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Shaping the regulatory environment so all ECD programmes are recognised and included
A large portion of the early learning sector operates informally because many Early Learning Programmes (ELPs) cannot meet the norms and standards required for formal registration. Informal ELPs are ineligible for much-needed state support and funding, which could help them grow and improve.
Hamstrung by ill-fitting regulatory and support frameworks, SA’s ELP sector has reached a perilous equilibrium: registration requirements in ELPs catering to poor children are unachievable and parents are unable to pay more fees meaning that they cannot invest to improve standards in order get state funding. ELPs, who must keep fees low to cater for the poorest children, are ironically least likely to be registered and subsidised.
The challenge
The requirements and processes to register ELPs are onerous. The registration standards are not context-specific and are set and enforced by different government departments and levels of government. This creates a complex regulatory environment that prevents SA’s poorest children from accessing quality early learning.
Timeline of activities
- Our partners Innovation Edge and Network Action Group (now Impande) developed a new approach to ELP registration that addresses the pain points for both government officials and ECD programmes, called Bhalisa Inkulisa. Using workflow tools designed for manufacturing, the registration process was made simpler, faster and data-driven. The approach was tested with the KwaZulu-Natal and Eastern Cape Departments of Social Development between 2015 and 2018.
- Between 2015 and 2019, Ilifa demonstrated how ELPs in the poorest communities cannot register and receive subsidies because they are unable to meet the prerequisite norms and standards. Through the Strategic ECD Infrastructure Support (SEIS) Programme with the Project Preparation Trust (PPT) and Impande, we identified the most common physical infrastructure improvements that needed to be addressed to solve registration blockages. The SEIS programme tested innovative approaches to upgrading and maintaining the infrastructure of ELPs so that they achieve registration.
- In partnership with the government; Ilifa, SmartStart and Cotlands demonstrated bulk registration of playgroups.
- While Ilifa's focus has consistently been on how to support existing ELP sites, we also recognised that there are communities without any ELP infrastructure at all. To address the issue, we worked with PPT, Lima Rural Development and Assupol Community Trust to design and pilot low-cost new builds.
- SEIS informed SA’s first nationally funded ELP infrastructure maintenance programme, the ECD Maintenance Grant.
- Bhalisa Inkulisa informed a tiered ELP registration framework, which allows ELPs to meet registration requirements progressively, which would go on to be adopted by government with time.
- Ilifa’s motivation resulted in the Maintenance Grant extending to unregistered ELPs.
- The Children’s Amendment Bill was tabled before Parliament without any significant changes to make the ECD operating environment more enabling. In response, Ilifa co-founded the Real Reform for ECD Campaign with the Equality Collective, a first-of-its-kind advocacy effort supported by over 200 organisations. The campaign resulted in 1,270 submissions to Parliament citing problems with the ECD amendments.
- As part of our legal analysis, we clarified that the law allowed the government to fund ELPs to support them in meeting registration requirements.
- Ilifa developed an Infrastructure Procurement Strategy assisting government operationalise the Maintenance Grant.
- Parliament rejected the Children’s Amendment Bill, a win for Real Reform 4 ECD.
- Ilifa assisted with redrafting the Children’s Amendment Bill.
The big shifts
- Lessons from designing and implementing Bhalisa Inkulisa informed a tiered ELP registration framework, which has since been adopted by the Department of Basic Education (DBE). The framework applies a developmental approach to registration and allows for the “conditional registration” of ELPs by giving them an opportunity to meet norms and standards over time.
- Bhalisa Inkulisa’s lessons now form the backbone of the government’s Vangasali initiative, which targets unregistered ECD centres with the view to assisting them in registering.
- Lessons from SEIS allowed us to advise the Department of Social Development on the design of an ECD infrastructure maintenance programme in 2017. The first of its kind, the programme pays for the renovation and maintenance of ELP sites. This means ELPs have an opportunity to meet norms and standards by improving their physical infrastructure. Improving registration outcomes through this programme proved to be a good intervention, however, managing the actual infrastructure work was challenging.
- The Ilifa low-cost ECD infrastructure designs cost up to 80% less than the government’s original blueprints for new ELPs and are now the state’s recommended design. Funding for new builds has been included in the ECD Conditional Grant.
- In March 2021, Parliament rejected all ECD provisions and instructed the government to prepare a second Children’s Amendment Bill dealing with ECD. After its rejection from Parliament, we supported the redrafting of the Bill to ensure a fairer and simpler regulatory environment for ELPs.
- In 2017, the North West Department of Social Development allocated funding to playgroups, signalling the critical role of non-centre-based programmes in closing the ECD access gap.
Crossing the bridge
The work on legislative reform will continue so that ELPs can meet appropriate norms and standards designed for the realities of diverse operating environments. ELP providers should be enabled to deliver early learning services to children without tripping up on unnecessary red tape, provided they operate within reasonable and realistic regulations set up by the state. Ilifa continues to support the Real Reform for ECD as a necessary component of the ECD ecosystem, growing the voices of ELPs.
