How do I prepare for a CCS Spot Check?

Spotlight on GECCKO resource and the Strengthening Regulation of Early Childhood Education and Care Safety through the Child Care Subsidy (CCS) – Provider Guidelines document

How do I prepare for a CCS Spot Check?

Spotlight on GECCKO resource and the Strengthening Regulation of Early Childhood Education and Care Safety through the Child Care Subsidy (CCS) – Provider Guidelines document

By BEST Childcare Consulting

In August 2025, the Australian Government released the Strengthening Regulation of Early Childhood Education and Care Safety through the Child Care Subsidy (CCS) – Provider Guidelines, marking a major shift in how safety, quality, and funding integrity are regulated across the early childhood education and care (ECEC) sector.

Under this strengthened framework, CCS approval is no longer just about meeting administrative requirements — it’s about demonstrating a whole-of-service commitment to safety, quality assurance, and governance accountability. The Guidelines empower the Department of Education to use data analytics, risk profiling, and unannounced CCS spot checks to verify that services receiving federal funding are operating safely, ethically, and transparently.

For approved providers and nominated supervisors, this framework acts as both a compliance roadmap and a reflection tool. It encourages services to regularly self-assess their systems — reviewing incident management, staff suitability, documentation accuracy, and financial integrity before any issues arise.

A practical way to prepare is through the Commonwealth’s free Geccko online training platform (Get Early Childhood Compliance Knowledge Online). Geccko helps educators, leaders, and administrators understand their obligations under the Family Assistance Law (FAL) — covering topics such as enrolment integrity, session reporting, gap-fee requirements, and governance responsibilities. Completion certificates can also serve as evidence of staff competence and proactive compliance during a CCS spot check.

Embedding both the CCS Provider Guidelines and Geccko training outcomes into your Quality Improvement Plan (QIP) demonstrates Exceeding-level practice across multiple Quality Areas — particularly QA2 (Children’s Health and Safety), QA4 (Staffing), and QA7 (Governance and Leadership). It shows your service is not only compliant but continually reflecting, improving, and modelling a culture of safety and integrity at every level.

Firstly, what’s the difference between CCS Spot check, ECRU Spot check and Assessment & Ratings?

CCS Spot Checks (Commonwealth level) safeguard federal funding and integrity

  • Run by the Australian Department of Education under the Child Care Subsidy (CCS) framework.
  • Focus on funding integrity, governance, and child safety—ensuring CCS payments are used correctly and services meet federal safety expectations.
  • Primarily administrative and compliance-focused, but may refer safety concerns to the state regulator (ECRU).

ECRU Spot Checks (State level – WA) safeguard children’s health and safety in daily operations.

  • Conducted by the Education and Care Regulatory Unit (ECRU) under the Education and Care Services National Law and Regulations.
  • Focus on health, safety, staffing, environments, and everyday practice within your service.
  • Findings can directly impact your compliance history and may influence your next Assessment and Rating outcome.

Assessment and Rating (A&R) evaluates overall quality and leadership for continuous improvement.

  • A scheduled and comprehensive review of your service’s performance against all seven Quality Areas of the National Quality Standard (NQS).
  • Measures the quality of educational practice and leadership systems, rather than compliance alone.
  • Results in an official rating (e.g., Meeting or Exceeding NQS) that reflects long-term quality improvement.

Each process strengthens a different layer of accountability — and together, they create a complete picture of how services protect, educate, and lead with excellence.

Use Geccko to learn about CCS 

Here’s how the online training platform Geccko (Get Early Childhood Compliance Knowledge Online) helps services prepare for a CCS spot check — and how you can use it to strengthen your readiness:

What Geccko covers

  • Geccko is developed by the Department of Education (Commonwealth) to support compliance with the Family Assistance Law (FAL), which governs the Child Care Subsidy (CCS). Department of Education+2The Sector+2
  • The courses cover key topics such as:
  • It is self-paced, suitable for all staff across approved care types, and includes certificates for completion. The Bursar AU+1

How Geccko helps with CCS spot checks

  • Understanding the rules: Because CCS spot checks focus heavily on compliance (enrolments, attendance, payment integrity, correct administration), Geccko’s modules ensure you and your team understand exactly what the regulator will look for.
  • Building staff capacity: Having more staff trained in FAL obligations means you’re better prepared across roles — not just the nominated supervisor or admin. This broadens your readiness.
  • Documenting training: Certificates from Geccko can act as evidence that the service is proactively educating staff about key compliance obligations — something valuable when being reviewed.
  • Supporting self-assessment and improvement: You can use Geccko’s tips and modules to identify areas of risk (e.g., enrolment practices, gap fees) ahead of a visit, and then embed corrective actions in your QIP or compliance register.
  • Linking to governance and leadership: Incorporating evidence of staff training via Geccko supports quality area 7 (Governance & Leadership) by showing a culture of continuous improvement and compliance awareness.

Understanding the “ Strengthening Regulation of Early Childhood Education and Care Safety through the Child Care Subsidy – Provider Guidelines August 2025” that authorised officer uses for a CCS Spot check 

Purpose

  • Provides a framework for the Child Care Subsidy (CCS) to support safety and quality in early childhood education and care (ECEC) by leveraging funding and regulatory powers. Department of Education+1
  • Explains how the Department uses new powers (via the Early Childhood Education and Care (Strengthening Regulation of Early Education) Act 2025) to tie CCS eligibility and administration to safety and quality standards. Ministers’ Media Centre+1

Key Themes & Provisions

  1. Legislative Powers & Scope
    • The Act and associated laws enable the Department to: suspend or cancel CCS provider approvals; place conditions on approval; conduct unannounced site visits and spot checks; refuse new or expanded services if quality/safety are lacking. Department of Education+2Federal Register of Legislation+2
    • The framework emphasises that safety and quality are paramount for CCS-approval and continuation. Department of Education+1
  2. When Powers May Be Used
    • When a provider or service exhibits risk of harm, poor safety/quality history, serious incidents, non-compliance with National Quality Framework (NQF) or funding rules. Department of Education
    • The Department will work with State/Territory Regulators in a data-driven, risk-targeted manner to minimise burden but act strongly where needed. Department of Education
  3. Self-Assessment Guidance
    • Providers are encouraged to assess their own compliance: consider their safety/quality systems, track record (ratings, incidents, complaints), improvement over time. Department of Education
    • The guideline makes clear that a serious incident alone may not trigger action—but how it was managed will matter. Department of Education
  4. Financial Integrity & Compliance Pyramid
    • CCS isn’t only about safety/quality—it also includes financial integrity (correct subsidy administration, attendance records, payments). Department of Education
    • The guideline shows a “Compliance Pyramid” illustrating escalating regulatory responses from supports to sanctions. Department of Education
  5. Legal & Regulatory Context
    • Providers must comply with both: the Family Assistance Law (which governs CCS) and the Education and Care Services National Law (which covers quality/safety via NQF). Department of Education+1
    • State/Territory regulators continue their role in monitoring and enforcing quality/ safety under NQF; the Commonwealth uses its CCS powers as an additional lever. Department of Education

What providers should do now

  • Review their quality & safety systems (supervision, staffing, incidents, compliance culture).
  • Ensure their CCS administration and financial record-keeping are accurate and meet obligations.
  • Monitor their service’s history of ratings, incidents, complaints and improvements over time.
  • Be aware of conditions, suspensions, cancellations as possible outcomes if standards not met.
  • Use the guideline to self-assess and identify improvement areas before regulatory action happens.

How the CCS Provider Guidelines are used by officers during CCS Spot Checks

The “Strengthening Regulation of Early Childhood Education and Care Safety through the Child Care Subsidy – Provider Guidelines (August 2025)” is not a checklist itself — it is the official policy and operational framework that guides how Commonwealth compliance officers conduct spot checks, assess risk, and make decisions about CCS approval, conditions, or sanctions. The CCS Provider Guidelines (Aug 2025) act as the rulebook for Commonwealth spot checks — outlining what authorised officers look for, how risk is judged, and how findings link back to funding, compliance, and safety outcomes. For providers, understanding this document means knowing exactly how your service will be viewed through the regulator’s lens — and using that insight to strengthen your QIP, governance, and Exceeding evidence before a visit occurs.

Here’s how it is used in practice by authorised officers

1. Forms the Regulatory Framework for Spot Checks

  • The Guidelines sit under the Family Assistance Law (FAL) and the Early Childhood Education and Care (Strengthening Regulation of Early Education) Act 2025.
  • They provide the legal and procedural basis for authorised officers from the Department of Education to enter premises, inspect records, and interview staff.
  • Officers use the framework to determine what to check, why, and how to interpret findings — for example:
    • Are CCS enrolments and attendance records accurate?
    • Is the provider operating in a way that upholds safety, quality, and integrity?
    • Do leadership and governance systems demonstrate accountability?

2. Defines Risk Indicators and Escalation Pathways

  • The Guidelines include a risk-based model that prioritises which services are selected for spot checks — based on data such as serious incidents, complaints, non-compliance, or rapid growth.
  • They outline the “compliance pyramid”, showing how responses escalate — from education and support → to conditions, suspension, or cancellation of CCS approval.
  • During a spot check, officers assess a service’s position within this risk continuum using the document’s criteria.

3. Aligns Commonwealth Compliance with State/Territory Regulation

  • The Department cross-references CCS data with ECRU (WA) and other state regulators to identify services at risk.
  • If a federal spot check uncovers health, safety, or quality concerns, these are referred to the relevant state regulator (e.g., ECRU in WA) for follow-up under the National Law.
  • This ensures the Commonwealth’s funding oversight and the state’s quality regulation work together, rather than overlap.

4. Guides Self-Assessment and Continuous Improvement

  • The same document is provided publicly so services can understand the expectations authorities will assess against.
  • Providers are encouraged to use it as a self-audit tool—checking their own CCS, safety, and governance systems before a spot check occurs.
  • This aligns with Exceeding practice under QA7 (Governance and Leadership), showing proactive monitoring and critical reflection.

5. Informs Post-Check Decisions and Actions

  • After a spot check, compliance officers use the criteria from the Guidelines to determine outcomes:
    • “Compliant”, “requires improvement”, or “high-risk”.
    • Whether to issue a condition, seek further documentation, or escalate to Services Australia or ECRU.
  • Any future funding or approval decisions (such as suspension or re-approval) must align with the decision-making principles outlined in this document.

What does this actually look like? 

Example: Self-Assessment – Strengthening Regulation of ECEC Safety through CCS

Service Name: Little Explorers Early Learning Centre
Approved Provider: Childcare Pty Ltd
Date Completed: 15 October 2025
Completed By: Nominated Supervisor – Jane Williams
Next Review: April 2026

  1. Commitment to Safety and Quality by Meeting National Quality Standards (NQS)

Our service demonstrates an unwavering commitment to safety and quality through embedded systems aligned with the National Quality Framework (NQF).

  • We maintain a comprehensive risk-management and supervision plan updated quarterly.
  • All educators hold current first aid, CPR, and child-protection training, verified in our staff matrix.
  • Policies and procedures are reviewed each year and cross-referenced with ECRU and ACECQA guidance.
  • The QIP is an active document reviewed every two months to reflect ongoing improvements and educator reflections.
  • Safety and compliance topics are standing agenda items at leadership and staff meetings.

Self-rating: 🟢 Strong
Evidence: Policy register | Training matrix | QIP reviews | Meeting minutes | Audit checklist.
Next steps: Continue embedding child-safe standards across programming; update risk-assessment training for new educators.

  • Improvement in NQS Ratings Over Time
  • Our service was rated Working Towards NQS in 2019 and achieved Meeting NQS in 2022 following targeted improvement in QA2 (Children’s Health and Safety) and QA7 (Governance and Leadership).
  • A post-A&R improvement plan identified specific actions: improved documentation, incident trend analysis, and strengthened communication with families.
  • Continuous internal audits since 2023 show progressive alignment with Exceeding themes — evidenced through educator reflections and strong governance oversight.

Self-rating: 🟠 Developing – with consistent upward trend.
Evidence: Past A&R reports | Internal audit results | Improvement plans | Educator reflections | QA2/QA7 documentation.
Next steps: Prepare for next A&R cycle by demonstrating sustainable Exceeding evidence in QA1 & QA6.

  • Previous and Current NQS Ratings and Conditions Imposed
  • Previous rating: Meeting NQS (December 2022)
  • Current rating: Maintained – due for reassessment 2026
  • Conditions: None imposed; however, following a minor compliance issue in 2021 (unnotified staff illness impacting ratios), a corrective-action plan was submitted within 24 hours and accepted by ECRU.
  • Ongoing compliance audits ensure this type of risk is now mitigated through a “backup educator pool” and daily ratio tracker.

Self-rating: 🟢 Strong
Evidence: Rating certificates | Correspondence with ECRU | Corrective-action records | Ratio tracking log.
Next steps: Maintain transparent communication with ECRU; retain all A&R evidence folders for cross-reference during CCS spot checks.

  • Serious Incidents, Complaints, and Breaches of Safety Laws
  • Over the past 24 months, two serious incidents were reported:
    1. Minor fall on playground (April 2024) — no injury; supervision plan reviewed.
    2. Medication error (October 2024) — parent informed immediately; full investigation completed and new double-check process introduced.
  • No breaches of safety laws or enforcement actions.
  • Complaints log shows three family concerns (all resolved within policy timelines).
  • Incident reviews are used for critical reflection and shared at staff meetings to strengthen safety culture.

Self-rating: 🟢 Strong
Evidence: Incident register | Complaint resolution log | Parent communication | Review meeting minutes.
Next steps: Introduce visual “Safety Snapshot” dashboard to track incident categories quarterly and share trends with families.

  • Compliance with Child Care Subsidy (CCS) Rules
  • All enrolments and attendance records are submitted accurately through our CCS software with weekly reconciliation.
  • Gap fees are collected electronically, meeting FAL requirements.
  • A quarterly internal audit checks attendance, enrolment status, and fee accuracy.
  • Two key administrators completed the Geccko “Understanding Family Assistance Law” training (certificates attached).
  • No compliance notices or sanctions have been issued.
  • Policies for CCS reporting, absences, and enrolment confirmations are reviewed annually.

Self-rating: 🟢 Strong
Evidence: CCS submission logs | Finance audit reports | Geccko certificates | Policy review register.
Next steps: Expand Geccko training to all lead educators and link CCS integrity indicators into the QIP under QA7.

Overall Summary

Little Explorers ELC demonstrates a proactive, data-driven commitment to child safety, compliance, and continuous improvement. Our self-assessment indicates strong alignment with the Commonwealth’s Strengthening Regulation Guidelines, ensuring CCS funding integrity and safeguarding children’s wellbeing through governance, transparency, and reflective practice.

How do I use this in my QIP?

QIP Write-Up Example

Focus Area: Strengthening Safety, Compliance, and CCS Integrity

(Aligned with the “Strengthening Regulation of ECEC Safety through the CCS – Provider Guidelines, August 2025”)

Quality Area 1 – Educational Program and Practice

Goal: Integrate compliance awareness and safety education into the learning program.

Exceeding Theme 1 – Embedded Practice

  • Educators embed safety, wellbeing, and self-care concepts into daily routines and intentional teaching.
  • Documentation links learning outcomes to protective behaviours, risk awareness, and self-regulation.

Exceeding Theme 2 – Critical Reflection

  • Educators reflect on how their practices uphold children’s rights to safety and agency.
  • Team meetings review incident data and supervision notes to inform curriculum design.

Exceeding Theme 3 – Meaningful Engagement

  • Families are invited to share their home safety strategies for inclusion in curriculum planning.
  • Children co-create visual safety rules, fostering responsibility and empowerment.

Outcome: Program decisions show deep understanding of safety as part of quality learning.

Quality Area 2 – Children’s Health and Safety

Goal: Strengthen proactive health, hygiene, and incident management systems.

Exceeding Theme 1 – Embedded Practice

  • Safety, hygiene, and supervision practices are consistent and visible across all learning spaces.
  • Risk assessments and daily checks are standard routines, not reactive processes.

Exceeding Theme 2 – Critical Reflection

  • Leaders analyse incident and injury reports to identify trends and prevent recurrence.
  • Reflective discussions focus on the quality of response, not just compliance.

Exceeding Theme 3 – Meaningful Engagement

  • Families receive open communication about incidents and service improvements.
  • Children learn about health and hygiene through visual displays and guided practice.

Outcome: Health and safety are culturally embedded as shared responsibilities.

Quality Area 3 – Physical Environment

Goal: Maintain environments that are safe, accessible, and promote confident exploration.

Exceeding Theme 1 – Embedded Practice

  • Safety audits (using ECRU compliance checklists) are completed monthly.
  • Environments are designed to balance risk-taking with protection.

Exceeding Theme 2 – Critical Reflection

  • Teams discuss how space, layout, and resources support both safety and autonomy.
  • Adjustments are made after incidents, feedback, or spot-check findings.

Exceeding Theme 3 – Meaningful Engagement

  • Families contribute ideas to playground upgrades and safety signage.
  • Children help create “Our Safe Spaces” maps to identify safe play zones.

Outcome: The environment evolves through collaboration, reflection, and design thinking.

Quality Area 4 – Staffing Arrangements

Goal: Ensure staff are qualified, compliant, and confident in safety and CCS integrity responsibilities.

Exceeding Theme 1 – Embedded Practice

  • WWCC and first-aid compliance are monitored automatically through a digital register.
  • Supervision zones are defined and understood by all staff.

Exceeding Theme 2 – Critical Reflection

  • Leadership reviews staffing rosters for continuity, ratios, and wellbeing impact.
  • Staff feedback informs professional development priorities and compliance focus.

Exceeding Theme 3 – Meaningful Engagement

  • Educators complete Geccko online training to build understanding of Family Assistance Law.
  • Shared learning is discussed in staff meetings to build a united compliance culture.

Outcome: A skilled, accountable team consistently meets and exceeds safety and CCS expectations.

Quality Area 5 – Relationships with Children

Goal: Ensure emotionally and physically safe relationships underpin all interactions.

Exceeding Theme 1 – Embedded Practice

  • Educators model respectful, nurturing communication that fosters trust and security.
  • Positive guidance practices promote children’s sense of safety and belonging.

Exceeding Theme 2 – Critical Reflection

  • Staff reflect on supervision strategies that protect children while supporting independence.
  • Feedback from families and children informs relational practice reviews.

Exceeding Theme 3 – Meaningful Engagement

  • Children contribute to creating service safety rules and kindness agreements.
  • Educators share strategies with families for supporting calm, regulated behaviours.

Outcome: Relationships are intentionally shaped around children’s rights to be safe, valued, and heard.

Quality Area 6 – Collaborative Partnerships with Families and Communities

Goal: Build a transparent culture of partnership, trust, and shared safety responsibility.

Exceeding Theme 1 – Embedded Practice

  • Families are regularly updated on safety improvements, CCS integrity, and policy changes.
  • Collaboration with local safety networks (fire, police, health) enhances community engagement.

Exceeding Theme 2 – Critical Reflection

  • Leadership reflects on feedback from family surveys about communication and transparency.
  • QIP improvements respond directly to community and family input.

Exceeding Theme 3 – Meaningful Engagement

  • Parents contribute to safety weeks, audits, and advisory groups.
  • Local agencies provide incursions and training, building community connections.

Outcome: Families and communities are partners in maintaining quality and safety excellence.

Quality Area 7 – Governance and Leadership

Goal: Strengthen governance systems linking safety, quality, and financial integrity.

Exceeding Theme 1 – Embedded Practice

  • Compliance and quality assurance systems are integrated across operations.
  • Internal “mock spot checks” ensure ongoing readiness for ECRU and CCS visits.

Exceeding Theme 2 – Critical Reflection

  • The leadership team reviews the CCS Provider Guidelines quarterly, updating policies accordingly.
  • Data from incident logs, audits, and QIP reviews informs governance decisions.

Exceeding Theme 3 – Meaningful Engagement

  • Reports are shared transparently with families, staff, and management committees.
  • Staff contribute to policy revisions and participate in risk-mitigation planning.

Outcome: Leadership demonstrates accountability, foresight, and a culture of continuous improvement.

BEST Childcare Consulting

At BEST Childcare Consulting, we believe proactive compliance is the new measure of quality.
Use the CCS Provider Guidelines as your roadmap — align your systems, educate your team, and embed safety and integrity into every layer of practice. Be prepared. Be accountable. Be Exceeding.

BEST can help you create your first CCS self assessment.

Contact us TODAY.

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