KITCHENER -- The Ministry of Education has proposed changes to child care in Ontario.

The changes on the table include grouping different age groups together, reducing the ratio of staff to children in some groups and lowering the qualifications for providers.

The amendments were released on Oct. 2. The province said they're aimed at saving time, providing clarity and offering flexibility for child care sector businesses.

Feedback on the 36-page document is due back by Nov. 20.

"For those 36 pages, probably 30 of them are those small types of changes that are not problematic, that are not going to be harmful," said Carolyn Ferns, policy coordinator for the Ontario Coalition for Better Child Care.

However, Ferns said there are some concerning amendments.

One proposal would allow child-care centres the option to group infants and toddlers in the same group. The group would have children up to the age of two, rather than separating any child younger than 18 months.

"That would mean that younger children would be in larger groups with fewer qualified staff," Ferns said. "That's really a concern for a quality perspective and children's well-being."

There could also be changes to staff-to-children ratios, allowing 10 children to be looked after by three staff members.

The Ministry of Education said it's also considering changing the qualifications for people looking after kindergarten-aged children and older to anyone with a diploma or degree in child and youth care, recreation and leisure services, or is a member in good standing with the Ontario College of Teachers.

"It really undermines the value of registered early childhood educators and I think that that's quite a problem," Ferns said.

The ministry said that change is for employee retention.

Ferns said she'd prefer to see better funding and working conditions.

"We are disappointed that the government is trying to push through regulatory change in the midst of a pandemic when child-care operators are solely focused on the health and safety of the children and our employees," a statement from CTV News from OWL Child Care Services said in part. "We call on Minister Lecce to pause all regulatory reform to allow the sector to focus first on the children and to have adequate time in the new year to review, absorb and respond to proposed changes."

OWL officials said they will analyze the amendments before making official comments.

The changes are all still just proposals. Child-care providers can give their feedback by next month.

In an emailed statement to CTV News, the Ministry of Education said there is no "universal consensus" on which ages should be grouped together.

"Research shows that the most important factor for children’s learning, development and well-being are their experiences of consistent caring and responsive relationships," the statement said in part.

The ministry also said the ratio of caregivers to children would be determined based on the children's ages.

Officials said the ministry will continue to work with sector partners about the proposed changes and use the feedback to determine criteria for child-care centres going forward.

Read the proposed changes here: