From:
Sent:Tuesday, 28 February 2017
To:DET Regulation Review
Subject:Submission for the Draft education regulations
To whom it may concern resending to ask that you please ensure my personal details are anonymous when published thank you.
Submission for the Draft Education Regulations
After reading the draft education regulations I have presented my submission, this includes some ways for families & the DET that will hopefully both be satisfied with the regulations. The following specifically pertains to the Homeschooling section Part 6 pages 30-33.
- Powers being fully granted to VRQA Authority's have a widespread fear amongst homeschoolers. Giving VRQA the power to reject or approve a homeschool registration goes beyond the scope of the law, the education and training reform act states that parents have the right to choose an appropriate education for their child. The regulations contradict this foundational principle of the act. It also breaches the Universal declaration of human rights article 26 (3) Parents have a prior right to choose the education of their own children.
This will put off many home educators from registering for fear of rejection, this has even been stated in the RIS, so it makes no sense as to why VRQA will be given such power over parents, if a registration is rejected this will have the chance of legal repercussions for the department. An estimated 20 thousand Victorian parents across the state have not registered to the VRQA, the main reasons for this is because it violates parent’s choices as stated above. This will also put some children at risk of parents who are being forced to go underground for fear of being controlled by VRQA. This is more concerning and is possible for causing more harm than good for children to be further put at risk within such extreme conditions as making parents feel they have no control to protect their children from harmful situations.
A solution would be to take this fear away from parents, accepting all registrations is a parent & guardians right, the Authority should not be granted any power to refuse a registration for homeschooling. Legally if a registration is rejected, the parent can just keep reapplying until it’s accepted so VRQA should not be allowed to refuse a registration, helping parents who choose this form of education for their children is the most logical answer, support & guidance is essential to increase registration.
There also needs to be a homeschooling department formed within DET, with experienced home educators at the very least with 5 years or more homeschooling experience as the people behind it, if there is no one in VRQA with any experience it’s going to fail, it is of utmost importance that DET & VRQA have people with personal experience in homeschooling, the setup of such a section within DET would promote support, safety & understanding for families who either choose to homeschool or who are forced to because of children who are special needs children or school refusers or children with mental health risks etc. This will also increase registration rates. This is the most logical solution for DET, VRQA, parents and most especially children, who should be first and foremost priority.
Families & VRQA working together in unity is vital for the future of educating children who are inadvertently let down by the educational system in public schools within the state of Victoria, further this is essential for children with special needs, if this is not set up as a supportive option then there is a capacity for a major increase in youth juvenile Detention Centre’s. I would go further in recommending that youth at risk of violence should have homeschooling promoted as an option to help them feel supported and understood at such an impressionable age in their teen years. I personally have seen children at high risk of turning violent become completely changed in their behavior due to homeschooling & the support of family.
- Plan implementation is seen as a form of control by parents, many home schoolers prefer to follow the curriculum using their children's own interests, children's interests can change from day to day or week by week and to expect families to stick to the plan is simply not feasible. Nor is it feasible to do plans for children who are special needs, in fact this is discriminatory as they cannot & do not learn the same way or the same pace as others. There is no understanding of the expectation of what types of plans would be accepted for registration.
A solution would be to get the parents to send a review perhaps twice a year showing the child’s learning & work progress that the child has achieved with the curriculum. This way the parents will feel completely at ease in the knowledge they can teach their child without the stress and anxiety of a timeframe on completion of levels for their ages, many parents want their child to learn at their own pace & forcing a child who isn't yet ready to learn something causes the child to rebel and not want to do the work. Many home-schooled children don't see schoolwork as “work”; they do it because they enjoy it & see it as a fun thing to do. Most importantly, special needs children require delicate handling as to their education needs, nobody knows best how to manage this except the parents and a home-schooling department within DET should do everything possible to support those needs or as stated previously has the potential to cause the child to grow up and have possible risks with violence etc. and risk going to youth detention centre’s, I have seen countless families home-school teenagers which then thrive in an environment from home as opposed to being angry and resentful at school’s who don’t understand the child’s needs, the support and encouragement and recommendation of home-schooling would be a fantastic option for those children at risk.
- The requirement for further information is a complete waste of time, this will cause major disruption to already struggling families, in my opinion causing more pressure to these families, and this will have an enormous increase of the risk of families let down by DET possibly with legal repercussions to the Department and VRQA. There is evidence of this happening in other countries, home education should be more supported and widely known as an acceptable option to all families which would greatly decrease the percentage of children who are struggling and have special needs, support is vital for teenagers most especially who are so misunderstood. Home education has saved countless children from future anger, mental health and violence issues in the state of Victoria over 60% in fact (taken from the Home Education Network’s website).
There is no criteria for what information will be sufficient to present to the Authority, this includes plans or assessment and leaves parents guessing at what would be acceptable by VRQA. Also in regards to reviews it states that the Authority will require specified information, how can parents know what to expect if it is not stated in the draft what is specified? Authority’s being given powers to cancel a registration also goes beyond the law, if a registration is cancelled it then increases the risk of legal repercussions because of the fact that it goes beyond the powers that the Authority is granted.
A solution would be to work with helping parents to support these children and families who rely on home-schooling as an alternative to mainstream. Control and dictating will only cause resentment and anger right across the community of home educators.
The commissioner letter addressed to Simon Kent has the following paragraphs:
To be adequate, a RIS must be logical, draw on relevant evidence, be transparent about any assumptions made and be proportionate to the proposal’s expected effects. The RIS also needs to provide a suitable basis for public consultation.
(There is no evidence for increased regulations in regards to home-schooling; if the department wants to see the progress of children’s learning then they should only require reports submitted perhaps twice yearly, or regulations similar to Queensland.)
The RIS notes that there is limited data available to inform the evaluation of the current regulations. Consequently, the analysis of the impact of many of the proposed Regulations is qualitative, based on the judgements or assumptions of the Department. Stakeholder feedback on this RIS will be particularly valuable in informing the Department’s understanding of the actual benefits and costs of the proposed regulations.
(It makes no sense to me why the Department did not attempt to gain feedback from the thousands of registered parents who home-school in order to better work out the RIS and the proposed draft education regulations, many parents have years of personal experience in home education and would be the most logical people to ask in regards to the creation and changes with regards to home-schooling, it is ridiculous that none of these parents were consulted about the regulation changes instead of the department making judgements and assumptions. I would go further in recommending the Department should at the very least have prepared and sent a survey or questionnaire to registered families before making changes that will affect them personally in order to gather evidence based data on any changes that the Department thinks should be in place. This would have been fairly simple and effective yet nothing was done, I personally think DET should be more responsible in considering such measures for the future of the children in the state of Victoria; it would have been quite a logical thing to do.)
The following pertains to the RIS.
The following section taken from page 6:
The Department reviewed the 2007 Regulations to identify options for improving regulatory practices and outcomes. As part of the review, the Department consulted with key stakeholders and the public in May and June 2016
(A key stakeholder would be the 2000+ registered home-schooling families being contacted to have their views considered for the purpose of the RIS; this did not happen, why not?)
The following section taken from page 7:
At the application stage, provide a learning plan that outlines how they will deliver instruction and what resources and materials they will use to cater for their child’s circumstances and learning needs
If selected, participate in a review that would involve providing evidence of their child’s learning progress, and possibly also undertake an interview with the regulator.
Even with these changes, Victoria would retain the ‘lightest-touch’ regulatory approach for home schooling when compared with other Australian states and territories. The proposed regulations do not contain common assessment practices used in other jurisdictions such as mandatory home visits or mandatory curriculum-based instruction.
(As previously stated plans are a complete waste of time and they also contradict Education and training reform act 2006 Page 19 Part 1.2, Principle 1.2.1 (d) Parents have the right to choose an appropriate education for their child. Parents choose to educate their child mostly by following their own interests, the very fact that parents who CHOOSE this form of education is a contradiction to forcing the parent to create plans, a child’s interests can change from day to day or week by week and so doing a plan is simply not feasible, if parents are forced to do a plan this would simply be to appease VRQA, no parent will be able to stick to such plans.
A solution would be to follow a similar requirement such as Queensland and get parents to send in reports and evidence of the child’s learning progress. Also I will just add that if VRQA were to decide to reject a registration due to the plan not being an acceptable one according to them, then by law they are taking away a parents prior right to choose the education of their child which will have possible legal ramifications. There is no evidence that plans will be of any value to anybody, it is a complete waste of tax payers’ money, not to mention the very fact that teachers are not required to send in plans to VRQA for each individual student, why are is the department asking more of parents than the current education system? The department are way out of their league and naïve in assuming it will take a mere 15 minutes to look over each individual plan, planning can take weeks, just ask any teacher, it simply makes no sense to be asking more of parents to send in plans.)
The following section taken from page 12:
In May 2016, the Victorian Government announced a review of the 2007 Regulations. The review aimed to identify options for improving regulatory practices and outcomes that achieve the intent of the Act—to provide for a high quality standard of education and training for all Victorians. The review investigated how existing regulations are working and how they could be improved if they are remade. It was informed by detailed analysis undertaken by the Department of Education and Training (the Department), submissions to a public consultation process organised for this review and feedback from targeted stakeholders, as discussed in chapter 2.
(The department did NOT bother to contact any of the registered home-schooling families in the state of Victoria. Why didn’t they? That was a potential 2000+ opinions of the home education community that was completely disregarded, had they done so they would have received thousands of submissions giving DET plenty of more options and ideas for what could be worked out for future regulations, keeping both families and DET happy with the outcome. It’s true that the majority of parents are stating the obvious, leaving things as they are is the most viable option for parents and the department, the only thing that needed changing so that the department are satisfied that home-schooled children are learning is to ask for a report of learning progress from families, similar to Queensland who have already learnt from past regulations, why hasn’t DET looked over other states data to see how their regulations have been? Learning from other states would have given DET a head start; it’s as simple as that.)
The following section taken from page 12:
This RIS presents the Department’s analysis and considerations that underpin its proposal for replacing the 2007 Regulations. Organisations and individuals with an interest in education and training in Victoria are invited to provide comment on the proposed regulations. Public feedback will inform the Department’s final proposal for replacing the 2007 Regulations.
(Yet again the department has a complete disregard for the thousands of home educators in the state of Victoria, no attempt at contacting any of these people has been made whatsoever to directly to invite the individual registered families and yet it appears under the Compliance strategy page 37 of the RIS, the department already made plans to inform families of the changes after they have already been implemented, it is such a disturbing thing in this day and age is to see a complete disregard for the community in the education system of Victoria! This is seen as a form of dictatorship over the people.)
The following section taken from page 14:
Education and training services are delivered to children and young people who are among the most vulnerable members of the community. The Department’s assessment indicates regulation, as a form of government intervention, is generally necessary to address market failures, promote social equity and manage public risk in delivering learning and development outcomes for the community.
(To promote social equity the department should have made an effort to contact home-schooling families to ask for input in the draft education regulations. The management of public risk is vital for the future, home education should be a recommended option for youth’s who are struggling within the public school system, I am extremely concerned there will be a major increase in the rise of such impressionable teenagers in youth detention centres, there is already a new one being planned in Werribee South, prevention should be more important than preparing for an increase in youth’s who will possibly end up in such centres. I strongly advise in using home education as a preventative measure for teenagers and as a recommendation to parents for helping these kids, it is vital to prevent violence and support them, I have seen kids be “saved” just by having home education as an option as opposed to forcing them to remain and stay in the situation that is detrimental to their health, wellbeing and the health of the community, when these children are supported it is a huge turn around in their mental health and behaviour within families and the community.)
‘Information asymmetry’ occurs when the service provider has more information or knowledge about service quality than the service user or consumer. The quality of education and training is not always fully observable to students and their parents, making decisions difficult, such as which school to attend and which learning pathway to undertake. This could create disincentives for providers to make sufficient effort and attain high service quality.