Education and Training Reform Regulations Review

February 12, 2017

Attn: Strategic Policy Division
Department of Education and Training

GPO Box 4367 MELBOURNE 3001

Dear Sir/Madam:

Re: Questions regarding the proposed changes to the Education and Training Reform Regulations

I have read the Consultation draft and the Regulatory Impact Statementdocuments in order to prepare for the future changes, and there are several questions I have identified. Can you please clarify the issues stated below?

The consultation draft states in section 72.3.c.ii-iii that we submit a learning plan that specifies the following:

(ii)a proposed educational program comprising a learning plan that specifies when and where instruction will take place, and the subject matter that will be covered by the instruction during the first year of registration; and

(iii)details of the educational materials and resources proposed to be used in the instruction, including how the student’s learning outcomes will be recorded.

Further down into section 73, it states that the information needs to be given within the period, in the manner and form specified by the Authority to give them time to assess if, according to their opinion, the information given is sufficient. If the Authority deems the information insufficient, this will be the basis for refusing registration.

Issue 1. Unclear requirement details

What is the manner and form required for submission of a learning plan? This is very vague and very subjective. I understand there are many home-schooling methodologies, and it will be a difficult thing to come up with a form that caters to all varying methods. There must be something that the Authority reviewing will be looking for to consider a learning plan sufficient, in terms of each requirement mentioned above, though what that would be is unclear.

For example: For the requirement “When will instruction take place?”
are you after a certain number of days in a week?
Number of weeks in a year?
Number of total hours/days/weeks/terms for every KLA subject?
More importantly, what are things you will consider insufficient?

Moreover, the requirements needed from us should be requirements that will support us in giving a better quality of education for our children, rather than be a burden and a distraction that will hinder us from moving forward. These requirements must be supported and approved, not only by education experts, but more importantly, by parents who have had successful home schooling experiences.

For example:
When trying to communicate with the Authority regarding the learning plan requirements or review, will we potentiallybe looking at waiting for hours on the phone to be connected to someone to talk to? We will have to make contact during school hours and this will greatly affect the quality of education we are delivering.
Many home schoolers see travel as a valuable educational experience. If we put in the learning plan periods where we travel to a regional area, interstate, or even overseas as part of our learning experience, will the Authority approve of this, or will this be viewed as taking time away from doing formal “school work, and counted against us as not having sufficient time to do school hours?

Issue 2. Procedure and period of communication between home schooler and authority is unclear

In section 72, it states that an application must be sent by November 30 of the year before the child is proposed to start home-schooling. In section 74, it states that the Authority must give notice of decision after 28 days of receiving application. This part is very unclear to me. I would very much like to see more detailed clarification specified in the Regulation document regarding this part.

Question: Does this mean that if I have a child that will turn 6 on March 1, 2019, I can submit my application as early as Jan 2018, or even earlier, say 2 years before? This question becomes relevant because of a lack of clarity I have regarding the 28-day waiting period, which I will detail below.

Question: Given my assumption above, when VRQA Authority receives my application on Jan 5, 2018, if I count 28 days after this (which I counted to be Feb 15 2018, excluding Australia day and weekends), I can expect a notice of the reviewer’s decision on Feb 15 2018. During the period from Jan 6 – Feb 14 2018, will I be able to expect feedback or consultation from the Authority reviewing our application to give us a chance to revise our plan if they see it as insufficient, so that there is an active communication happening during the 28-day assessment? I got a hint of a potential active communication/interaction between the VRQA and home schoolers in review from the RIS but it is not stated clearly when this happens. Or do we wait without any communication within that 28-day period, and expect to receive a “yes” or “no” template form of communication from VRQA?

If the proposal of the draft regulation is to have an active form of communication during the 28-day waiting period, I have no further question regarding this section, other than a request to specify this clearly in the draft
If the proposal of the draft regulation will have no active form of communication during the 28-day waiting period, I require more clarification.
Can we expect to have information on what grounds the registration is being refused?
Will we be allowed to resubmit once more, and will this mean we can resubmit and wait for another 28 days for a decision? Following the scenario above, after I receive a refusal on Feb 15, 2018, if I make revisions and resubmit on Feb 20, 2018, calculating another 28 days it will be expected on April 3, 2018? Will the cycle of resubmitting and waiting be ongoing until acceptance is received, or until November 30 2018? After this, the child needs to have a school enrolment as a backup while we continue to resubmit and consult with appropriate authority for approval. Is this correct? This is not clear in the draft regulations.

Question: In case of a refusal, what can we do if we would like more information regarding what was disapproved? Will there be a supportive form of communication that will allow us to revise our submission and come to an agreement to pursue home schooling? There are a lot of questions regarding this part of the registration, due to a lack of definition and clarification. Would it be possible to have a personal meeting to consult one on one to clearly understand reasons if a refusal is received? What amendments can be made to get it accepted? What are our options if we are determined to homeschool? Can all these options and steps be clearly specified in the regulations?

In section 77, it states that the parent of the home schooler must notify Authority of any changes to the information given. This part is very unclear and raises so many questions on my part. Through my home schooling journey, one thing I have noticed is that change is inevitable because the child is growing, and his learning experience is not static. Our schedules change, our curriculums change, our resources change, our strategies change, our extracurricular activities change, our goals change. I constantly review during a term, and change course if I realise I am not making any headway. My focus and energy is heavily invested in seeing where a spark is ignited in my children’s learning. To document all this in a presentable manner for someone else when I am focusing on our direction will be very distracting and time consuming, and will greatly reduce our time for doing school for ourselves.

For example: I used a certain all-in-one curriculum for my oldest child for reading, writing, language, and math. I assume it will be what I will use for my next child. When the time comes for my next child to learn, I realize that my current curriculum is not working, so I try anothercurriculum (or maybe even more than one curriculum to address the different subjects), method, strategy, or schedule. Will I then have to contact the Authority that I am going to try another way of learning reading, writing, language and math as my second child is not responding as well to my planned resources as my first child? Do I have to give details of what I will use already? What if I submit my second plan to the authority, and after implementing, I realize it still is not a good fit. Then do I need to write up another plan and let the authority know I will still be on the lookout for another curriculum, strategy, plan, schedule or method? This trying to find a good fit can take place for at least 2 weeks, and may possibly change again before the term ends. Does this mean during this time, I need to keep submitting plan after plan of every change we are making? Or do we just submit when we have finally found a good fit? What if during our period of trying to find a good fit, we get picked for a review, and we are questioned for not sticking to the resources or plans we have submitted, will this then be grounds for deregistration because we did not let the authority know of our plans to change? All of this is very unclear, and has so much potential of wasting valuable time if not addressed properly, reasonably, and clearly.

Issue 3. What are the qualifications of the Authority who will be reviewing our plans?

I do not object to increasing requirements for registration. However, who will be responsible for reviewing our plans? Are they people who have a deep understanding of home schooling? What will be the basis of allowing a person to be a member of the review team? This is a very big part of my question about the regulation changes. If you will be in authority over me to assess whether my plans are successful for the future, are you first and foremost, for or against homeschooling? I have met many lovely people in the education industry, and I do not engage in discussions of home schooling with them or even with friends because there is often no point. They are closed to it, without having much knowledge about what it is all about. This bias against homeschooling is very prevalent in the education industry, and I am speaking from personal experiences with principals and teachers. If this is the mindset of the experts who will be positioned over us to review our home school education plans, this is not a fair start and it will be bound to fail because the reviewer does not believe in it in the first place.

The review panel, and the review system, are not clearly specified. If it will be introduced as a regulation that there will be more requirements needed from us which will determine if we can continue to homeschool or not, first, the requirements to determine what will cause it to be rejected need to be explicitly clear. Secondly, the requirements must be reasonable based on successful home schooling experiences. Third, the panel must consist of people who are supportive of home schoolers with significant practical home education experience.

A very big issue I see here is the 72.(3).iii requirement to put:

(i)details of the educational materials and resources proposed to be used in the instruction, including how the student’s learning outcomes will be recorded.

If the person reviewing our learning plan sees that we purchase educational materials produced by home schooling parents either locally or overseas, without any educational experience other than home schooling their children successfully all the way to university, for a home schooling mother, that is a substantial qualification for success. Will the reviewer in Authority use this as grounds for rejecting a plan, despite any demonstrated success?

What if, during a random check, it is found we are not meeting year level requirements, because we are going very slow, and I do not want us to jump to next level until we have mastery of the level we are at? If we are still at level 2, when we should be at level 3 or 4, for a home schooler, the idea is to go at the pace the child is willing to absorb and learn, because it is not about ticking a box without really digesting what is being taught. So, we pause for a while, and follow the leading of the child’s interest. It will not necessarily reflect very well on a review or a NAPLAN testing result which assumes a majority of children should have proficiency of certain academic skills based on age/year level. If the reviewer does not have a mindset and an understanding and belief of this principle, will it be made grounds for us to deregister, despite our approach being in the best interests of my child?

Issue 4. Will clarifications be released regarding these questions before the regulations are finalised?

This draft was released in December and submissions are due on February 28, 2017. Because this is a time of many beginnings both for DET and the home school community, many questions and clarifications will arise. The timing of when it was released was very poor. Our families needed our attention, and to have to focus on these lengthy documents during a time that should be spent with family should have been considered.

This is a pioneer project that will need much communication and transparency to get a reasonable and productive solution for both parties involved. I ask that the clarifications will be released with consultation from the home school community, and that ample time be given to digest the clarifications, and another period given to us to raise further questions before things are finalised.

Sincerely,

GilbeyDy

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