Don't re-open ECE centres under level 3

19 April 2020

The ECC has written to the Prime Minister and other educational leaders saying we need more time to get this right.

Our primary concern is the threat of carrier risk, along with the myriad of issues we're still working through with the Ministry of Education. We believe it's only safe to re-open under level 2.

The text of this open letter follows:

Rt Hon Jacinda Ardern

Prime Minister
c/- Parliament Buildings

Dear Prime Minister,

We write to you directly on a matter of serious concern for the Early Childhood Education (ECE) sector – the proposition that ECE centres can re-open, under certain circumstances, during COVID-19 Alert Level 3, possibly in the very near future.

We applaud the work being done by the Ministry of Education to prepare our sector, but feel opening centres is the wrong decision in Level 3. We believe ECE services should not re-open under any circumstances until COVID-19 Alert Level 2.

The primary reason for this extra caution on our members’ part is the carrier risk of reigniting a COVID-19 outbreak.

The Ministry of Education are quoting Director General of Health Dr Ashley Bloomfield in their information:

"Our experience in New Zealand and overseas with COVID-19 over the last three months shows that it does not infect or affect children and teens in the same way it does adults."

"So children and teens have low infection rates, they don't become that unwell if they do get infected, and they don’t tend to pass the virus on to adults."

We believe this is a misquote. Although statistics for children are relatively lower than all other age groups, there is nothing about them acting as carriers, or published research to support this proposal. The Ministry of Education are using Dr Bloomfield's quote to set policy and rules for our sector, based on this lack of data.

Our parents are not stupid people, and will point to several reported cases of children carrying and dying from COVID-19, and ask us why they’re not being taken into account. We include examples in the appendix of this letter.

In addition to this carrier risk, there is a multitude of issues and unanswered question raised by our members and submitted to the Ministry of Education. While we understand Ministry officials are working hard to answer these questions, we feel the move to re-opening is too fast and that many of these issues will remain unresolved. Our sector needs clarity in order to plan, to inform staff and parents, to inform external stakeholders (like bankers). To give you an understanding of the breadth of these unresolved issues, I attach a list in the appendix to this letter. This list has already been shared with the Ministry of Education.

The guidelines provided by the Ministry of Education to the ECE sector for re-opening at Level 3 are commendable. They are, however, impossible to implement and will not prevent the spread of COVID-19 from asymptomatic children. It is impossible to prevent teething infants from putting toys in their mouths just as much as it is impossible to prevent an 18 month old from breaching their bubble in the playground.

COVID Alert Level 2 is the only condition under which it is safe enough for an ECE service to re-open, given:

  • - more certainty for parents and ECE services
  • - more data on carrier effects
  • - new cases being contained at near zero each day
  • - less-stressed staff who simply cannot be asked to put their lives on the line, working with children sneezing randomly, with runny noses, etc
  • - less stressed parents who are currently worried about carrier effects from other parent workplaces
  • - more chance that our centres will survive through this, instead of making them operate at further losses, potentially driving them into bankruptcy.

We do not believe our 1,300 childcare centre members are going to be satisfied and sufficiently confident enough to accept the current assurances from the Ministry of Education to re-open under COVID Alert Level 3.

We implore you and your Cabinet colleagues to re-consider this specific element of the COVID Alert Level 3 picture and keep the majority of ECE services closed.

We appreciate the need to support ‘Safe’ workers with young children, but the Ministry of Education’s approach contracting a number of selected home-based ECE providers has not been successful in our view. The demand for the service has been questionable in terms of viability for the service, and ignores the carrier risks outlined above.

We recommend that Safe workers be supported to stay at home to care for their children without any risk or threat to their employment, until the country moves to COVID Alert Level 2.

If you have any queries please do not hesitate to contact me.

Yours sincerely,

Peter Reynolds
Chief Executive Officer

CC: Minister of Education, Hon Chris Hipkins

Secretary for Education, Iona Holsted

ECAC Members

ECC Members

Appendix one – examples of children contracting COVID-19

Three babies have virus amid fears of rise in cases when school returns

5-year old dies from COVID 19

6-week old baby dies from COVID19

New-born dies from COVID19

1-day old dies from COVID19

12-year old dies from COVID19

13-year old dies from COVID19

Appendix two - case study examples

Scenario one

Our Centre has a Licence for 40 children. Only two children are full time; the remainder are sessional. Therefore no bubble of 10 children: Children would be coming and going through the day, which is not permittable within the guidelines.

Result / solution: Don’t open

Scenario two

Our Centres are open-plan – while we can separate for mat time, I would need to physically measure the rooms to see if they meet the new guidelines. We remain concerned, however, that the 3sqm will make absolutely no difference when dealing with a preschool child when it comes to preventing the spread of covid-19. Social distancing is not relevant in our context because it is about the child, not the environment. If a child plays with, snots on, places saliva on a toy; dribbles or sneezes on the floor; has covid-19 on their hands as they crawl across the floor – then they are contaminating your recently cleaned environment with covid-19 & the arbitrary idea of 3sq metres is irrelevant. The issue for us is not the environment, it’s the child who has absolutely NO IDEA when it comes to hygiene and the impossible expectation on centre management and their staff to manage that child’s behaviour in terms of hygiene and mitigating spread of covid-19.

As has already been raised, our outdoor area has no segregation that would separate bubbles.

Result / solution: Don’t open

Scenario three

I called all 50 of our parents on Friday to ask them if they will bring their children back if we are allowed to re-open. Two said yes. We cannot afford to open or staff pour centre at that level.

Result / solution: Don’t open

ECC Member Survey Results

We asked our members for their thoughts in the last 24 hours, and 80% favour a delay in opening their doors until several key issues are addressed, or COVID Alert Level 2 is achieved at least. For over 50%, maintaining small cluster safely is their main concern.

Feedback includes:

“We don't feel safe and the practicalities of opening for ECC is more complicated and dangerous than for primary and upwards.”

“There is risk as teachers have their own families how would they deal with them and work when there is no one to look after their own children. I as a teacher would feel guilty not going to work but looking after my own kids at home when iam needed at my work place.”

“I am comfortable about returning to work but we need to recognise that a teachers bubble (and therefore their families bubble) goes from single digits to in the 100's or 1000's depending on which children return. We have no PPE or social distancing and we are one of the worst paid industry there is. I would also like some more evidence that children are not the vectors for the spread of Covid19 because for use our main clients (and those in our bubbles) are most likely to be those in the highest risk, front line positions (e.g. sons and daughters of doctors, nurses, essential workers).”

"Give all ECE and Schools in NZ an extension of two weeks closure. My concern is we all open and then there will be an increase in COVID-19 clusters at ECE, Schools and the local communities (second wave) and we have to all go back to full closure."

Unanswered Questions Submitted to the Ministry of Education


  • How will this work? Will it continue to be based on enrolment data rather than attendance to cater for those who choose not to return at present?
  • How will the 25% wash-up work?
  • What about (particularly smaller) centres that cannot staff or do not feel confident to open? Will they be funded and how?
  • The last thing we want is for MoE to pay at March level - this is likely to be the lowest, influenced by parents who withdrew their children early. Will the funding approach take account of the likely partial return of children?
  • Will the Childcare Subsidy from Work and Income start up again?
  • If a centre chooses not to open just yet, will they still receive funding?
  • The Ministry have been supportive to date by confirming there would be no funding clawbacks while in lockdown under Alert Level 4. Will that be extended to Alert Level 3?


  • MoE have said centres should support staff who do not feel comfortable to work or who may be at risk. How are they to be paid? Do centres now use sick leave, annual leave, or are wages to be covered in some other way?
  • The Wages Subsidy is not available to everyone – will this be extended? Will the 30% rule be relaxed a little?
  • What about centres that have a significant amount of teachers who fall under the at risk category and cannot work?
  • How do we treat staff who choose to stay at home to look after children because they choose not to utilise childcare? Do we continue to pay them, expect them to use leave entitlements, or is there likely to be an extension to the wages subsidy?

Licensing Criteria and Regulations

  • Are these new rules for Level 3 going to lead to a change in Regulations and/or Licensing Criteria?
  • The update talks about one group per room. It still means that our new 'COVID licences' are now in multiples of 10, depending on number of rooms and capped by your new max number at 3m2 per child. That's around three U2 teachers or two/ O2 teachers for each mini bubble of 10. For many centres that means they will be limited to 10 children, making the whole thing unviable.
    Why can’t more than one group be in a larger room if steps are taken to ensure they remain separate? For smaller centres, in particular, requiring a separate room for each group is unworkable.
  • What about access to playgrounds – is this to be staggered?
  • We note that the unworkable ideas of staggered drop-off and pick-up; and safe distancing of children within a centre are missing – have these (sensibly) been dropped?
  • Are children to continue to share bathrooms, across groups of 10?
  • How do we identify families of “safe” businesses from any that are not, or are we taking all?
  • What does “voluntary” mean and how will that work?
  • Children are to attend one ECE service (no dual enrolments). What about siblings from the same bubble going to school?
  • What about centres with a high proportion of essential worker parents all wanting to make use of the centre, eg: on hospital grounds?
  • How does the group of 10 children work with mixed age-groups?

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