Record-Keeping Processes for Child Care Program Inspectors

The Alberta Auditor General’s October report revealed that Alberta Children’s Services’ record-keeping was inconsistent and made it impossible to determine if child care programs were meeting provincial standards (Kleiss, 2010).  The report identifies that the problem occurs with the documentation (or lack thereof) of “low-risk” breaches of existing standards, which are often handled with a “verbal warning”, or recorded inconsistently by inspectors.  The Auditor General quite correctly notes that this poses a safety risk to the children in these programs (2010, 33-34).

My first question is why there is no consistency already in how inspectors are reporting breaches.  One would hope that such an important role in our society, the people responsible for holding accountable the services that provide our child care, would function like a well-oiled machine.  Is it a lack of training, i.e. human error?  Is it a poorly designed reporting system, i.e. system error?  How does this happen?

There are clearly existing procedural regulations in place for inspectors.  The Auditor’s report acknowledges the following about the inspection activity:

Authorities’ licensing officers inspect these programs at least twice a year and inspect in response to complaints and program reported critical incidences such as child injury. If a program is not complying with regulatory requirements, through delegation from the Statutory Director for Child Care, a licensing officer may:

  • issue a verbal warning to correct non-compliance
  • issue an order to remedy non-compliance
  • impose conditions on a license
  • vary a provision of a license
  • suspend a license and issue a probationary license
  • cancel a license

Enforcement action will vary depending on the severity of the non-compliance. Low risk non-compliance may warrant more serious enforcement action if frequently repeated or identified as part of a pattern of ignoring requirements. (35)

It goes on to describe how the lack of records tracking verbal warnings, as well as inconsistency in acquiring and providing evidence of non-compliance when issuing an order to remedy problematized the task of following-up in cases when further action would be required.  It is not clear if this type of documentation has always been inconsistent, but the Auditor’s report made three recommendations:

1. Review and improve documentation and training to ensure all program requirements are being met.

2. Improve the consistency of monitoring by correcting systems that ensure compliance with processes.

3. Improve follow-up processes by ensuring that all verbal warnings are adequately documented and resolved.

While the report seems to me the perfect example of why good records management is critical, it made me wonder how the office of the Auditor General conducted its audit, and how it came to draw the conclusions it did.  According to the report:

Our audit procedures included reviewing relevant legislation, standards, policies and procedures, interviewing senior staff at the Department and five Authorities, shadowing licensing officers as they inspected programs, reviewing inspection reports, and examining the Department’s Child Care Information System (CCIS). (33)

The mention of CCIS, an ERMS, made me wonder precisely what sort of information was recorded in it.  After all, CCIS must be counted among the “systems” and “processes” identified in the recommendations.  The report (which, if you have not realized by now, is remarkably thorough) describes CCIS as follows, in the context of recommendation 1:

Authorities record enforcement actions in CCIS, link it to the corresponding regulation, and do some analysis of that data. However, more detailed trend analysis of this data may reveal the location, timing, and types of non-compliance, as well as help in planning future monitoring or training actions. For example, in our sample, we identified a pattern across Alberta of non-compliance with a requirement for maintaining portable emergency records. This could indicate a need for training or stricter enforcement action in this area. (36)

The report also identifies, in the context of recommendation 3, that while “Orders to Remedy” were consistently entered in CCIS, “verbal warnings” were not, and there was no way to tell if any remedial action was taken in cases where verbal warnings were given.

Other “records” in this story worth noting:

  • The legislation, provincial standards and statuatory requirements that govern child care in Alberta
  • The Auditor General’s Report itself (and what it says about the governmental review process in our province)

(apologies for the unoriginal title)

________________________

References

Auditor General Alberta. (2010, October). Report of the Auditor General of Alberta—October 2010.  Retrieved on November 15, 2010 from http://www.oag.ab.ca/files/oag/OAGOct2010report.pdf

Kleiss, K.  (2010, October 28).  Better Paperwork Expected of Daycare Inspectors.  EdmontonJournal.com. Retrieved on November 15, 2010 from http://www.edmontonjournal.com/life/Better+paperwork+expected+daycare+inspectors/3737004/story.html

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