Proposed modifications of the rules for school daycare services and free education

1 April 2022

The Fédération du personnel de soutien scolaire (FPSS-CSQ) has submitted its comments to the Minister of Education on the two draft rules dealing with daycare services in schools.  Here are the main points of these two draft rules.

Responsibilities of the institution’s administration

This modification of the rules would clarify the role of the institution’s administrators concerning daycare services by reminding them that responsibility rests with them, as is usually the case.  The provisions of the rules describe their responsibilities unequivocally: they must play a leadership role in this matter.

First aid

Changes to standard first aid training courses should include a section on the proper management of severe allergic reactions. Anaphylaxis (severe allergic reactions) is on the increase everywhere, which requires an adjustment of preventive measures.

The number of children between the ages of 5 and 12 who received an epinephrine auto-injector between 2006 and 2014 increased by 90% and the number of emergency room admissions for allergic reactions increased by 25% among those under 18 years old. The prevalence of food allergies in Canada is around 6.9% among children aged 1 to 17. A significant proportion of allergic children had their first allergic reaction in the presence of food at school.

This requirement would be implemented in future training courses or when the training of daycare staff is renewed.  It would not be necessary to undergo specific training on this component if the educator’s qualifications are currently up to date.


With respect to ratios, we would have preferred that beginning next school year, rather than beginning on July 1, 2023, only daycare staff present among the students be taken into account when calculating the ratio.  For example, if the Daycare Technician, the Educator Principal Class or other educators are not actually present among the students, they wouldn’t be counted.

With respect to the ratio for kindergarten 4-year-olds in school daycares (SGMS), which is 1:17 if there are only 4-year-olds in the group, we asked that this be expanded to mixed groups, even if there is only one 4-year-old student attending kindergarten, because 4-year-olds have their own special needs.  They require more attention, more time and more supervision.  Special conditions are required to ensure that their needs are met and to ensure their safety and well-being.  We would prefer to see the 4-year-old kindergarten component of regulation 30011 of the budget rules improved for the next school year. 

We are hoping that the current ratio of 1:20 will be reduced in the next round of negotiations, in order to take into account the needs and realities of the milieu.

Sharing of premises

Sharing the use of premises is still an important issue for school daycares.  Shared premises are insufficient to accommodate all the pupils, which makes it necessary to use classrooms.  It must be recognized that this can generate dissatisfaction, so impacts need to be reduced and, even more importantly, we need to raise awareness of the needs of children among all education staff. As with the amendments to the rules, we think a premise-sharing protocol is essential in all our institutions.

Program of activities

The amendments to the rules recognize that school daycares play an important role in the student’s life and that a program of activities must be created, that it must be part of the school’s educational project, take into account the characteristics of the students and enable their overall development on the physical and motor, emotional, social, language and cognitive levels.  There should also be an open approach with a wide range of activities offered to children, as is the case in most institutions.

Fees charged to parents

The maximum charge would be $8.55 for regular days and $14.60 for pedagogical days, with no maximum for additional fees charged to parents during pedagogical days. This last point is important because students and parents are very keen on field trips. We understand that costs are an issue for parents, and we do not want this to be a hindrance to daycare attendance.  It will therefore be necessary to continue to plan activities at the school whenever there is an outing.

Since the morning period is shorter than the afternoon period, fees for sporadic students would be $3.00 an hour. For example:

  • 7:15 to 8 :00 (45 minutes): 0.75 hours X $3.00 = $2.25
  • 11:30 to 12:45 (1 hour 15 min.): 1.25 hours X $3.00 = $3.75
  • 3:00 to 5:30 (2hrs. 30 min.): 2.5 hours X $3.00 = $7.50

It is relevant that no administration fees will be charged to parents since section 3 of the Education Act states that in all cases the right to free education applies to costs of an administrative nature.  This makes it consistent with the law.

The fees would be indexed on July 1 of each year.

Lunchtime supervision

According to the draft rules respecting the free provision of teaching materials and certain financial contributions that may be required, the charge could not exceed $3.00 per hour for the lunch period and would be indexed on July 1 of each year.