Voice Official Response 980: Childcare Act 2006: Future Approach to Fees and Subsidies

Voice Official Response to DCSF consultation

Childcare Act 2006: Future Approach to Fees and Subsidies


The Professional Association of Nursery Nurses (Voice) is pleased to respond to the Department for Children, Schools and Families Consultation: Childcare Act 2006: Future Approach of Fees and Subsidies.  In forming our response, comments do not follow any particular order. 

This consultation invites views on the proposed structure and level of fees payable to Ofsted by childcare providers joining the compulsory part of the Ofsted Childcare Register (OCR) or Early Years Register (EYR) from September 2008, as well as proposals for changes to the subsidy arrangements for both fees and Criminal Records Bureau checks. 

Home Childcarers / Nannies

Under the new fees structure it is proposed that the same fee is set for both the voluntary and compulsory elements of the OCR, and for both new registrations and renewals.  The fee rises from £15.00 to £103.00 in September 2008. 

Voice is concerned that the proposed fees represent a significant new burden for home childcarers / nannies.  Nannies are currently not legally required to register on the OCR but can register on the Voluntary Ofsted Childcare Register (VOCR).   However, as the VOCR will not include inspection in the majority of cases, we fail to see how charging the same fee as the OCR, which does include inspection, can be justified. 

Furthermore, we consider the above to be a disincentive for nannies interested in the VOCR. 

It is our strong belief that there should not be a voluntary element to the OCR and that all those working with children and young people should be required to register regardless of their place of work.  By providing a voluntary option, Ofsted is offering an ’opt-out’ for those not wishing to be regularly inspected and monitored, not wishing to improve their knowledge and expertise, and raising the standards of childcare for all.  

Voice notes that the introduction of the VOCR and the inclusion of nannies is to allow parents employing nannies some financial relief towards their childcare costs.  We would prefer the driving force to be that of raising standards and safety.  

Voice remains unconvinced that nannies would elect to register voluntarily when there is little obvious benefit for them to do so.  Future employment is not dependent on voluntary registration nor are improved terms and conditions of employment and, without rigorous inspection and monitoring, there is little in the way of reassurance of best practice for parents.  


Voice does not have childminders in its membership and therefore will leave a more detailed response to the National Childminding Association.  However, we would like to make the following points:

  • There are already significant costs to setting up a childcare business and this additional financial burden may put off new childminders, as well as causing existing childminders to consider whether to continue childminding.
  • A large increase like this could force many childminders out of business.  With fewer childminders working, the duty on local authorities to provide a range of childcare places for parents will be more difficult to fulfil.
  • Linked to the above is the danger of an increase in unregistered providers, thereby endangering the safety of children and dramatically undermining the increasing quality of registered childminders.

Voice supports the government’s commitment to making childcare available, affordable and of high quality.  However, we strongly believe that these proposals risk undermining quality and affordability and could significantly reduce the number of available childcare places. 


For nurseries operating on tight margins, the proposed increases are substantial.  Increases will inevitably be passed on to parents.  

Voice would urge the government to take note of the annual Daycare Trusts survey of childcare costs published just last month.  The figures are alarming and consistently show fees rising well above the rate of inflation: 

A nursery place for a child aged under two in England now costs on average more than £8,000 a year.  

The yearly cost of a nursery place for a child under two is now £8,368 in England, £7,384 in Wales and £7,332 in Scotland.  

In England, costs for a child under two have gone up to an average of £159 a week and for a child aged two and over to £149 a week - an increase of nearly 5 per cent in a year. 

There are many pressures forcing the price of nursery places upwards, including the rises in minimum wages, spiralling business rates, shortfalls from the Nursery Education Grant and the drive to increase graduate recruitment.  Few private settings report making a profit. 

If parents do not cover costs, the only area where nursery proprietors can make savings is in staffing costs.  This would result in either a reduction in the number of qualified staff being employed to fill future vacancies, current qualified and experienced staff being replaced by cheaper, less able employees or, redundancies as a result of cutting the number of childcare places offered which would reduce the number of staff required. 

Many staff members in the sector are on the National Minimum Wage and such increased overheads could impact on the ability of providers to improve the terms and conditions of employment for their staff. 

In conclusion 

If childcare places are lost by childminders disappearing or nursery providers cutting back on staff and therefore the number of places they can offer, this will limit parental choice, make it difficult for Local Authorities to deliver on their legal obligations and, critically, lower quality of provision when parents turn to less qualified, un-registered childcare. 

Voice is not opposed to the government’s proposal that fees and subsidy arrangements should be changed to achieve a fairer balance between the fees providers can afford to pay and support from the tax payer.  We can also see some merit in considering putting in place arrangements for administering this funding at a more local level, using existing local authority mechanisms, where it would be possible to target this support to meet local need.  However, we do not believe that these proposals meet these objectives. 

The proposed increase in fees at the levels suggested, together with the upcoming consultation on the details supporting the new Independent Safeguarding Authority Scheme and its fees, along with the government’s notification that it intends to review the current subsidy on Criminal Records Bureau checks, all contribute to our above concerns and do nothing to allay our fears and objections. 


Tricia Pritchard

Senior Professional Officer (Voice Section)