An open letter to the Victorian Department of Education regarding the Draft Education Regulations 2017

(Updated on 19 January)

21 December 2016

Education and Training Reform Regulations Review
Attn: Strategic Policy Division
Department of Education and Training
GPO Box 4367
Melbourne, Victoria 3001

Dear Sirs and Madams:

The Victorian Department of Education has before it Draft Education Regulations that would, in part, require registered home-schooled families to:

    • wait for permission before removing children from school

    • submit a plan to Victorian Registration and Qualifications Authority (VRQA) for approval as part of registration process

    • submit to reviews by the VRQA on a ‘random sample’ basis by the VRQA.

My question is: Why? What problem is this plan designed to solve?

The claim in the RIS is that the Victorian Education department does not “have enough data about quality of homeschooling education in this state”. In a thinking organisation that requires data, research is done before regulations are enacted. Since you are entrusted with the education of our children, I would like to assume that yours is a thinking organisation, and so I have to wonder what it is that you’re truly trying to accomplish.

I have been a classically oriented homeschooling parent for 14 years. It alarms me that the VRQA intends to further infringe on the educational autonomy of registered home-schooled families, with measures can not serve the stated purpose and are thus unjustifiable.

I agree whole-heartedly that every child deserves the best possible education, but those who value Universal education must carefully steward the limited tax-payer resources available to provide for those who would drink at the public well.

Those resources that would be squandered to no end by the addition of the expenses of new staff and infrastructure (and increased work load) required to collect, evaluate, and maintain the new homeschool registration information demanded by these proposed new measures are desperately needed for the education of those children whose welfare has already been entrusted to the public school system of the state of Victoria.

The eager, publicly educated student are ill-served when we squander the limited resources we have for the education of the children of this state on unnecessary new projects that don’t serve them.

There is no evidence to suggest that home-education in Victoria is broken. There is, on the other hand, evidence published every day, in the newspapers comment columns and online conversations, evidence to suggest that the standard set for functional literacy by the public schools in Victoria is not excessively high. Perhaps you should turn your attention to the standards of education and the levels of engagement of the students currently in your care.

When I first began my study of pedagogy in the late 1970s, one of the first things I learned was that there are dozens of methods of approaching the education of young people, and that all of the methods work better for some children than for others, and that no one method is ideal for every child. I also learned that the one thing required for successful learning is internal motivation by the scholar. Young people learn best and remember most when they are motivated to learn for their own reasons.

That means that even the very best of public schools can only successfully reach and engage the majority of children. Large group education can not reach every child; that is the nature of the human condition.

Homeschooling families, with their very small class size, are better suited to conveying a style of education at an appropriate speed and depth, best suited to their own scholars, especially when those scholars fall on either end of whichever continuum you might want to evaluate. Already, in designing an education for my single child over the last many years, I have had to change course several times to keep pace with his development in unexpected directions; something that is simply not feasible in large scale education.

Home-educators tend to be “can do” people; people who see a problem and work toward a solution rather than waiting for someone else to fix it. This is the very sort of problem solvers that Victoria, and Australia, needs. Surely there can be no fruitful end to an endeavour that would burden an already under-funded system, and present one more barrier for the kind of autonomous, enterprising families we need so badly in our state.

Please reconsider these regulations. The regulations, as written, are FAR too vague, and give far too much undefined power to the VQRA, with no guidance or protection for homeschool families who will be subject to that power. In at least one case, it intends to usurp the moral and legal rights and responsibilities of a parent to protect their child from harm. It brings up far more questions than it answers. The Regulatory Impact Statement, which should be used to explain why the regulations were written the way they were, is instead used to hide functional regulations where they needn’t be reviewed before or announced when they are changed, leaving the homeschool family on a slippery footing in which we can’t count on the rules from one moment to the next. This is duplicitous and unfair.

Attached is my point by point discussion of the proposed regulations.

Commentary on the Draft Education Regulations 2017 as it applies to Homeschool Families

Misti Anslin Delaney
Parent Educator