and increasing program supports and access to local recreational spaces for licensed home child care providers could increase the capacity for regulated care in many communities.  This would also have significant implications for working families who currently worry about the safety of their children while they are at work.

The Modernization of Child Care in Ontario requires that we understand and pay attention to innovative research into the developmental needs of children as well as the needs of their families for high quality care for the periods of time when parents are not available during out-of-school time.

We would also like to add our voice in support of the City of Toronto’s recommendation that child care be recognized as, “a valued and core part of the school program.”  This integrative system of care is essential to school-age children receiving safe, accessible and quality care.  This will require a stronger and more seamless relationship between the City of Toronto, our school boards along with their individual Principals, and the Province.  We would encourage the Ministry to take the lead in formalizing this relationship and make running before and after school programs a financial reality.  Schools are the best place in terms of potential economic benefits and family needs to provide this space.

Martha Friendly and Trish Hennessy in their paper for the Canadian Centre for Policy Alternatives Ontario Office entitled Go Public, Take Leadership – The Path to Better Child Care in Ontario have laid out the case for modernization and have clearly pointed out why the child care system in Ontario needs to be improved.  We would encourage that their paper be considered in your definition of modernization.

In conclusion, The Middle Childhood Matters Coalition Toronto would like to emphasize that changes to Early Learning and Care require a focus on children over the age of 6.  In fact, we believe, and research supports, that children require the supervision of caring adults and developmentally appropriate space and programming until they reach the age of 12.  This investment has many benefits to communities both economic and social.  Once again, we thank you for the opportunity to be part of this process.  We look forward to working with you in creating sustainable solutions for children and their families.

City of Toronto, Children’s Services (Response)

“Modernized Legislative and Regulatory Framework:

Develop age-appropriate licensing requirements for high-quality, out of school time
programs for six-12 year olds based on research and best practice.

The discussion paper specifically asks whether a new licensing category is needed for older
children. Toronto’s position is that for older children (aged six to 12) a new regulatory
environment is needed. Specifically, a broader range of age-appropriate programs is seen as
a requirement for this age group. A system that meets the needs of six to 12 year olds will
depend on a regulatory environment that allows appropriate models to be set up. As such,
requirements for school age children should be established in legislation separate from the
DNA. A number of community partners in Toronto are currently working on a Middle
Childhood Strategy that would develop a comprehensive system of high quality out-of-schooltime programs for children six to 12 years that includes a wide range of services, providers and
interests that exist across the city. The strategy will be evidence-based and reflect community
consultation findings, and could be used to inform the development of a new regulatory
framework for the age group. It is clear that the strategy will rely heavily on school board
participation and access to school space. As such, school boards must be full partners in
planning for this age group. Other items, such as lunch provision for FDK children, also need
to be addressed as changes happen in both child care and school programming.”

The YMCA, A Child Care System for Today and Tomorrow (Response)

“Achieving universal access to quality, affordable child care is a
high priority for YWCA Canada and essential to women’s equality. As YWCA Canada’s 2011
report, Educated, Employed and Equal: The Economic Prosperity Case for National Child Care
revealed, over the last 30 years women have reversed the gender gap in education and closed it in
employment numbers. Given these trends, the social policy and program gap on early learning
and child care is decades behind reality. Closing it is necessary not only to supporting Ontario’s
children but also to the economic prosperity of the province. A modern early learning and child
care system supporting children ages 0-12 is a social necessity.

Yes, after school group care for six-to-12-year-olds should be on the recreation program model
including safety of equipment, staff requirements, play space requirements, and should reflect the
Board of Education regulations for the same category of programs.
Staffing requirements should be amended to allow for graduates with other recreation
qualifications to be hired.”

Macaulay Child Development Centre (Response)

“Review DNA requirements for school-age and kindergarten child care programs to 
provide greater flexibility and be more aligned with school standards.”

Ontario Public School Boards’ Association (Response)

“One of the Liberal election campaign platforms was to provide on-site after school programs for children 
ages 6-12 (once FDK was implemented). We would be supportive of a new licensing category for older 
children that is more relevant to that age group and suggest that the government consult with the many 
providers of existing successful programs including the YMCA, Boys and Girls Clubs, municipal Parks 
and Recreation programs and others. Many of these groups are operating programs in our schools and 
have for quite some time. We would also suggest connecting with groups such as the Middle Childhood 
Matters Coalition who are specifically advocating for an “increase access to high quality out-of-school 
programs for all children ages 6–12.”

CUPE Ontario (Response)

“Ontario doesn’t shine in domestic, inter-provincial comparisons on public child care spending either. 
Ontario, once the national leader on child care funding, has fallen behind other provinces; By 2008, at 
$3,040, Ontario’s spending per regulated space had dropped considerably from the 1995 figure of 
$3,664 per space while Manitoba, Saskatchewan, Quebec and Newfoundland, as well as the Yukon 
continued to spend more per space than Ontario, while Ontario’s spending on regulated child care 
spending for each child aged 0-12 ($414) was lower than that of Manitoba at $606 per child, the Yukon 
at $1,415, Quebec at $1,694 in 2008.

Proposed Action: 

• core (base) operating funding to support affordability to parents and improving wages and working conditions for early childhood educators and worker, ensuring low staff-to-children ratios and improving quality; 
• capital investments for system and physical infrastructure;
• funding for supports and services for children with special needs;
• allocations that reflect the needs of First Nations and northern communities;

Family Day  (Response)