HALLELUJAH!  ONTARIO FINALLY HAS A NEW FUNDING FORMULA

Hallelujah!  As of August 14th, 2024, there finally is a funding formula to provide some revenue-certainty for child care providers in Ontario. Not a moment too soon, in fact, a year or two too late. As of January 2025, this formula for the provision of operational funding to providers will be implemented to replace the inequitable revenue-replacement model that has existed since April 2022. As the new funding guidelines admit “[w]hile a revenue replacement approach is transparent and simple to implement, it is not responsive to the true cost of providing child care in Ontario.” (p. 7).  Revenue replacement was not equitable and it did not facilitate growth of capacity, so we will not mourn its passing.

This marks a new stage of development of the $10 a day child care program in Ontario.  And, I am sure that other provinces will be looking closely at this example to see if they should model their funding formulas on this one.  Together, we need to assess whether the funding formula is any good and what its strengths and weaknesses are.  As with any funding formula, there are many details and understanding how the system will work is not easy.  This blog post is a start.  In this post, there is a lot of description and only a small amount of opinion.  More opinion will follow soon.

I think a question and answer format will be best.  And, I will, in this blog post, only describe funding for centres, not for home child care agencies.  I will get to family child care in a later post. 

  1. B2C2 and others have called for a funding formula similar to the one in Prince Edward Island; is Ontario’s new funding formula like PEI’s?

Ontario’s funding formula is not like PEI’s.  The allowed costs in PEI are based on the provincial wage grid for child care staff with wages varying by qualification level and experience.  PEI’s formula encourages hiring of staff with higher qualifications because operating funding is increased to cover actual wage costs.  Then, PEI has an allowance of 20% for benefits and there is a provincially-funded pension plan.  And PEI’s formula provides the same revenues across the Island for similar centres.

In contrast, Ontario does not have a wage grid for child care staff.  Ontario’s new funding formula gives flexibility to a centre to spend its allocation in different ways, but does not, in particular, reward the hiring of more staff who are fully qualified RECEs.  Ontario’s benchmark for benefits is only 13.4% for staff and 16.2% for Supervisors and there is no provincially-funded pension plan.  And operational funding for centres under the new funding formula in Ontario will be highly variable across different locations.

2. How is the Funding Formula structured?

The structure of the new Ontario child care funding formula is relatively simple, getting more complex as you get into the details.  The funding formula is based on calculation of what is called a “Benchmark Allocation”.  A Benchmark Allocation, as the Ministry of Education’s funding rules make clear, is supposed to represent “the typical costs of providing quality child care in a geographic region, based on planned operating spaces.”  (p. 9) . One of the Ministry’s goals with the new funding and accountability processes is “to gradually shift the overall cost of providing child care … towards more standardized costs, as represented by the benchmark allocations.” (p. 48).  On top of the Benchmark Allocation, there is also an allocation for profit or surplus.

Benchmark Allocations, which vary across the province, are designed so that about 50% of existing licensees will have their expected eligible costs fully covered.  The other 50% of licensees will not have their costs covered by the regular (benchmark) funding allocation, but legacy centres (those currently and continuously in CWELCC) with higher costs will be eligible for a Legacy Top-Up to this funding.  This top-up formula evaluates the 2023 cost structure of centres, along with 2025 evidence of some fixed costs such as rent, insurance and property tax. There is also a provision for cost increases since 2023.

Calculation of the Benchmark Allocation for a centre involves two parts:

  • Calculation of the Unadjusted Benchmark Allocation (total of four components)
  • This is multiplied by a Geographic Adjustment Factor (GAF) which can move the total up or down. 

Once adjusted in this way, our calculation is called the “Benchmark Allocation” for your centre. 

3. What About Top-Ups?

That’s not the end of it, though.  When the Ministry canvassed existing centres about their actual costs, they found lots of variation.  To account for this cost variation, the Ontario funding formula includes a Legacy Top-Up to provide additional revenue for legacy centres with costs higher than their Benchmark Allocation. 

In addition, there is another revenue top-up that applies only to new spaces or new centres.  This is called a Growth Top-Up and recognizes that the Benchmark Allocation will not necessarily be sufficient to cover operational funding of new capacity.  The Growth Top-Up will provide some increased operating revenues to most centres that are new or growing in capacity. 

Details on the Top-Ups

  • Legacy Top-Up – If you are a legacy centre (you were signed up to CWELCC when this funding formula was born and still are) and your proven costs (according to a formula) are higher than that Benchmark Allocation, your SSM will provide a Legacy Top-Up to cover these supplementary costs. 
  • Growth Top-Up – In the first year of any expansion, you will be eligible for a Growth Top-Up which recognizes the (higher than benchmark) program costs associated with new spaces that come on stream during the year.
  • In years after 2025, a centre that received either of these two top-ups will receive a “Rolling Top-Up” based on the calculated top-ups that were received in 2025.  In other words, these top-ups will become permanent in revenue calculations after 2025.

The “Program Cost Allocation” is the name the new funding system will use to describe the sum of your Benchmark Allocation plus any top-ups for which you are eligible

All of the above calculations are based on an annual operating plan for the coming year that each centre submits to its SSM.  Funding is determined based on the plans for each centre. 

Amongst other things, the operating plan will specify the planned number of operating service days for each age group and the planned number of operating spaces for each age group.  In order to calculate the amount of operating money the SSM will give you, the SSM must then subtract the amount of fee revenue (adjusted for enrollment shortfalls) you expect to receive from parents, or on behalf of parents who receive Child Care Subsidy.

It is important to note that funding is not aggregated across centres that have the same licence-holder, so that the funding allocation for a centre has to be spent on the costs of that specific centre.  This will, no doubt, cause problems for multi-site operations who are used to planning and funding activities across the group of centres, rather than treating each centre separately.

4. More details about Top-Ups

The funding guidelines describe Legacy Costs this way: “Legacy costs are costs that are consistent with legacy centres’/agencies’ 2023 cost structures, adjusted for eligibility, cost escalation, and changes to operating practices and fixed costs.”  Legacy Top-Ups are designed to ensure that Legacy Costs are covered going forward.  In applying for a legacy top-up, centres would provide an audited 2023 Statement of Operations and other financial information to their SSMs to calculate the cost of eligible services (e.g., for children 0-5 rather than 6-12) at the level of an individual licence.  From these costs, ongoing costs would be scaled up to reflect cost increases between 2023 and 2025.   This would allow the calculation of the amount by which Program Cost revenues need to be scaled up  to cover higher costs.  This is the Legacy Top-Up.  The Legacy Top-Up will take account of changes in spaces, days and hours of service over this period.

There is also a Growth Top-Up for all centres that are adding new spaces.  Before the calendar year begins, the annual revenues of each centre are determined by their SSM based on operational plans filed with the SSM.  For centres that expand licensed capacity during the year, an adjustment needs to be made.  This is the Growth Top-Up.  The calculation of revenues for these new spaces is largely similar to the calculation of the Benchmark Allocation, but applied only to the new spaces and with the allocation raised by a Growth Multiplier.  Importantly, there is no Legacy Top-Up on new spaces, even if other centres operated by the same licensee receive Legacy Top-Ups because of elevated costs.   The new Benchmark Allocation is multiplied by a Growth Multiplier.  This Growth Multiplier may add as little as 0% to the funding for these new space (City of Cornwall) or as much as 30% (County of Lanark, United Counties of Prescott and Russell, County of Renfrew, Rainy River DSSAB), based on geography. The typical value of the Growth Multipliers is about 15%.

Once these top-ups are added to the Benchmark Allocation for an eligible centre, the total is called the Program Cost Allocation.

5. What about Profit or Surplus?

The new Ontario funding formula has one more major component.  It builds in a separate allocation which goes as profit for owners or as surplus for non-profit or public child care centres.  Profit/surplus therefore does not depend on good performance, but is a guaranteed payment.  On the other hand, the formula provides a limitation on the amount of profit that can be earned in any year out of the government portion of revenues.

There are three parts to the calculation of profit/surplus (which the Ministry guidelines call “allocation in lieu of profit/surplus”).  There is a base amount, a part that is 3.5% times the amount of the Benchmark Allocation and a part that is 4.25% times the Program Cost Allocation (which is the sum of the Benchmark Allocation and the top-ups).  These three parts are added together to get the total Profit/Surplus allocation.  Both the Benchmark Allocation and the Program Cost Allocation are influenced by the Geographic Adjustment Factor.  That means that the amount of Profit/Surplus is also affected by this GAF.

6. How are the individual parts calculated that make up the Benchmark Allocation?

There are four components that are summed together to get the Unadjusted Benchmark Allocation: the Program Staffing Component (related to the wages and benefits of program staff), the Supervisor Component (related to the wages and benefits of the Supervisor), the Accommodation Component, and the Operations Component (related to all other costs, including wages and benefits of non-program staff).  These are calculated based on the number of licensed spaces for different age groups, the operating capacity this year for different age groups, the proportion of staff in your centre that are delivering CWELCC-eligible services, the number of service-days of child care you provide to each age group over the year and a few other things.  All of these calculations are based on your plans for your child care program in the coming year, not on past numbers.

In effect, each of the four components is adjusted according to a Geographic Adjustment Factor, although this calculation is  done at the end after the four components are summed together.  In other words, if you are in what the Ministry’s data says is a high cost area, the amounts for each element of this allocation will be boosted.  If you are in what the Ministry’s data says is a lower cost area, the amounts for each element of the allocation will be lowered. 

For example, centres in Toronto have a Geographic Adjustment Factor of 1.07; centres in Kingston have a Geographic Adjustment Factor of 0.79.  So, the benchmark revenue allocation in a Toronto centre will be boosted by 7%.  The benchmark revenue allocation in Kingston will be reduced by 21%.  These Geographic Adjustment Factors are said to represent differences in the costs of providing child care services in different parts of the province.

7. Can you provide a  simple example of how the Benchmark Allocation is calculated?

(There are some helpful worked-out examples from page 55 onwards in Schedule D of the Funding Guidelines.  But, the example below provides some additional words of explanation).

As an example, think of a child care centre in a community setting in Toronto that has 48 preschoolers and no other children, just to make calculations simple.  We will assume that the licensed capacity and actual operating capacity of the centre is 48 children.  The per-diem benchmark allowed in the funding formula for 2025 for preschoolers (full day child care for children over 2.5 years) is $39.23.  Assume the centre will be in operation 261 days per year.

To get the amount of the Program Staffing component, we multiply 48 preschoolers X 261 service-days per year X a per-diem of $39.23. X an ancillary costs multiplier (13.4% to cover mandatory benefits like CPP/EI/EHT/WSIB).  In the case of our example, that gives us an amount of $557,330.88. 

To get the Supervisor component of the Program Costs, we multiply 261 service-days per year X a Supervisor per-diem of $301.38 X a Supervisor ancillary costs multiplier (16.2% to cover mandatory benefits).  That gives us a total of $91,403.13.

The allowance for Accommodation costs is based on the number of licensed spaces, independent of current operating capacity.  In our example, there are 48 licensed spaces.  The annual per-space benchmark varies according to the age category of these licensed spaces, but also by whether the centre is in a community setting or is located in a public school.  For preschool spaces in a community setting, the benchmark is $1,735.54 per space.  For this centre, the Accommodation costs component would be 48 X $1,735.54 = $83,305.92.

The Operations Costs component has both a fixed and a variable part to the calculations, and varies according to whether the centre is in a community setting or a public school. The fixed part is based on the number of licensed spaces and the annual number of days of service and this varies by age category of children.  The variable part is based on the planned operating capacity and the number of days of service and this also varies by age category of children.  The community-setting benchmark for fixed operations costs for preschoolers is $15.09 per licensed space-day.  The community-setting benchmark for variable operations costs for preschoolers is $1.64 per operating space-day.  So, for our example, the fixed part of operations costs would be 48 X 261 X $15.09 = $189,047.52.  The variable part of operations costs would be 48 X 261 X $1.64 = $20,545.92.  The total allocation for operations costs would be $209,593.44.

If we sum the allocations for the four components in our example, we get $557,330.88 + $91,403.13 + $83,305.92 + $209,593.44 = $941,633.37.  This is the Unadjusted Benchmark Allocation.

This calculation would be the same for any centre with 48 preschoolers anywhere in the province.  However, the Geographic Adjustment Factor (GAF) will change this allocation in every location.  Toronto has a Geographic Adjustment Factor of 1.07 (i.e., relatively high typical costs) so multiply the Program Costs number by 1.07 to get $1,007,547.71.  With the GAF applied this is called the “Benchmark Allocation”.  To see the importance of this Geographic Adjustment Factor: if this same centre was in Kingston, the Benchmark Allocation would be $743,890.36.

It is important to note that this allocation can be spent in any way the centre thinks best to provide services for children.  It can pay lower or higher wages,  more or less in benefits, more or less to the Supervisor, more or less in mortgage or rental costs, more or less in the costs of operations, as long as these expenditures are judged to be eligible expenditures.  The flexibility in spending is potentially positive, but without a wage grid (there is only a wage floor for RECEs), it means that unscrupulous operators could cut corners on compensation and quality in order to spend money in other ways.  That would be undesirable, of course.

8. What about the calculation of profit/surplus for this centre?

The base amount of profit/surplus is $6,000 annually.  For our example centre of 48 preschoolers in Toronto, the part based on the Benchmark Allocation would be 0.035 X $1,007,547.71 = $35,264.17.  Because we are assuming no Legacy or Growth Top-Ups for this centre, the Program Cost Allocation is the same as the Benchmark Allocation.  Therefore, the part of profit/surplus based on the Program Cost Allocation is 0.0425 X $1,007,547.71= $42,820.78.  The sum of these three parts is the allocation in lieu of  Profit/Surplus, which is $84,084.95.

The total revenue of this centre during the year would be the Benchmark Allocation of $1,007,547.71 plus the Profit/Surplus allocation of $84,084.95, which equals $1,091,632.66.  Profit/Surplus would be 7.7% of total revenue.  Another way of thinking of it: profit in this example is a markup of 8.3% over the Benchmark Cost Allocation.

Not all of this revenue would come from the SSMs of course.  The planned amount to be received from parents or on behalf of parents (adjusted for enrollment) would be subtracted from this total revenue calculation to get the annual funds received from the SSM.

9. Does the new funding formula provide enough funding?

This, of course, is the big question.  I need you to help me answer this.  I have some examples in the table below and they give calculations of the total amount of revenue centres will have, based on their size and location in the province.  The examples are simple and do not include provision of before-and-after school care for kindergarten children.  There are three centre sizes:

  • 49 children: 10 infants, 15 toddlers, 24 preschoolers
  • 73 children: 10 infants, 15 toddlers, 48 preschoolers
  • 88 children: 10 infants, 30 toddlers, 48 preschoolers

These centres are located in Toronto, Ottawa and Windsor.  Toronto has a Geographic Adjustment Factor (GAF) of 1.07.  Ottawa has a GAF of 0.94.  Windsor has a GAF of 0.80. These Geographic Adjustment Factors play a big role in the revenue totals that centres will receive and these examples are a good indication of the range of revenue values that will affect centres across Ontario, urban and rural, north and south.   The other factor that affects funding is whether the centre is located in a community or in a publicly-funded school.  This affects funding allocations for Accommodation and for Operations.

This table calculates the total annual revenue of these centres. Total revenue includes both the amount to cover costs and the amount to cover profit or surplus.  Some of total revenue will come in funding from the SSM and some will come from parent revenue (or child care subsidy revenues provided on behalf of parents).  As parent fees go down, a greater percentage of revenues will come from government and a smaller percentage from parents, but the total revenue would remain the same (unless benchmarks are changed).


Table 1: Total Annual Revenues of Centres of Different Sizes and Locations

Under Ontario’s New Funding Formula – Community-Based and School-Based Centres

Toronto Ottawa Windsor
Community-based or School-based centreCommunityCommunityCommunity
Geographic Adjustment Factor - GAF1.070.940.8
Total Revenue – 49 space centre$1.394m$1.226m$1.044m
Total Revenue – 73 space centre $1.884m$1.656m$1.410m
Total Revenue – 88 space centre$2.283m$2.006m$1.709m
TorontoOttawa Windsor
Community-based or School-based centreSchoolSchoolSchool
Geographic Adjustment Factor - GAF1.070.940.8
Total Revenue – 49 space centre$1.291m$1.135m$0.967m
Total Revenue – 73 space centre $1.731m$1.522m$1.296m
Total Revenue – 88 space centre$2.098m$1.844m$1.570m

Notes:

  • Total Revenue figures in the table are in millions of dollars of revenue annually, including both operating funding from governments and parent fees.
  • 49 space centre has 10 infants, 15 toddlers, 24 preschoolers, all full-day
  • 73 space centre has 10 infants, 15 toddlers, 48 preschoolers, all full-day
  • 88 space centre has 10 infants, 30 toddlers, 48 preschoolers, all full-day

Notice that for the same sized centre, a location in Toronto will get revenues which are hundreds of thousands of dollars higher than a location in Windsor (or many other places across the province).  Are true underlying costs that different in different locations? 

And, are these amounts of total revenue enough to operate centres and provide good quality child care?  I don’t have enough evidence yet to draw a conclusion, but I’m happy to hear from centre directors about your example and experience.

These calculations are based on Ontario’s 2025 benchmarks.  Benchmarks can change in future years.  Current centres will be potentially eligible for Legacy Top-Ups.  And, allocations for new centres will be affected by Growth Multipliers (but not Legacy Top-Ups).

10. What is the role of the SSMs?

The SSMs have many roles in relation to planning and operationalizing growth plans and assisting and communicating with child care providers in a range of different ways.

If we focus specifically on their role in relation to funding in 2025, the SSMs have to:

  • Receive operational plans from each operator/each centre.  Operating plans will include planned operating spaces for each age group, planned number of service days for each age group, number of hours of service for each age group, copy of parent handbook. 
  • Collect legacy data from those operators claiming a Legacy Top-Up.  Legacy data in 2025 will include specific evidence of any fixed costs (especially accommodation costs), the operating budget for 2025, 2023 audited financial statements and any related financial reports to support claim.
  • Calculate the Program Cost Allocations for each centre including the Legacy Top-Ups, the Growth Top-Ups and the Profit/Surplus for each centre.
  • Schedule advance payments for each centre based on these calculated Allocations
  • Select centres that will have their reported costs reviewed in a cost review (not the same as the Direct Engagements on Compliance) and carry out cost reviews
  • Accept and process applications for in-year changes in funding
  • Collect spending attestations and standardized financial reports from each centre
  • Compare Allocations to Actual Costs/Spending and promptly recover overpayments to centres and refund these to Ministry.

11. What are the key issues with this new funding formula?

The biggest issue with the funding formula is one that is not yet answered.  In new centres and new spaces, will there be enough funding available for providers to fund the provision of good quality care with educators and other staff that are fairly and reasonably compensated?

The Legacy Top-Ups in the funding formula are designed to ensure that existing centres with costs that are higher than the median will not have to close their doors; their costs will apparently be compensated by revenue supplements that become permanent through Rolling Top-Ups.  That’s obviously a good thing, but Legacy Top-Ups are not available to new centres or even to new spaces in existing centres. 

So, in judging the adequacy of revenues provided by this funding formula going forward, we need to ignore Legacy Top-Ups.  They exist for Legacy centres (i.e., current centres), but not for new centres.  The real question is “for new spaces (growth), will the revenues be adequate to provide good child care?”.   At this point, we don’t have a clear answer.  What we do know is that new spaces will only be eligible for the Benchmark Allocation  plus the Growth Top-Up plus the Allocation in Lieu of Profit/Surplus. 

As for the rest of the key issues with this new funding formula, that’s a topic for another blog.  Coming soon.

Affordable Child Care Services vs Money for Parents

Those who oppose the $10 a day program often argue that there is a simple and better program to replace it – give money directly to parents instead.  The logic is, at first glance, persuasive.  If you give parents money, it seems like they should be able to purchase exactly the child care they need.  And competition among different providers should, you might think, keep fees down.  Programs that directly fund child care services, like the $10 a day program, are said to be bureaucratic and inflexible and to create huge shortages and long waiting lists. 

There is some truth here, but much falsehood, and much deliberate ignoring of the evidence on the impact of a “family allowance” approach.  I have just written a report for The Prosperity Project that examines the likely impacts of giving parents money instead of funding and providing child care services that parents can use.  I unearth a lot of new data about families that are using child care in Canada and the number of parents who want access to affordable, accessible, high quality child care. 

The evidence shows that this type of “family allowance” fails as public policy because it:

(a) isn’t what most families want

(b) doesn’t address families’ needs for child care

(c) would be much more expensive than the $10 a day program

(d) would have negative effects on women’s employment and the economy, and would increase the gender-based child penalty that mothers pay with reduced earnings

(e) has been tried before and hasn’t solved child care issues, and

(f) ignores the very large child benefit programs that already provide money to parents.

You should read the report in full (19 pages), or at least its Executive Summary (3 pages).  Below, I provide a few tidbits to encourage you to dig deeper.

  • As of 2023, when Statistics Canada collected large amounts of data from parents about child care and employment, there are 938,000 Canadian children using licensed or accredited child care services – the kind of services supported by the federal government program.  In fact, over three-quarters of children using any kind of child care are in licensed care.   In 8 of Canada’s 13 jurisdictions, average fees for this child care is down to $10 a day or less.  Other jurisdictions have lowered fees by at least half relative to fee levels in 2019-20.  In other words, although the press scarcely covers it, a very large number of Canadian children and families are already benefiting from licensed child care that is subsidized to be affordable and more accessible.
    • Licensed child care is not the only part of the set of services and benefits that will make up a fully developed early learning and child care system.  Many children benefit from full-day or part-day kindergarten at ages 4 and 5 years.  Many children and families benefit from paid maternity and parental leave for up to 12 or even 18 months.  If we put these all together, it is already true that in 2023 over 1.5 million children currently benefit from Canada’s early learning and child care and leave arrangements.  That is about 2/3rds of all children 0-5 years of age.  
    • Some people think that the reason some parents don’t currently use child care is because they don’t want to.  But, outside Quebec, most families (58%) that currently do not use any child care would like to use some type of non-parental child care if they can find what they need and want.  And, of these, the lion’s share – 62% – would like to use licensed child care, largely as a means to join or rejoin the workforce. 
    • Some people argue that it is mostly affluent parents that benefit from universal child care programs and that marginalized families and those from diverse backgrounds are left behind.  That is certainly true of market-based child care systems when fees are not controlled; high parent fees are only affordable by affluent families and many vulnerable families do not qualify for income-based subsidies.  However in fixed-fee systems like the $10 a day program, families from all backgrounds gain access.  I show a series of charts from Quebec making this point.
    • A family allowance program would have to give parents an amount of money that was equivalent, on average, to what they gain by having $10 a day child care.  This family allowance program would cost the federal government just over $28.5 billion annually and its net cost would be three times as much as the cost of providing child care services.  
    • Women who have children suffer substantial losses in earnings after the birth of a child.  Economists have found that mothers’ earnings decrease by 49% in the year of a child’s birth.  Even ten years later, women suffer from an average earnings loss of 34% relative to their earnings before childbirth. Universal child care has been found to substantially reduce these “child penalties”.  In other words, accessible child care services make an important contribution to increasing gender equity.

    Please read the full report and executive summary

    Ontario Is Violating the Early Learning and Child Care Agreement

    Most child care in Ontario is provided by non-profit or public operators.  This has been true for years.  A full 70% of the licensed/regulated child care spaces for children 0-5 were non-profit or public back in 2022, when Ontario signed the Canada-Wide Agreement with Ottawa. 

    So, two things are not in doubt.  First, it is obviously possible for non-profit and public child care services in Ontario to grow and expand, given the right conditions.  They have done it successfully in the past, more successfully than the for-profit child care operators.  Second, the Ontario government, with the support of municipal governments and school boards, knows exactly how to facilitate and co-ordinate the expansion of non-profit and public child care, because it has done this in the past.

    So, if non-profit and public child care are not expanding rapidly in Ontario, it must have to do with the failures of Ontario government policy (as described in my recent blog post). 

    • Ontario has failed to fix shortages of early childhood educators.  Starting wages in Ontario are $5.00 an hour less than in P.E.I.!
    • It has failed to provide or enable sources of capital funding for expansion of community non-profit child care. 
    • It has starved child care providers of revenue in the $10 a day program and has failed to provide any certainty about future revenue streams for operators.
    • Ontario has failed so comprehensively that you have to wonder if the failings are deliberate. 

    To cap it all off, we now find that Ontario is deliberately violating the terms of the Canada-Wide Agreement that it signed with the federal government back in March 2022.   Ontario promised to increase child care capacity by at least 86,000 spaces, and it promised that a maximum of 30% of these new spaces would be operated by commercial for-profit operators.  The balance would be community-based or school-based non-profit and public child care.  It also promised that it would prioritize development of child care in underserved areas and amongst families with greater needs. 

    Instead, about 75% of the expansion that has occurred has been in for-profit spaces.  And at least half of the new spaces are in areas of greater profitability rather than areas of greater need.  Half of the new spaces can charge whatever fees they want, rather than being affordable spaces. 

    We know some details about Ontario’s expansion because of good journalism by Allison Jones of Canadian Press.  She has recently written:

    “Ontario’s deal committed the province to 86,000 new child–care spaces since 2019, though the deal was signed in 2022. But so far while there have been about 51,000 new spaces since 2019 for the kids five and under, the age group covered by the national program, only 25,500 of those are within the $10-a-day system.”

    So, let’s do the math:

    • Pretty well all of the new spaces that are outside the $10 a day system (without any controls on fees) are for-profit, so that is already half of the 51,000 spaces. 
    • Much of the growth inside the $10 a day system is also for-profit.  When Ontario published its Action Plan in 2022 it told us that 15,000 spaces had  opened since 2019 and 45% of this was for-profit. 
    • A further 21,200 spaces were said to be “in the pipeline” and 66% of this was for-profit. 
    • I estimate therefore that about half of the growth since 2019 that is inside the $10 a day system is for-profit (the Ministry of Education has these figures and is shy about releasing them, which tells you that they know they have something to hide). 
    • In other words, about 75% of the total of 51,000 new spaces in Ontario since 2019 are in the for-profit sector.

    This is a clear violation of the Canada-Wide Agreement Ontario signed in 2022.  In that agreement it promised that “at the end of this Agreement, the proportion of not-for-profit licensed child care spaces for children age 0 to 5 compared to the total number of licensed child care spaces for children age 0 to 5 will be 70% or higher.” (emphasis added).  The agreement clarifies the purpose of this clause: “to ensure that the existing proportion of not-for-profit licensed child care spaces for children age 0 to 5 will be maintained or increased by the end of this Agreement.”

    In case there was any doubt, the “definitions” section of the agreement refers to the Child Care and Early Years Act, 2014 in defining licensed child care.  In other words, it refers to all licensed child care governed by that act.  

    So, Ontario is taking federal money intended to build a publicly-managed, affordable and accessible high quality child care system and it is not doing what is necessary to provide spaces for children and families.

    Of course, parents who are desperate for child care spaces right now don’t care if the spaces are for-profit, non-profit or public.  They  just want a space for their child and they want it now.  The negative effects of relying on for-profit child care without sufficient controls won’t show up for a while. 

    That’s what happened in the early 2000s when the Government of Quebec, under Jean Charest, tried the same trick – relying on for-profit child care for expansion.  The results were disastrous for the quality of child care services, with nearly half of the new for-profit centres failing quality assessments sponsored by the Quebec Government.  Similar quality problems are what led  Mathieu Lacombe, the Quebec Minister of Families from 2018 to 2022 to say that allowing for the expansion of private daycare, was the ‘biggest mistake the Quebec government committed in the last 25 years.”  

    As I wrote in that recent blog:

     I am not trying to say that all for-profit operators provide poor quality child care or that all of them skimp on child care staffing.  Some small for-profit operators provide good quality care and devote themselves to quality improvements.  You can have a certain percentage of for-profit providers in a publicly-funded child care system, but there need to be strong measures of public management that limit the ability of for-profit enterprises to extract profit at the expense of quality. 

    That was the spirit of the Agreement that Ontario signed up to  in 2022.  If Ontario were to implement this agreement in good faith, it would adopt a generous funding formula to cover actual costs, it would make expansion of child care into an all-of-government priority with a range of provisions for capital financing, it would develop a wage grid for child care educators that is at least as generous as the one in PEI and it would implement the agreement it signed on the balance of non-profit and for-profit expansion.  Ontario’s parents and children need the $10 a day child care system they were promised.

    Who’s To Blame For Child Care Shortages In Ontario?

    Todd Smith is Ontario’s new Minister of Education and he has already decided who he wants to blame for Ontario’s child care shortages – it’s the federal government.  So, Todd Smith wants federal minister Jenna Sudds to release Ontario from the agreement it signed back in 2022 that limits expansion by for-profit enterprises to a maximum of 30% of the total expansion.  Ontario never wanted to limit for-profit expansion;  apparently they only signed the agreement under duress.

    The problem of child care shortages is a real one.  We need a lot more child care expansion in Ontario and we need it now.  We will need even more child care when Ontario drops the parent fee down to $10 a day.

    But Todd Smith doesn’t seem to understand why Ontario is facing such a shortage of child care spaces, so he’s coming up with solutions that are antithetical to the high quality universal child care we have been promised.  He’s new in his job, so let’s give him a primer:

    • Ontario knew very well that there would be a huge shortage of child care spaces.  The Financial Accountability Office of Ontario told them this in November 2022;
    • The solutions are well known. Ontario’s officials and politicians were told by many people – including me and the Financial Accountability Office – what steps they needed to take to make child care expansion happen;
    • Instead of implementing these solutions, Ontario has fumbled and delayed and prevaricated and done nothing, or very little, to facilitate the child care expansion that is needed;
    • Now, Ontario wants to blame the federal government for Ontario’s failures to provide new child care facilities for parents and children that need it.  Some blame is due to the federal government, but Ontario is the one with the responsibility and capacity to fix the shortages;
    • It is true that for-profit child care providers are quicker to assemble capital funding than non-profits, but there are serious long-term costs.  Ontario knows well how to facilitate non-profit and public child care expansion; its current child care system has been built primarily this way. 
    • Quebec’s experience makes it clear that  relying on for-profit child care can come at a substantial cost in child care quality, which Todd Smith is ignoring.

    Ontario knew there would be a substantial shortage of spaces

    In November 2022, the Financial Accountability Office of Ontario (FAO) reported to the Legislative Assembly that at $10 a day, Ontario parents would need 300,000 additional child care spaces.  Demand would increase by that much.  They compared that to the 71,000 additional spaces that Ontario was planning to add between 2022 and 2026.  The FAO’s conclusion was that when parent fees reach $10 a day “…the families of 227,146 children under age six (25 per cent of the projected under age six population of 919,866 children in 2026) would be left wanting but unable to access $10-a-day child care.”

    I had published similar estimates in May 2021.

    Ontario has promised an additional 86,000 new child-care spaces compared to 2019.  As Allison Jones article for Canadian Press tells us, so far there have been about 51,000 new spaces created in Ontario, with only half inside the $10-a-day system.

    Ontario knew what to do to expand child care

    The FAO, in its understated way, had already identified one key barrier to expansion that Ontario should deal with.  Its November 2022 report stated that “…uncertainties over some aspects of the $10-a-day child care program, such as the extent of ministry reimbursement of future cost increases to child care providers, could reduce incentives for child care providers to create spaces.”   In other words, if child care providers do not know whether revenues will be enough to cover their legitimate costs, they won’t decide to expand. 

    Working with Building Blocks for Child Care (B2C2), I wrote and circulated widely a paper and a blog post laying out the steps needed to facilitate the expansion of non-profit and public child care:

    1. A system of capital grants and loan guarantees for not-for-profit and public operators
    2. Creating public planning mechanisms with provincial, municipal, school board and community members
    3. An inventory of publicly-owned lands and buildings suitable for child care expansion
    4. Mandate where possible the co-location of licensed child care services whenever business and housing developments happen
    5. Explore the use of Land Trusts to preserve the preservation of child care assets in public hands for future generations
    6. Use provincial legislation and regulations to control transfers of child care assets and ensure they are not controlled by big-box corporate child care chains
    7. Early guarantees of operational funding and licensing of not-for-profit and public operators that plan expansion following public plans.
    8. Development and implementation of a province-wide salary and benefits grid and much more funding to increase compensation of educators and other staff. Recruitment and retention of qualified educators is Job #1.
    9. Transparent and effective future funding guidelines to support expansion. Assistance to municipalities to implement financial accountability measures in a long-term funding model.
    10. Public funding of organizations such as B2C2 that support not-for-profit operators to negotiate hurdles associated with expansion of child care services

    Ontario has done very little to facilitate expansion

    Ontario thought that child care expansion would be a natural process, not requiring much government support.  Based on what Ministry of Education officials told the FAO “The ministry plans to create 71,000 net new spaces through what it terms natural growth (48,459 spaces) and induced demand (22,406 spaces)”  (FAO Report, 2022). Except the “natural growth” has not happened.  Here’s why.

    In Ontario:

    • Operators do not know what their future revenues will be or what factors will generate more or less revenue.  Their future revenues will be governed by the new funding system which Ontario promised in 2023 and again in 2024 and now will come in 2025.    Ontario still has the funding arrangement it invented on-the-fly on day one of the new child care system.  Which was to just replace the exact amount of the fee that child care centres charged on March 27, 2022.  But as anyone who has lived through the last few years would tell you, the costs of everything have been changing a lot in the last while.  And since, in the child care sector, there are substantial shortages, costs of some things have been rising substantially. 
    • There is very little funding support for expansion of child care centres.  There is start-up funding to pay for toys and equipment, but no capital grant program for community child care.  There has been capital money for new centres on school board premises, first announced in 2019 (i.e., expansion planned before the $10 a day program), but now even expansion in 56 of these school board centres has been cancelled by the Ontario government. 
    • In the midst of a huge shortage of early childhood educators – estimated by the Ministry of Education as a shortage of 8,500 new educators by 2026  – the support by the Ontario Government for staff wages is stingy at best.  In Ontario the base wage rate for an early childhood educator is $23.86 per hour, while the average hourly wage of all Ontario employees is $36.14 per hour.  In PEI, the base wage rate for an early childhood educator is $28.36 per hour, and the average hourly wage of all PEI employees is the same – $28.36 per hour.  There are huge child care staff shortages in Ontario, but not in PEI.

    We know that Ontario is able to expand capacity quickly if it were to be a priority.  In 2010-2014, Ontario provided expanded classroom space for about 280,000 children who moved from half-day kindergarten to full-day kindergarten.  All of that expansion in only 5 years.  Because it was a priority.  The financial and personnel resources were mobilized to make it happen.  But, the expansion of child care for the tens of thousands of Ontario children who want access is clearly not a priority for this government.

    Having committed itself to building an affordable, accessible child care system largely with federal money, the Ontario government decided to sit on its hands and let the system fall apart.  They did the easy part.  They lowered parent fees, initially by 25% and then approximately by another 25%, so that parent fees are much lower than they were.  So, demand for child care has skyrocketed.

    But the Ontario government has not done the hard parts – reducing workforce shortages by raising compensation, providing substantial capital and management supports for child care expansion, and implementing a funding system to provide guaranteed operating revenues for providers.

    So, now there are shortages.  And the Ford government has been sitting on its hands, waiting for the crisis to get worse. 

    Ontario wants to blame the federal government

    This was a sweet deal for Ontario, because the federal government committed to turning over a huge whack of money to Ontario to make this happen. In the first  year (which was virtually over by the time Ontario had signed the agreement), the federal government provided $1.1 billion for Ontario child care.   In every year after that the federal contribution to child care in Ontario has risen and will reach just less than $3 billion in 2025-26.  By this time, the federal government will be paying about $3 for every $2 spent by Ontario to support providing child care for Ontario’s children and families.

    There are elements of blame that the federal government should wear.  The reforms should have been phased in more slowly, so that demand did not ramp up so fast.  And, the federal government will need to provide more money – there is not enough to support child care for an additional 300,000 children that the FAO predicts will want child care.

    But the federal government has now put over $1 billion on the table in reduced-interest loans and another $625 million distributed to provinces for capital grants to support child care expansion. Ontario will get the largest share of those amounts.

    If Ontario does not do the hard work of…

    • reducing workforce shortages,
    • providing supports for child care expansion by nonprofits and public agencies, and
    • providing operating revenues with an equitable and sufficient funding system,
      then sufficient child care expansion will not happen in either the for-profit or the non-profit and public sectors.

    For-profit expansion is easier but more dangerous

    When it comes to growth, for-profit child care providers have structural advantages over not-for-profits.  Not-for-profits are frequently unwilling to go into debt, so there needs to be a program of capital grants and encouragement to access low-interest loans to pay for the costs of building new facilities or repurposing existing buildings.

    The mission of for-profit businesses is to make a profit, so expansion is a natural fit, particularly when the government is paying  80%-90%  of the operating costs and providing a guaranteed demand for services.  Shareholders or banks are always willing to ante up when the government is willing to provide guaranteed funding for profit-making businesses.  They are not used to providing similar supports for non-profits in the child care sector.

    But there are ways around these structural barriers faced by not-for-profits.  Not-for-profits need two main things if they are to build new capacity quickly.  First, is access to capital.  Some of this should come in the form of capital grants to not-for-profits or municipalities or school boards who are willing to move quickly.  Some of this can be in the form of low-interest loans, like those that will soon be available from CMHC.  Governments should guarantee the loans, but most importantly, the Ontario government needs to ensure that there will be ample operating funding for child care centres to pay back the loans over time.

    The second thing that not-for-profits need is a development champion – a development agency that specializes in handling all the details involved in building new capacity or renovating existing capacity.  This is familiar territory for co-operative housing or not-for-profit housing developments.  There are specialized agencies that handle the housing development and then turn the housing over to co-ops or not-for-profit housing agencies to manage and operate.  This should be the case for child care as well.

    Neither of these barriers is particularly insurmountable, but they do require governments to facilitate surmounting them.  In many cases, public agencies such as municipalities, school boards, and community colleges can help a great deal in supporting not-for-profit and public developments.  And the provincial and federal governments should be open to expansions of kindergarten integrated with before-and-after school care. 

    Ontario shows that rapid expansion of not-for-profit child care services is very possible.  Over the 10 years up until 2019-2020, centre spaces increased in Ontario by 198,600.  Fully 85% of the increase (168,900 spaces) was in not-for-profit child care. 

    Quebec shows us the terrible cost of expanding mostly in the for-profit sector

    Todd Smith should talk to Mathieu Lacombe, Minister of Families in Quebec from October 2018 to October 2022 in the conservative government of François Legault.  Andrew-Gee in the Globe and Mail quotes Mathieu Lacombe: “Allowing for the expansion of private daycare, he said, was the ‘biggest mistake the Quebec government committed in the last 25 years.’”  

    Of course, Todd Smith could also decide to read the Auditor-General’s report for 2023-24 in Quebec.  This report looked at measured quality levels in child care centres serving children 3-5 years of age.  It also looked at what percent of front-line child care staff are qualified early childhood educators.  The Auditor-General investigated the performance of three types of child care centres – the nonprofit CPEs, the for-profit child care centres that charge a fixed fee, and the for-profit child care centres that are funded by a parental tax credit for child care expenses (and do not have fixed fees).

    For-profit operators are always looking for a way to save money and increase profits.  In child care, saving money generally means cutting back on staffing, because staffing takes up the large majority of the costs of providing care for your children.  Before the pandemic, the required ratio in Quebec was that 2/3rds of front-line staff would be qualified staff – early childhood educators with a diploma.  This ratio was lowered to 1/3rd of staff during the pandemic as an emergency measure but raised to ½ in March 2023.  It  was supposed to return to 2/3rds by March 2024, but the Quebec government had to delay this due to widespread shortages of early childhood educators.

    The table below gives the full story for 2023 in Quebec.  It tells us what percent of the three types of child care centres were below three benchmark levels of child care staffing.  The first benchmark is one-third of staff who are qualified as early childhood educators.  The second benchmark is one-half and the third benchmark is two-thirds of staff qualified as early childhood educators.

    As you can see, the nonprofit centres score much better on the percent of early childhood educators than either of the for-profit categories.  Shockingly, 19% of the for-profit tax-credit-funded centres do not even have one out of every three staff qualified as an early childhood educator.  Over half of these centres do not meet the currently required ratio of one-half of staff being early childhood educators.  And 86% of these for-profits do not meet the 2/3rds requirement that Quebec has been trying to re-establish. 

    Percent of Front Line Staff Who are  Qualified Early Childhood Educators in Non-Profit, For-Profit Fixed Fee, and For-Profit Variable Fee Centres in Quebec, 2023

    % of nonprofit centres% of for-profit fixed-fee centres% of for-profit tax-credit-funded centres% of all centres
    Less than 1/3rd of staff qualified as educators1%3%19%7%
    Less than 1/2 of staff qualified as educators5%19%55%23%
    Less than 2/3rds of staff qualified as educators18%53%86%46%


    Staffing has a big effect on quality, of course.  Quebec has had a program of testing quality in 3-5 year-old classrooms in Quebec centres since 2019.  The Auditor-General summarized the results.  Over the period 2019 to 2023,  36% of “garderies subventionées” – for-profit child care centres that charge a fixed fee – failed the quality examination. In other words, they showed quality levels that had some important problems and were unacceptably low.   Worse than that were the “garderies non-subventionées” – the tax-credit-funded child care centres that are able to set their own fee levels and wages.  47% of these – very nearly half of all centres tested – failed the quality examination over the period 2019-2023.  In line with their greater reliance on qualified early childhood educators, only 11% of CPEs – the nonprofit child care centres that are the heart of the fixed fee system – failed the quality test.

    There is no such thing as a free lunch.  Todd Smith should learn that lesson.  In the short run, you might save money by relying on for-profit child care expansion, because they will find their own capital money, especially corporate child care with deep pockets and those supported by private equity capital.   Pretty soon, however, you will have built a child care system that is offering poor quality services to your province’s children and their parents.  And you know that you will end up paying for the for-profit’s capital expansion in the long run, so you might as well do the work now to encourage non-profit and public child care to take up its 70% share.

    What we have in Quebec is a demonstration of the pernicious effects of unleashing the profit motive in child care – which is what Quebec did especially from about 2009 onwards.  I am not trying to say that all for-profit operators provide poor quality child care or that all of them skimp on child care staffing.  Some small for-profit operators provide good quality care and devote themselves to quality improvements.  You can have a certain percentage of for-profit providers in a publicly-funded child care system, but there need to be strong measures of public management that limit the ability of for-profit enterprises to extract profit at the expense of quality.  The measures of public management are obviously insufficient in parts of Quebec’s child care system.  And Todd Smith cannot be trusted to ensure strong public management in Ontario.   

    Who’s to blame for child care shortages in Ontario?  Look in the mirror, Mr Smith.

    New Support for the Economic Benefits of Universal Child Care

    I met Sebastien Montpetit at the Canadian Economics Association meetings in Winnipeg last year.  He is a Canadian and Quebecer who has been studying for his PhD in economics at the University of Toulouse.  And he, with co-authors, has come up with a really fascinating analysis of the impacts of Quebec’s universal child care program ushered in the late 1990s and the early 2000s. 

    The paper is complex, has multiple parts, and the latest version of it is available here.  It has been selected as one of three finalists for the Canadian Labour Economics Forum prize at the upcoming Canadian Economics Association meetings in Toronto.  I’ll give you the main take-home points right away, and then delve into where the results come from.

    Sebastien’s main conclusions?

    • The importance of the supply of child care services has been underrated.  Greater supply of child care – availability – is as important as improvements in affordability.  In Quebec, the regions that had the largest increases in child care supply had the biggest impacts on mother’s employment and increased child care use.  Lowering fees without increasing coverage has modest effects on the benefits to families.  The bottom line: increasing local child care supply is key to the effectiveness of child care reforms.

    • The economic benefits from improved maternal labour supply in Quebec have been well studied and Sebastien confirms them.  But, there are very substantial non-monetary benefits for mothers too.  Think of this as work-family balance, things like the reduced search time for child care, the shorter distances that have to travelled each day when child care is much more available and affordable. 

    • When all the benefits are summed, benefits total more than 3.5 dollars of benefit per dollar of net government spending – more than twice the benefit that comes from looking only at increased mothers’ earnings.
    • Earnings gains for mothers impacted by Quebec’s child care reforms are concentrated in the fifth through the eighth decile of income. In other words, many of the fiscal benefits to governments of a universal child care reform come from mothers who can earn moderate to reasonably high incomes.  These are mothers who will not be reached by a targeted approach to child care spending.  A universal approach may therefore be more fiscally responsible than targeted child care initiatives.
    • Michael Baker, Kevin Milligan and Johnathan Gruber became renowned for their paper concluding that there were a range of negative effects on children who lived in Quebec during the early years of Quebec’s child care reforms (and may have participated in child care).  Sebastien looks at data on those children many years later and assesses whether their educational development was negatively impacted.  He finds no evidence of this; educational attainment of students in Quebec and the rest of Canada is very much the same.
    • Michael Baker, Kevin Milligan and Johnathan Gruber gained some additional notoriety for a follow-on paper that found increased juvenile criminality amongst Quebec children who were exposed to Quebec’s child care reforms.  Sebastien Montpetit looks at the evidence on juvenile crimes and finds that most of the increased juvenile crime that may have occurred was very minor and that the societal cost is relatively small.

    The main data source for all of his analyses is the National Longitudinal Study on Children and Youth.  He also uses data from the Canadian Censuses of 2016 and 2021. 

    There are four types of analysis that compose this complex paper.  First, with new data on regional child care coverage rates, Sebastien uses a difference-in-differences approach to compare mothers in Quebec to those in the rest of Canada.  He finds that in regions where child care supply increased the most, employment and child care use increased much more when other factors are controlled.

    In particular, in regions where child care supply expanded more, the child care reforms boosted mothers’ labour force participation by 40% more than in other regions

    Further, Sebastien finds that mothers with low levels of education also respond more in these regions with high levels of expansion.

    Results suggest that for high educated mothers with a post-secondary qualification, the main incentive to take up employment was the fee reduction.  For mothers without a post-secondary qualification, access to a space was key. 

    Sebastien uses a non-linear difference-in-differences model to estimate earnings gains across mothers’ income distribution.  Mothers’ earnings gains from the child care reforms are found to amount to $1.42 per $1.00 of net government spending.

    Baker, Gruber and Milligan found that eligible children in two-parent families experienced worse developmental outcomes and lower consistency in parenting.  Other researchers found substantial heterogeneity in these results.  Haeck et al (2015,2018, 2022) found that most negative impacts on children and parental behaviour fade away over time.

    In order to look at children’s educational attainment later in life, Sebastien employs a triple-difference model which compares education levels of same age individuals born before or after the reforms in Quebec to similar individuals in the rest of Canada.

    The paper concludes: “We find no evidence of negative effects on educational attainment of eligible children in the long-run. This pattern is true for each educational level, namely for university, high school, and college completion….

     As a result: “…the negative impacts on child behavior documented by Baker et al. (2008, 2019) do not translate into depressed economic outcomes later in life.” (p. 2)  “…this evidence thus suggests the absence of negative fiscal impacts stemming from eligible children’s economic outcomes in the long run.” (pp. 2-3).[1]

    Triple-difference estimator compares same-age individuals who vary in eligibility status based on the census year and their province of birth.   He finds no evidence of negative effects on educational attainment of eligible children in the long run.  This pattern is true for every educational level. 

    Sebastien Montpetit takes Baker and colleagues’ estimates of increases in youth criminal activity (2019) and estimates what the victimization costs and productivity losses would be.  Using recent estimates of the costs of crime, he finds that these social costs are small.

    Difference-in-differences estimates seek to use good control groups to help judge the effectiveness of some policy change.  So, for instance, children 0-4 years of age in the rest of Canada where there was no major child care reform, might be considered to be a good control group to compare to what happened with children 0-4 or the mothers of those children in Quebec.  Why is it called difference-in-differences?  Because this statistical technique does not compare the level of a variable (like mothers’ labour force participation) in Quebec to the same level in Canada.  Instead, it compares the change in mothers’ labour force participation (called a difference) in Quebec to the change over a few years (another difference) in the mothers’ labour force participation in the rest of Canada.  This analysis is done in a regression framework including other variables, so that we can see the impact of those variables on the policy result.

    Montpetit then estimates a structural model of maternal labour supply and child care choice in order to make inferences about the size of the non-monetary benefits that mothers receive from Quebec’s universal child care system.  The non-monetary benefits are found to be substantial.  Using the model to do additional simulations, Sebastien concludes that these non-monetary benefits are particularly closely related to the availability of child care services in the local area.  He concludes that universal child care policies for children 0-4 can generate substantial social returns.  And he concludes that increased availability of child care is particularly important to these returns.

    Sebastien notes that the quality of Quebec child care in this period was very uneven with CPEs having higher quality and other child care centres having lower quality.   Sebastien is not able to include quality measures in his analyses. 

    Altogether a very interesting, carefully crafted and timely paper.  Congratulations Sebastien and co-authors!


    [1] Montpetit, S., Beauregard, P., & Carrer, L. (2024). A Welfare Analysis of Universal Childcare: Lessons From a Canadian Reformhttps://drive.google.com/file/d/1dDWvj2e08YodXAWd5zdmBKP3j-kxt1Uj/view

    The Fraser Institute’s Evaluation of the $10 a Day Child Care Reforms

    This is not his best work.  Phillip Cross has had a notable career at Statistics Canada.  He’s an expert in macroeconomic trends.  But, one thing that he knows very little about is child care.    Unfortunately, he has written a short paper for the Fraser Institute evaluating the success or failure of the Canada-Wide Early Learning and Child Care reforms so far. 

    It’s bad. Almost everything in the paper is either wrong or misleading.

    So what does Phillip Cross say?

    • He says that the Canada-Wide early learning and child care program had 3 goals:

    (1) providing more jobs in the child care industry,

    (2) enabling mothers to join the labour force, and

    (3) providing better care for young children. 

    His paper will look at the first two.

    • He looks at some evidence and concludes that there has been no change in the employment trends in child care staff.
    • Then, he looks at evidence about women’s labour force participation and concludes that it has hardly changed since 2015.
    • Having concluded that the Canada-Wide child care reforms are a failure, he goes on to take pot shots at Quebec’s child care system concluding that its universal child care system doesn’t really help low-income families, wasn’t really responsible for the boost in its labour force participation, has long waiting lists due to inadequate supply, and isn’t really universal.

    Phillip Cross is wrong on all counts, contributing yet more false information to child care discussions in Canada.  There are many problems with the rollout of the Canada-Wide program across the provinces and territories – particularly slow rates of growth in child care capacity.  However, the Fraser Institute paper does not grapple with real issues and propose real solutions.

    Phillip Cross, believe it or not, ignores improving the affordability of licensed child care in his list of goals of the Canada-Wide program.  This, of course, is the greatest success of the program so far.  Hundreds of thousands of children and families have benefited from less expensive child care.  Their very high child care costs have been cut by half or more.  These parents are very happy with the marvellous success of the program.


    Employment in the Child Care Industry

    There has been substantial growth in employment in the day care industry (NAICS Code 6244) since April 2021 when the Canada-Wide program was announced.  By my reckoning, the number of persons employed in Canada outside Quebec has risen by 36.9%, a total of 32,885 additional persons employed.  Phillip Cross hides this growth in two ways.  First, he looks at Canada including Quebec, which is inappropriate.  Quebec has a mature child care system and its employment of child care staff is not growing quickly.  The focus of growth in the Canada-Wide program is on the provinces and territories outside Quebec.

    Second, Phillip Cross ignores the collapse of child care employment during the pandemic and assumes that child care employment should have grown as if the pandemic did not happen.  In fact, child care employment in Canada outside Quebec collapsed from over 100,000 at the beginning of 2020 to less than half of that a few months later.  Employment did not climb above 100,000 until March of 2022.  So, the Canada-Wide program has helped the revival of employment in the child care industry and gone well beyond.  We should celebrate this, rather than hiding it.  This evidence can be found in Statistics Canada CANSIM Table 14100201.


    Mothers in the Labour Force

    Phillip Cross concludes that the Canada-Wide program has also shown no progress in supporting mothers to enter the labour market.  According to him, labour force participation hit its peak in 2015 and even after all this money spent on child care, it has only just about reached the same level.  As he notes, the participation rate was 61.7% in 2015 and now it is just 61.5%.

    But, Cross is not looking at the right statistics.  He is looking at the labour force participation of all women 25-54 years of age.  However, most women do not currently have a child 0-5 years of age.  Women without young children would not have their labour force participation affected by the Canada-Wide child care program.

    The Fraser Institute report should instead be looking at labour force participation of mothers with children 0-5 who are the target of the program.  Here, participation rates are up by several percentage points from April 2021 to now (from 76.9% to 79.9%) even though expansion of child care has been slower than it should be.  And compared to 2015, which the Fraser Institute cites as the high water mark, the labour force participation of mothers with children 0-5 is over 6 percentage points higher now than it was then.  So this evidence of “failure” is false news and should not be left to become conventional wisdom.  This data can be found in Statistics Canada CANSIM Table 14100397.


    Quebec’s Universal Child Care System

    Phillip Cross would presumably be very surprised to hear that Quebec’s child care system is very popular with parents and with the Quebec government.  He believes that low-income families have been squeezed out of access to child care.  In fact, there is good evidence that a much higher percentage of low-income families in Quebec have been able to access child care than was true for low-income families in the rest of Canada in the period before the Canada-wide system[1]. The universal system of child care in Quebec encouraged many more low income mothers into the labour force and into using child care.  It is true, and a problem, that on average low-income families are more likely to have their children in the lower-quality for-profit child care services.  The Quebec government is expanding not-for-profit centres as a partial remedy.

    Cross claims that Quebec’s child care system is not universal.  His evidence for this seems to be that there are 51,000 families on a waiting list for child care services.  Here his lack of child care knowledge is really showing.  This is a waiting list to get into one part of their child care system – the preferred part with a fixed fee and many better quality services. 

    There is no overall shortage of child care spaces in Quebec; in fact there are many empty spaces in the for-profit child care services funded by a tax credit.  But parents don’t prefer these for-profit spaces where there is no guaranteed parent fee.  These services have been shown to be much poorer quality than the not-for-profit spaces in CPEs (early childhood centres).  So, yes, there are 51,000 children on a waiting list to get out of these tax-credit-funded spaces and into the fixed-fee services that they prefer.

    Finally, Phillip Cross tries to deny that the universal child care system in Quebec has been responsible for dramatic increases in labour force participation of mothers.  He writes that “proponents attribute the increase in female participation in Quebec to its childcare program” and “Clearly, some determinants of female labour force participation are not understood by researchers, who nevertheless loudly endorse Quebec’s initiative.”  This is a bit strange, because if there is one thing that all economic studies of the Quebec child care program are agreed upon, it is that there was a substantial boost to mothers’ labour force participation and hours of work as a result of universal child care.

    A summary of the results of one of the many studies goes like this:  “Lefebvre and Merrigan[2] (2008) use Statistics Canada’s Survey of Labour and Income Dynamics (SLID) annual data from 1993 to 2002. Using the sample of all Canadian mothers with at least one child aged 1 to 5, they find that the policy had substantial effects on a diversity of labour supply indicators (participation, labour earnings, annual weeks and hours worked). In 2002, the effects on participation, earnings, annual hours and weeks worked of the childcare policy are respectively between 8.1 and 12 percentage points, $5,000 to $6,000 (2001 dollars), 231 to 270 annual hours at work, and 5 to 6 annual weeks of work.“   

    The Fraser Institute is not noted for the complete accuracy of its studies, but this is a bit ridiculous.  As an evaluation of the success or failure of the Canada-Wide Early Learning and Child Care program, the Fraser Institute study is worse than useless. It is, perhaps deliberately, misleading. 

    Instead, we should conclude that:

    • Hundreds of thousands of children and families have benefited from more affordable licensed child care
    • There are now nearly 33,000 more persons working in the day care industry than there were when the program was announced in April 2021 – an increase of nearly 37%.  Many more qualified educators are needed, but this is a good start.
    • Even though the growth in the number of child care spaces has been too slow, there has still been a rise of 3 percentage points in the labour force participation rate of mothers with children 0-5 since April 2021.  Again, only a start, but definitely a start.
    • Quebec does have a universal child care program and many families access child care for less than $10 a day.  It is a very popular program with families.  There is no overall shortage of child care spaces in Quebec, but many families want to get into the fixed-fee part of the child care system, especially the better-quality not-for-profit CPEs.  Many of these families are on a waiting list.  A large number of low-income families have benefited from the universal child care program in Quebec, a much larger percentage than benefited from Canada’s targeted child care assistance.  There is still important work to do to ensure that low-income families also benefit equally from better quality in child care services.

    [1] Cleveland, G. (2017) “What is the Role of Early Childhood Education and Care in an Equality Agenda?” pp. 75-98 in Robert J. Brym ed. Income Inequality and the Future of Canadian Society ISBN-13:978-1-77244-044-7 Oakville, ON: Rock’s Mills Press. Proceedings of the inaugural S.D.Clark memorial symposium.  That study found that:” In Quebec, 61.8 percent of children 1-5 years with an employed or studying mother with a high school education or less use licensed child care. Including children with a mother who is not employed, 43.1 percent of Quebec children whose mother has a high school education or less are using licensed child care — about 30 percentage points higher than the comparable figure in the rest of Canada.“

    [2] Lefebvre, P., Merrigan, P. (2008). Childcare policy and the labor supply of mothers with young children: a natural experiment from Canada. Journal of Labor Economics 23, 519–548.

    The story coming from the CSELCC survey – I don’t think we’re going to make it…not even close!

    We know that child care affordability is improving dramatically because of the $10-a-day program (otherwise known as CWELCC or the Canada-Wide Early Learning and Child Care Program).  But what about access and availability?  It’s difficult to know.  There is some activity, and lots of announcements, but are there actually more children using licensed child care?  A really important question, because most of the social and economic benefits of the $10-a-day program come from improving access to children and families that haven’t used child care before.

    Finally we have some solid answers.  Statistics Canada just completed a massive survey of parents across the country that tells us how many children have access to centre-based child care (the overwhelming bulk of licensed child care in the CWELCC program is in centres).  We can compare this to the situation before the pandemic in 2019.  Unfortunately, the picture is not positive.

    Looking only at the provinces and territories that are part of the CWELCC program (i.e., leaving out Quebec), there are 521,800 children 0-5 using centre-based child care in 2023.  There were 483,200 children 0-5 using centre-based child care in 2019.  That’s an increase of centre-based spaces in the provinces and territories participating in CWELCC of 38,600 spaces over the course of the last 4 years, an increase of about 8%

    However, the agreements signed between the federal government and the provinces and territories promised that there will be 250,000 additional child care spaces available by March 31st, 2026.  That would be an increase of over 50% compared to the spaces that were available in 2019.  That’s just over two years away.  I don’t think we’re going to make it.  Not even close!

    The CSELCC survey indicates that 49% of parents using child care reported difficulty finding it.  Up from 36% in 2019. 

    In 2023, 26% of parents with children 0-5 who are not using child care reported that their child is on a waitlist for child care, up from 19% in 2019.  Almost half (47%) of infants younger than one year who are not using child care are on a waitlist!!!  That’s up from 38% in 2022.

    Yes, the affordability problem has improved.  But availability or access is either worse or not much better depending on your point of view.  And accessibility is improving at a snail’s pace compared to the promised additional 250,000 spaces.  Hurray for Statistics Canada giving us a clear picture of this problem.  Now federal and provincial/territorial governments have to seriously address the problems of how to grow our wonderful child care system in the not-for-profit and public sectors that are the priority.

    HOW MUCH WILL IT COST TO RAISE THE WAGES OF EARLY CHILDHOOD EDUCATORS?

    It is now widely acknowledged that the pay of early childhood educators is too low.  Comparisons of ECE hourly wages to those in other competing occupations show that educators are paid as if they had a high school education rather than a college certificate or diploma.  We can see the effects of this in the extreme shortages of fully-qualified ECEs for existing and new child care facilities.  In most Canadian provinces and territories, growth in spaces is held back as much by the lack of staff as it is by the lack of organizational and financial support for planned and funded expansion.  

    The big questions for governments are (1) how much will it cost to raise wages? (2) how should they do it? and (3) who will pay? 

    Up till now, it’s been hard to answer the “cost” question because we haven’t had good data on how many program staff work in licensed services and what their average wages are now. 

    I’ve spent a large amount of time pulling together and analyzing the best publicly available data on this, province by province (sorry, I haven’t done the Territories yet).  The details of this (staff numbers and typical wages by qualification level for each province) will appear in another blog on this site once I have finished crossing the t’s and dotting the i’s (lots of numbers and boring reading for most people).  But, using those numbers, I can now make estimates of how much raising ECE wages will cost.  If you have better numbers, I’m happy for you to send them to me so I can make revisions.

    The table below shows my estimates of how much it would cost to raise the wages of fully-qualified ECEs across the country by 25% from whatever their current level is.  For the average ECE, that would mean a raise of $5 to $7 an hour from current levels.  I’m not trying to say that’s enough, or that this is the right way to raise ECE wages.  If I look at the data on wage comparisons to other occupations, it very likely isn’t enough.  But, it may begin to move the needle on the supply of early childhood educators.  It may encourage more new ECE graduates and existing ECEs to stay in the sector. 

    Have a look at the last column province by province. Each cell shows the overall cost of raising qualified ECE hourly wages by 25% compared to what they are now (including the effects of wage grids, wage grants and wage supplements).

    This is simply a simulation to give us all an idea of how much it will cost to have a significant rise in ECE wages.  It is not a carefully thought out design for wage increases. What is needed will vary from one province to another; some provinces have done a lot already, others have done little.  In provinces with generally high wage levels for all types of workers, a 25% rise in ECE wages may not do very much. In provinces that have already done a lot to raise wage levels and establish wage grids, a 25% wage rise might be very significant.

    To see all of the columns, view the table below in a new window

    ESTIMATED STAFF NUMBERS (0-12), CURRENT WAGE BILL, AND COSTS OF WAGE INCREASES FOR FULLY-QUALIFIED ECEs

    ProvinceNumber fully-qualified incl directors/ supervisorsNumber of less qualifiedTotal program staffTotal FTE program staffCurrent annual wage bill ($ mil)Cost of 25% increase for fully-qualified ($ mil)
    BC16,8006,80023,60020,600$1,005.4+$208.0
    AB13,00010,75023,75021,000$965.8+$155.9
    SK1,6501,3002,9502,600$90.7+$15.5
    MB3,4003,0006,4005,700$215.3+$34.9
    ON35,00020,00055,00051,000$2,183.0+$391.7
    QC (0-4)29,00010,30039,30035,000$1,576.0+$315.9
    NB2,7002,0004,7004,300$186.0+$29.9
    NS2,6008003,4003,200$142.4+$29.9
    PE7004001,100950$42.3+$7.3
    NL8254001,2251,100$48.2+$8.9
    CANADA105,67555,750161,425145,450$6,455.1+$1,198.0
    CA – QC76,67545,450122,125110,450$4,879.5+$882.1
    To see all of the columns, view the table above in a new window
    • Fully-qualified refers to ECEs with a 1-year college ECE certificate or a 2-year college ECE diploma, or more.
    • These calculations are produced by Gordon Cleveland, based on the estimated wages and staff numbers in Estimates of Staff Numbers and Wages in ELCC Centres, by Province, August 16, 2023.  Numbers for the Territories are not yet included.
    • It is assumed that wages would have to rise equally for ECEs caring for children 6-12 years of age.  However, in Quebec where fully-qualified staff caring for children 5-12 years are employed by the school system, numbers refer only to staff caring for children 0-4.

    These numbers do not include the extra cost of compulsory benefits like contributions to pay for EI and CPP/QPP and vacation pay.  That would add another 15%-18%, perhaps.  However, these estimates do include an allowance for supply staff.

    There is no magic in this 25% wage rise simulation.  But, now, with data on current numbers of staff and on current wage levels, we can do whatever simulations we think are appropriate and estimate the costs of taking action (and compare them to the costs of inaction).  That, I think, is a big step forward.

    With these simulations in hand, we can turn to the next two questions.  Question #2 was how exactly we should raise wages.  That debate is too big for this blogpost, but let me make some observations. I believe that the big staff supply problem is centred in the inadequate supply of fully-qualified early childhood educators, whether that is a one-year ECE college certificate or a two-year ECE college diploma.  Recruiting untrained staff or recruiting staff that need to take only an orientation course or two is not where the problem lies.  That means we need to concentrate our scarce funds on raising the wages of qualified educators.

    And once we have decided to concentrate our wage-raising efforts on fully-qualified staff, we need to avoid the Ontario mistake.  Ontario decided to raise wages by concentrating their efforts on low-paid educators.  In 2022, they boosted all early childhood educators earning less than $18 an hour up to $18, but they did nothing for anyone else.  In 2023 and beyond, they are raising the pay of other educators by $1 per hour each year, but only if the educators currently earn less than $25 an hour; $25 is the top wage for this program.  This focus only on low-paid educators ensures that ECE will continue to be a low-paid profession; even $25 an hour will keep educators well below competing occupations.

    And, the Ontario wage supplement design ensures that most of the wage assistance will go to centres that previously were underpaying their workers, disproportionately those in the for-profit sector.  The Doug Ford government is developing a bit of a reputation for favouring for-profit friends, whether it be the Greenbelt or child care, but this kind of wage supplement design will not do a good job of retaining the best-qualified and most experienced staff and making ECE an attractive profession.

    Finally, there is the question of who will pay.  I would be overjoyed if the federal government decided to come up with a billion dollars of extra annual funding, but I don’t think that will happen very soon, and wage rises do need to happen very soon.  Some provinces may be willing to up their spending to solve wage problems, and that is welcome.  But the most obvious immediate place to get funding for educator wages is to change priorities for the expenditure of federal dollars under the Canada-Wide Early Learning and Child Care Agreements.  The very large majority of the federal funds under current Action Plans goes to lowering parent fees.  Right now, many provinces are renegotiating Action Plans to cover the next three years.  Why not allocate a larger portion of money in the next three years to cover wage increases for fully-qualified early childhood educators?  And there should be provincial contributions to cover the wage increases for staff caring for 6-12 year-olds. 

    The numbers in the table above tell us about how much reallocation of dollars is needed in each province.  Let’s get it done, or expansion will not happen and access to affordable child care will continue to be a dream for most families.

    British Columbia’s New Spaces Funding Program

    My opinion of British Columbia’s New Spaces Fund is shaped by the context.   It’s a valuable, if imperfect, source of capital funding for the expansion of not-for-profit and public child care.

    The context is that we’re not doing a good job in expanding the availability of child care services in Canada.  That’s disappointing, of course, but also a danger to the ultimate success of the Canada-Wide Early Learning and Child Care program. 

    Without rapidly expanded capacity, most parents will not be able to benefit from $10 a day child care.  Women will not be able to enter the labour force.  The economic growth benefits of child care will not happen.  Parents will be angry and frustrated at governments that have promised them services they can’t deliver.  A new government may come in and turn everything over to the for-profit sector, loosening staffing regulations, and allowing operators to surcharge parents for “extras” to make providing child care more profitable. 

    The decision of federal and provincial/territorial governments to rely on the not-for-profit and public sectors for child care capacity was good for the long-run, but it’s having lots of problems in the short run.  Not-for-profit and public services are typically of higher quality with better effects on children’s lives.  Not-for-profit and public services become trustworthy community assets, here for the long term, in a way that for-profits do not, always anxious to sell assets or property to the highest bidder. 

    But, not-for-profits need more help to expand than the for-profits do. For-profits have better access to capital funding from the private sector than not-for-profits do; many banks and financial institutions are unwilling to make construction loans and mortgages to not-for-profit organizations.  Most not-for-profit organizations find it too risky to make expansion promises until future on-going operational funding arrangements for services are settled;  some for-profit organizations are willing to take a gamble that future operational funding will be generous, or that costs can be slashed to ensure a profit.   On top of all this is the shortage of qualified early childhood educators.  Not-for-profits are typically unwilling to expand until they can hire enough fully-qualified educators to run good-quality programs.  For-profits are often willing to plan to operate without a full complement of trained staff, hoping they can get exemptions from government regulations and be able to operate with unqualified staff.

    British Columbia’s New Spaces Fund is not perfect.  Yet, in the context I’ve just described, it provides some important support for child care expansion to not-for-profit and public organizations in B.C.  And that’s a lot more than I can say for most of Canada’s provinces, outside Quebec.  The New Spaces program provides capital grants only to not-for-profit and public organizations who are willing and anxious to expand the supply of child care services.  Previously, it was available to the for-profit sector who did not need it; that was a big mistake that has since been corrected. The budget last year was $292 million, about $84 million from provincial funds and the rest from federal funding under the Canada-Wide ELCC program. 

    Some of the projects are for minor renovations, some for equipment only, but some are for much bigger projects.  The new Ministry of Education and Child Care prefers to have projects that are funded for $40,000 or less per space, but this restriction can be waived.  Since, construction costs have been rising rapidly, $40,000 per space is now below full cost for many projects.  And applicants are expected to come up with 10% of the entire project cost from other sources. 

    It’s also a one-time capital grant, so you have to know a lot of detailed cost and design elements up-front when you apply.  At the time you apply, you are guessing at much of this.  This is a disadvantage.  A capital program, instead of a one-time capital grant, can be more flexible.

    Eligible costs for the New Spaces program include project management, design/engineering costs and site evaluations, architect and accountant fees, and business planning development (business case model and analysis).  Also eligible are infrastructure costs – water, sewer, roads, sidewalks.  And equipment. And GST/PST and a 10% contingency.)  Not included are costs of purchasing real estate, or buildings or commercial space (however, modular buildings to be erected on site are an eligible expenditure).

    Many of the applicants for New Spaces funding are local governments, school boards, health district authorities, public post-secondary institutions, and First Nations. This is a great use of the program.  Many of these bodies may have access to land for building, and many will have considerable experience in managing large development projects.

    The New Spaces Fund is application-driven.  In other words, organizations have to take the initiative and plan child care expansion and apply for capital funding.  The New Spaces Fund is therefore a capital grants program, it is not part of a program of capital expansion.  In many ways, this is a weakness and this feature has been criticized.  Advocates say that B.C. needs planned child care expansion, focused first on areas of higher need, with support for many aspects of expansion – not just capital grants.  Most child care centres do not have the resources to take on major capital development, raising millions of dollars of capital funding and managing multi-year expansion projects.  Capital expansion requires more than just money. It needs organizations that will take responsibility for development; it needs architects with knowledge of child care,  it needs design standards.  It also needs a much longer guarantee that facilities will stay in place than the current 10-year requirement of the New Spaces Fund.   Manitoba’s Ready-to-Move program is a model to look at for how resources of different actors can be mobilized for child care expansion.

    While that’s true, let’s give B.C. some kudos for having a program of capital grants at all.  Believe it or not, most provinces apparently believe that (capital) money grows on trees (for not-for-profit and public organizations).   Alberta offers $5,000- $6,000 per space.  Ontario offers about $7,000 per space.  In the context where the cost of new-build construction is often more like $50,000-$60,000 per space, that’s not a serious amount of capital assistance.

    B.C. has much to do.  They are planning development of a wage grid to attract early childhood educators, but there is no deadline for when this will happen. 

    B.C. has not yet developed a funding formula for the provision of operational funding when parent fees are an average of $10 a day for everyone.  This means that future revenue streams are uncertain, so the planning of child care expansion for not-for-profit and public services is more risky than it needs to be.

    B.C. has not yet developed mechanisms for planning and guiding the child care expansion that will have to happen.  Based on current use patterns in Quebec where parent fees are now $8.75 a day, we can expect that B.C. will need to have  spaces for 174,180 children 0-5.  That would mean a need for about 77,750 additional child care spaces compared to 2021.  So, B.C. needs to get its game on.  As many other provinces do.

    Modular Child Care Expansion in Manitoba: An Idea Worth Looking At

    This is a good-news story about the expansion of child care capacity. 

    Right now, there are not many good-news stories; child care expansion is happening much slower than it should be.  And all the indications are that even the 250,000 additional child care spaces that provinces and territories have planned (but not funded!) by 2026 will not be enough.  TD Economics, in its recent publication, calculates that at least 243,000 MORE spaces will be needed to satisfy demand for child care when it is available at $10 a day. 

    So, we had better get working on designing, funding and building extra child care capacity.

    Manitoba has a good plan for how to expand child care services in rural, remote and northern communities.  It’s called the Ready-to-Move project.  Its origins were with the 2017 Canada-Manitoba ELCC agreement when the Department of Families in Manitoba developed three rural child care facilities through a modular construction project.  The initiative was developed by the Department in co-operation with Manitoba’s Social Innovation Office which seeks innovative solutions for complex social and environmental issues.  By the way, Early Learning and Child Care is , since 2022, part of the Department of Education and Early Childhood Learning.

    The Winnipeg Metropolitan Region has an incorporated entity called JQ Built that is providing project management support to municipalities that wanted to be involved.  The result is known by the name “Daycare in a Box”.  It creates modular buildings with a pre-fabricated construction process.  The child care centres are made in a manufacturing facility in Winnipeg and transported to a permanent site in the relevant municipality for assembly.

    To date, there are 23 communities with projects approved and another 14 applications being considered for future rounds of development.  The first batch of facilities began construction in February 2023, and the first facility is planned for opening on July 21, 2023.  That’s quick!

    Municipalities and First Nations communities that want to participate have to provide serviced land in their community rent-free for 15 years.  And they have to agree to provide maintenance, snow clearing and repair services for this period.

    The province is providing 100% of the capital funding for the centres.  This is an investment of between $4 million and $6 million each depending upon the size of facility. A 74-space facility is about $4 million while a 104-space facility is closer to $6 million. The centres will become municipal assets.

    So, let’s make a tally:

    100% capital funding from the province – check

    Municipalities and First Nations communities have serious skin in the game – check

    There is an experienced public sector project manager to provide development services that child care centre leadership cannot readily do – check

    The centres become municipal assets in perpetuity – check

    The whole process is designed to provide new spaces quickly in areas that are currently underserved – check.

    I like it.

    Of course, it’s only a beginning.  It is not the model for every situation.  And attracting sufficient fully-qualified educators is still an unsolved problem.  But, it’s a good initiative that deserves attention from other jurisdictions.  Good on you, Manitoba.