Volunteering for activities such as Meals on Wheels and at school tuck shops should count as "work" that will qualify parents for childcare payments, major childcare providers say.
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Australia's largest childcare provider, Goodstart Early Learning, along with the Australian Childcare Alliance and the Early Learning and Care Council, are urging the Abbott government to define volunteering in broad terms to allow more families to qualify for childcare assistance under the new families package.
The Coalition plans to require parents to work, study or train for at least eight hours a fortnight to gain access to 36 hours of subsidised care over the same period. They will have to work for 49 hours to get the full 100 hours per fortnight subsidy.
In the current system, many parents are able to access payments without doing a work activity at all.
While the Department of Social Services says it has not modelled the impact of the planned changes on families, the new "activity test" has sparked serious concerns in the childcare industry that some families and children will "fall through the cracks" if parents have difficulty finding work, have casual jobs or are easing their way back into the workforce after having a baby.
Submissions in response to a "regulation impact statement" for the childcare package have seen childcare providers call for a wide definition of volunteering as part of the activity test.
In its submission, the Australian Childcare Alliance, the peak body for long-day care providers, expresses concern about the proposal that "voluntary work only be recognised if through a recognised voluntary organisation".
It says work ethic and skills can be demonstrated in many positions, and "many voluntary positions, e.g. in schools, turn into regular employment".
Goodstart's submission adds that volunteering at a local Meals on Wheels, neighbourhood centres or sports club should still be recognised, even if they are not "specifically focused on a parent's employment skills".
It argues volunteering "helps break the cycle of disconnection with the community that plagues long-term unemployment and isolated mothers of young children".
In June, Department of Social Services officials told a Senate estimates hearing it needed to confirm exactly what forms of volunteering would be considered as part of the new work, training or study "activity test". Officials said the department needed to "have a good discussion about what is actually a stepping stone for work and workforce readiness".
Social Services Minister Scott Morrison says the new childcare package - which provides an additional $3.5 billion over five years - is intended to "help parents who want to work or work more".
He has also stressed that the government was proceeding carefully with the new reforms, the majority of which are not due to start until 2017.
"The regulatory impact statement report is being finalised and will then be considered by the government," he said on Tuesday. "These considerations will assist in the drafting of the childcare bill."
