ACE National’s New Proposal to Reduce Affordability, Access and Accountability in Ontario Child Care

ACE National is an organization that groups together child care operators, most of them for-profits, to lobby for reforms that serve their interests.  Their chair and most prominent spokesperson is Krystal Churcher, who owns a child care centre in Fort McMurray, Alberta, and also heads up the Churcher Group which is a consultancy firm supporting child care operators.

ACE National recently published a report recommending 10 major reforms to CWELCC in Ontario. These reforms would apparently create “A Structurally Sustainable Framework for CWELCC” for the years 2027–2031.

Unfortunately, their report is actually a slide deck – with 10 very briefly described reforms and no research or evidence evaluating their likely impacts.  So, this is more like a press release than it is a report.  Nonetheless, it is worth looking at to see what ACE National has to offer.

According to the report, their recommendations are aimed at helping Ontario continue its participation in CWELCC.  They say that their proposals would avoid the need for substantial new funding, would preserve affordability for families and would control costs structurally.   It sounds like a dream.

Unfortunately their 10-point plan would reduce services offered to children and families, increase costs to parents, and totally eliminate eligibility for some children and families. On top of this they want to reduce measures of financial accountability for the public money that providers receive, and they want to shovel public money towards the 8% of providers in Ontario that have refused to enter the CWELCC program (almost all of them for-profit operators charging high fees without any financial accountability).  None of this passes my sniff test as a useful, well thought out set of policy reforms to make CWELCC sustainable.

Let me give you a few details about their 10-point plan: 

  • ACE would adopt a “Tiered Affordability Model”.  Apparently this means parent fees that vary with income.  There would still be a fee maximum, but we don’t know how high, or how much families would pay at different income levels.  And we don’t know how it would be administered.  Would operators have to income-test parents to determine how much they would pay?  Parents wouldn’t like that.  According to ACE, a few $10 a day spaces would be available but only  to a “limited budget-controlled subset” of families.  ACE suggests that this tiered affordability system would save $300 million – $600 million per year, which is less than would be saved by simply keeping the maximum fee at its current $22 a day level while increasing subsidy funding for low-income families.  Not a very sensible suggestion in my opinion. 
  • ACE would make the standard child care day only 8 or 9 hours per day, rather than the current 10 or 11 hours.  Any family who needed to use extra hours would have to pay extra.  Of course, this means that most parents working an 8 hour shift would face extra-billing. 
  • ACE would cancel eligibility for child care for ALL children in Junior or Senior Kindergarten.  There are currently about 128,000 before-and-after-school spaces for these children in Ontario.  All these children would lose CWELCC child care assistance.  That’s close to 40% of the children currently benefiting from CWELCC in Ontario.
  • ACE wants to get rid of cost-based funding of child care in Ontario (i.e., the funding formula).  Instead, child care providers would get “standardized per space operating grants”.  And, there would not have to be detailed financial accountability for public money received.  Instead only risky operators would have to undergo audits.  Apparently, there would also be no more limits on the percent of public revenues each year that can be taken as profit, unlike with the current funding formula.
  • ACE wants the province to define clearly which services are part of CWELCC and which are not.  Services that are not included would be additional costs to parents above the daily fee.
  • ACE wants the government to provide money to operators who have refused to join the program so they can provide low-fee child care for families. Currently, government subsidies and revenues are only available to operators who are part of the CWELCC system.  But ACE wants to reverse that and subsidize the profits of these operators outside CWELCC.
  • ACE wants to eliminate local planning restrictions on expansion of child care services.  Instead of planned expansion with a priority on underserved communities, expansion would be allowed wherever shortages exist (i.e., everywhere) and whenever projects were ready to go.  Sounds like a free-for-all for the for-profit sector which would receive guaranteed future operating funding for new spaces they are willing to provide. 
  • Even when it comes to a recommendation about staff wages, ACE can’t get it right. There is currently a wage floor of $25.86 per hour for Registered Early Childhood Educators, rising over time. ACE wants to establish a wage floor for non-RECEs – program staff that are not required to have any child-related qualifications.  However, ACE proposes that unqualified program staff – Early Childhood Assistants – should have a guaranteed wage that is no less than $2.00 per hour below the RECE wage!   I wonder how many RECEs will want to spend two or more years getting qualifications and paying annual registration fees to the College of Early Childhood Educators when they could earn nearly as much with no training.

Overall, this is an incoherent mishmash of ideas designed to reduce services to families, charge extra to families for the “voluntary” services that they need, eliminate child care services for children who are in kindergarten, and reduce or eliminate financial accountability and restrictions on the amount of profit.   All of this in a proposal which is free of any evidence that supports its claims.

On top of this, government revenues would now be funneled towards the 8% of (for-profit) operators that refused to join the program initially.  And any operator who wanted to open and had the money to open a new child care centre could do so with few restrictions and then would receive government operating funding as a right.  

ACE National calls this “A 10-Point Plan to strengthen affordability, access, and accountability in Ontario childcare.” However, as we’ve seen, their plan would reduce affordability, access and accountability. Sounds like a dream scenario for some entrepreneurs and a nightmare for parents and the Ontario government.  This is policy advice the Ontario and federal governments should reject.