6 reasonable steps for approved providers
It is an approved provider’s responsibility to ensure staff* follow their service’s policies and procedures, and they must take reasonable steps to meet this obligation under Education and Care Services National Regulation, Regulation 170.
There are 6 steps, described as broad outcomes, the Regulatory Authority (RA) considers reasonable.
This guide breaks down the 6 reasonable steps with suggested strategies and examples of documented evidence of practice or observable practice that may assist an approved provider to ensure and demonstrate their compliance with Regulation 170.
The strategies an approved provider uses, particularly where it holds many service approvals, will vary and are influenced by local factors such as the:
- service type, size, location, and availability and use of technology
- staff and family needs including cultural, language and access needs.
These strategies and examples of evidence are not intended to be prescriptive or exhaustive and unless required by law, retaining the listed evidence is not mandatory.
Documentation, such as staff training records, that is recorded at the time of the event and contains sufficient details, including the date and names of relevant parties, is the most reliable evidence of practice.
Approved providers may use this documentation to demonstrate compliance when authorised officers conduct monitoring or investigations.
However, authorised officers can also gather evidence through discussions with staff and observing practice.
* The requirements of Regulation 170 capture a range of staff of centre-based and family day care services, whether engaged as employees or contractors, including nominated supervisors, educators, assistant educators, family day care (FDC) coordinators, FDC educators, FDC educator assistants, volunteers and other staff members, including temporary staff engaged through labour hire or temporary recruitment agencies.
These steps will ensure that staff follow a service’s policies and procedures:
Policies and procedures are readily available and accessible to staff as required.
- As it is a regulatory obligation to ensure staff can access current policies and procedures (refer to National Regulation 171), consider a process for monitoring compliance at each service operated under your provider approval.
- Ensure staff know where and how to readily access the latest versions of policies and procedures and any supporting tools or documentation such as checklists or templates. How staff access these documents will vary depending on the service type, size and systems, and the staff member’s role.
- Assess the needs of your staff and families and, where required, provide policies and procedures in multiple languages or an appropriate alternative, such as online translation software and/or in audio versions.
- Consider the needs of any temporary or casual staff and how they will access the policies and procedures.
- An FDC service’s register of educators, coordinators and educator assistants shows that during support visits, the coordinator provided educators with advice and written materials on how to access policies and procedures. This may have included instructions on how to download the documents from the service’s websites or portals.
- Staff members can show an authorised officer how they independently and readily access the latest version of their service’s policies and procedures, whether in hardcopy or from the service’s software system.
- Documents demonstrate a needs assessment of staff and families has occurred at induction or enrolment on accessing policies and procedures. Documents are provided in languages other than English or via audio or other forms as necessary.
- Physical or electronic records, including version numbers, show that the service is reviewing, updating and following current policies and procedures, particularly after operational and legislative changes have come into effect.