Wrong! The QLD Government is proposing shorter times to respond to reviews, and the removal of Certificates of Registration.
Welcome to part 5, the final instalment of the HEA's position paper in response to the EGPA Review Consultation paper.
We hope you are feeling equipped to respond the the Consultation paper and are taking the opportunity to make your voice heard.
A copy of our full position paper is at the bottom of the page for you, along with templates to help you respond to the DoE and write to your MP.
If you are prefer to make your submission anonymously, simply send it to contact@hea.edu.au We will de-identify your submission and include it with the HEA submission.
We do not collect information about registration status, and we will not disclose your details.
Removing requirement to issue a Certificate of Registration
Do you support removing the requirement for issuing a Certificate of Registration?
The HEA opposes this proposal.
Producing a certificate of registration is not an onerous task for the DoE. In this technological age, we expect that it would be largely automated. If that is not the case, it may be more effective for the Government to update their systems rather than seeking to alter the legislation.
Certificates of registration are used by many families as evidence that they are registered. Their removal may disadvantage the most vulnerable in our community.
Is there anything you use the Certificate of Registration for that would not be addressed through provision of a written notice of the registration decision?
Using the written notice of the registration decision generally includes extra information not included on a certificate. Some families may find the need to use the notice instead of a certificate to be invasive of their privacy.
Potential uses for the certificate of registration include:
Accessing discounts at educational venues such as museums, zoos etc.
Some providers of educational resources (e.g. Maths Online) require evidence of registration to access educational discounts.
Centrelink requires evidence of registration to access AIC or to waive activity requirements.
Additionally, some children like to have the certificate and include it in their portfolios.
Changing calculation of time periods for internal review decisions
The HEA opposes this proposal.
Are there any unidentified risks associated with a shift to calculating the timeframes for internal review decisions on a calendar day basis?
The move to calendar days represents a significant reduction in time for home educators. For example,
20 school days = 4 weeks but
20 calendar days = almost 3 weeks.
This proposal is based on a flawed assumption that home educators do not observe weekends and holidays.
Should existing timelines for internal reviews be retained if this occurs? If not, what changes might be required?
No. If this proposal were adopted, a significant increase in the timeframes would be required.
Expanding grounds for cancellation of registration
The HEA opposes the expansion of grounds for cancellation of registration.
The only valid grounds for cancellation is failure to comply with the standard conditions of registration.
If a school is not meeting requirements, a body moves alongside them and helps them, holds their hand to be successful. We need to have the same approach with home education. In cases of failure to comply with the standard conditions of registration, support and assistance should be provided to assist the parent to comply. This could be provided by the Government by means of an Advisory Board, or the parents could be referred to community organisations such as the HEA to access support.
The question must be asked: why is the Queensland Government seeking to add reasons for cancellation?
State/Territory | Cancellations in the last reporting period |
QLD | Data Requested |
TAS | NIL |
ACT | NIL |
VIC | 1.27% (2019) |
NSW | 1.83% |
SA/NT/WA | Data not available |
Does inclusion of these additional grounds for cancellation of home education registration appropriately align with the home education registration requirements?
The HEA opposes the expansion of grounds for cancellation of registration.
Linking registration to the child’s usual address is problematic, because it:
May disadvantage families with insecure accommodation, including those who rent, who may experience periods of homelessness or who are travelling.
May disadvantage shared custody situations where children usually live on more than one home.
May be interpreted to mean that education that occurs outside the home does not ‘count’ towards a young person's educational program.
Rather than adding a reason for cancellation, the HEA suggests that this problem could be resolved by updating the definition of home education. A more contemporary definition would recognise the home as the locus of control, rather than the physical location of education. Simply put, the home in home education is about who takes responsibility for the child's education, rather than where it occurs.
We also have concerns about the proposed reason for cancellation being: “The parent ceases to be the education provider.”
This could be used to restrict learning opportunities, as has happened in the recent past. For several years, the HEU has been instructing parents that they cannot report on subjects not taught by them, an issue only recently resolved. Home educated students learn in a variety of ways and settings, including:
Groups/co-ops where parents share the teaching.
Groups/co-ops where parents share the cost of hiring a specialist teacher.
Individual tutoring for specific subjects - for example a music tutor may be engaged to provide instruction on learning a musical instrument or a maths tutor may be engaged for maths tuition.
Independent learning using online resources or programs where the parent is the facilitator but not the teacher.
While we do not support pop-up schools currently appearing, we suggest a more appropriate governmental response would be to investigate the displaced teachers running those groups.
Are there any other grounds for cancellation that should be considered?
No.
We repeat, the only valid grounds for cancellation is failure to comply with the standard conditions of registration. And then, only after genuine support and assistance has been provided in a way that is mindful of the inherent power differential between the regulator and a parent.
How can you be involved?
Send your response to the consultation paper either
directly to the Department (use your link) or
to the HEA for anonymous submission (email to contat@hea.edu.au)
Write to your MP
Ask your friends and family to write to their MP’s
What resources are available to support your participation in the review?
The HEA has released a position paper in response to the consultation paper
A form response letter for the review
A form response letter for your MP
View the HEA's full position paper here:
Need help to write your response to the DoE consultation paper? Here's a template you can use:
Write to your MP
Media Enquiries:
Book a time to talk with HEA President Karen Chegwidden
Dr Rebecca English (PhD)
Senior Lecturer
QUT
(07) 3138 3323
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