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OSHC COMPLIANCE & ASSESSMENTS

Keep your OSHC service compliant and assessment-ready

HCPA helps you turn OSHC policies, Quality Improvement Plans and National Quality Standard requirements into practical systems that work across before-school, after-school and vacation care.

OSHC compliance needs to work in the realities of school-age care. Children move between school, care and home, services often operate from shared facilities and supervision needs can change quickly across short sessions.

Policies, the educational program, staffing and child-safety systems therefore need to reflect what actually happens at the service, not just what is written in the compliance folder.

When urgent OSHC compliance support may help

Some findings require service improvement, while others can lead to formal regulatory action. The first step is understanding exactly what has been identified and how serious it is.

Working Towards NQS rating

A Working Towards NQS rating means one or more National Quality Standard elements have not been met.

Start with the assessment report and identify the practice or evidence behind each finding. The aim is to fix what happens in the service, not simply rewrite the QIP.

Compliance notices or directions

A regulatory authority may require specific non-compliance to be corrected within a set timeframe.

Review the requirement, identify the underlying problem and gather evidence showing how the service has addressed it.

OSHC show cause notice

A show cause notice means the regulator is considering more serious action against an approval.

The notice should be reviewed immediately, with each ground addressed using clear evidence and a documented response.

Risk of service approval suspension

Service approval can be at risk where serious or persistent non-compliance remains unresolved.

Where suspension is being considered, ACECQA’s current framework generally provides 30 calendar days for a written response to a show cause notice. 

Key OSHC compliance requirements

OSHC compliance needs to reflect how children actually move through the service, from school dismissal or morning arrival through to collection and vacation care.

Keep supervision strong across school transitions

Supervision needs to work across classrooms, playgrounds, toilets, collection areas and other shared spaces.

Clear processes for school handover, authorised collection, headcounts and child location help reduce gaps during busy transition periods.

Maintain appropriate staffing and child-safety systems

Rosters need to reflect enrolment numbers, supervision needs and the qualification requirements that apply in the relevant jurisdiction.

National child-safety reforms also introduced mandatory child safety and child protection training requirements from 27 February 2026. See ACECQA’s child safety training requirements.

Deliver a genuine school-age educational program

OSHC should not simply recreate the school day.

The program should reflect My Time, Our Place V2.0, with opportunities for play, leisure, choice, relationships and participation that respond to the interests and experiences of school-age children. View My Time, Our Place V2.0.

Keep OSHC policies matched to the service

Policies should reflect the actual premises, school relationship, staff structure and daily routines.

A generic procedure is less useful if educators cannot explain how it applies to arrivals, transitions, collection, vacation care or the shared school environment.

Keep the OSHC Quality Improvement Plan active

The QIP should show what the service has identified through self-assessment, what it is improving and what action is underway.

ACECQA requires a new service to prepare its QIP within three months of approval and existing services to update it at least annually. See ACECQA’s QIP guidance.

Maintain useful operational records

Attendance, collection, incidents, medication, staffing, risk assessments and program records should help reconstruct what happened when an issue arises.

For OSHC, evidence of communication with families and the school can also be important where responsibilities cross between school and care.

The practical test is whether the written system and everyday OSHC practice tell the same story.

OSHC assessment and rating readiness

OSHC services are assessed against the National Quality Standard, but the evidence needs to reflect a school-age care environment.

Authorised officers can use observations, discussions and documentation when assessing the service, so preparation should extend beyond updating policies.

Relevant evidence may include:

  • the current QIP and OSHC policies

  • attendance, collection and child records

  • staffing, qualifications and child-safety training

  • supervision and school-transition practices

  • the educational program and MTOP evidence

  • incidents, risks and family communication

  • governance and previous compliance issues

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Staff should also be able to explain how these systems operate during a real OSHC session.

For OSHC, assessment should not be approached as though the service is simply long day care for older children. Programming, supervision, transitions and relationships should demonstrate how the service responds specifically to children and young people.

HCPA can review the service, identify evidence gaps and help staff prepare to demonstrate how OSHC policies and procedures work in practice.

Speak with an HCPA OSHC compliance consultant

What to do after receiving a Working Towards rating or compliance notice

The right response depends on the findings, but there are four immediate priorities.

Step 1

Understand why the element was not met

Identify the exact element, regulation, practice or evidence behind the finding rather than assuming the policy itself is the problem.

Step 2

Compare policy with everyday OSHC practice

Review what educators actually do during supervision, transitions, programming and collection to identify where the documented process has broken down.

Step 3

Address immediate child-safety risks

Where the issue involves supervision, staffing, collection or another immediate risk, correct that problem first while preserving the relevant evidence.

Step 4

Build the improvement into the QIP

Assign clear actions, responsibility, timeframes and evidence of completion so the response becomes part of ongoing service improvement.

Why choose HCPA for OSHC compliance support?

OSHC operates differently from other centre-based care. Short operating windows, school transitions, shared facilities and the needs of older children all affect how compliance works in practice.

HCPA can review policies, the QIP, staffing and daily service systems together to identify where documented procedures and actual practice have become disconnected.

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HCPA’s broader early learning compliance work includes policy development, assessment preparation, root-cause analysis and remediation. For OSHC, that experience can be applied to school-age programming, supervision, child safety and assessment readiness.

Frequently asked questions about OSHC compliance

Use a consistent monitoring framework rather than allowing each educator to manage compliance differently.

This should include scheduled coordinator visits, current residence or venue assessments, educator records, follow-up actions and evidence that identified issues have been resolved.

ACECQA identifies educator monitoring and coordinator visit records as important evidence of effective family day care management.

The response depends on which one has been received.

For a Working Towards rating, identify which elements were not met and address the practices or evidence behind them.

A show cause notice is more serious. Review the grounds and deadline immediately, preserve relevant records and prepare a response addressing each concern. Legal advice may also be appropriate where suspension or cancellation is being considered.

It means the service has not met one or more elements of the National Quality Standard.

The useful question is why the element was not met. A weaker rating may reflect a gap in supervision, programming, records, governance or another part of everyday service delivery.

Yes.

An approved provider can generally apply for a First Tier review within 14 calendar days of receiving the final assessment and rating report. See ACECQA’s First Tier review process. 

A Second Tier review may subsequently be available through ACECQA.

The same National Quality Standard applies, but the service context is different.

OSHC typically involves school-age children, shorter sessions, transitions between school and care and greater use of shared spaces. The educational program should also reflect My Time, Our Place and the interests, choice and agency of older children.

Assessment is not limited to documents.

An authorised officer may observe supervision and educator practice, speak with staff and review attendance, child records, programming, incidents, risk management and governance evidence. ACECQA confirms that assessment and rating considers service practice against all seven quality areas of the NQS.

Show how the program responds to the children who actually attend rather than presenting only a timetable of activities.

Evidence may include children’s interests and choices, educator planning and reflection and examples of how My Time, Our Place V2.0 shapes play, leisure and participation.

Not automatically.

However, persistent failure to improve a Working Towards rating can form part of the grounds for stronger regulatory action in certain circumstances. ACECQA’s service approval guidance expressly includes an unimproved Working Towards rating among the matters relevant to suspension where the statutory conditions are met.

Deal with any immediate child-safety concern and required notification first.

Then review why the incident occurred. The underlying problem may involve supervision, staff responsibilities, transitions, communication or record keeping, and the corrective action should address that system rather than only the individual event.

Related OSHC resources

Start an OSHC service

Planning a before-school, after-school or vacation care service?

Assess the school arrangement, family demand, staffing and facilities, then prepare the provider, service and CCS approvals required to open.

Get started

Grow your OSHC service

Looking to increase enrolments or expand the service?

Keep your QIP, supervision and school-age care systems current, or respond to a Working Towards rating, compliance notice or other finding.

Start Growing
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