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Consultation Paper April 2022

wirraglen4homeschool

Updated: Jun 6, 2022

During the last week of March 2022, many parents and carers received from the government an email called "EGPA Consultation" which asked for their opinion on a few changes regarding the current law.


We analyzed the document and we found it to be more like a position statement instead of an actual consultation. There should have been done some research or discussion with home educators before issuing the paper so that the questions would have been hopefully more appropriate.


We have added some questions of our own for your consideration and also provided answers for the paper's questions to reflect our thinking:


Statement #1

(1).The first published employment condition (of five) for a HEU Senior Education Advisor is Demonstrated capacity or proven ability to quickly acquire knowledge of the legislation relating to home education in Queensland and the philosophies, practices and processes underpinning home education..



Question to reflect:
Do you believe the HEU staff appear to have or to demonstrate such qualifications?

Statement #2

(2) High Quality education is not defined for either schools or home educators.

How to achieve a High - quality education IS defined in the Act at sections5,6 and 7. There are two goals and several ways of achieving these goals. It applies to home educators and all education institutions.

It is not the Act's role to define a curriculum. The Minister is responsible for State school programs (section 12 of the Act), Home school programs are the responsibility of the parent.

If the Act or the State were to define the home school program then the parent would not be providing it, as defined in the Act (section 205). In any case, the Paper states that the definition of Home Education is to remain.



Question to reflect:
Why should the right to decide what your home educated child engages with, and when to engage, be taken over by the State?


Statement #3

(3.) Regarding ACARA - at paragraph 2, ACARA statement (The Shape of the Australian Curriculum, Volume 5, June 2020) it states "the primary audience for the Australian Curriculum is teachers, The curriculum is written (to be) appropriate for professional practitioners of each learning area."

ACARA is NOT designed for the varied philosophies, practices and processes of home educators.



Question to reflect:
Does the HEU currently advise parents of this?


Statement #4

(4) Currently the HEU registration "recommendations" re the Summary and High-Quality education do NOT comply with the Act. The HEU "preferred template" for reporting does NOT comply with the Act. The HEU offers no advice to parents on how to comply with the Act. The HEU is not required to be reviewed, publish reports or survey parents. They have no published Key Performance Indicators (KPI's)



Question to reflect:
Do you believe the HEU needs to be regularly reviewed and the reviews made public?

Question to reflect:
Do you believe the HEU needs to conduct regular parent surveys?


The Questions in the Paper.

Based on our experience and feedback from parents, here are our suggestion of answers for the paper received.


Page 8, Boxed questions:


1. Would one application work.

A. Yes


2. If you cut and run before reporting is due, to reapply should you have to report before being registered?

A. No. Make the reporting requirements more relevant and flexible.


3. Time periods are reasonable?

A. 60 to 90 days to submit registration Summary and High Quality statement is necessary. Parents need time to decide on the High-Quality education for a child. If reviewers at HEU had qualifications as described at (1) above, then they would appreciate this.


4. Caters for unforeseen circumstances?

A. If the HEU is staffed by people with home education knowledge and preferably experience then this will be handled sensibly.


Page 9, Boxed questions:


1. Would a definition of high-quality education help for registration and reporting?

A. No! The Act does not define the content of a High-Quality education - neither for schools nor for home educators. The Act sensibly describes the purposes of a High-Quality education and how to achieve these. What a home educated child learns is the result of a personalised and necessarily flexible learning plan. This plan is vetted by the parent and the child. The State is not responsible for them.

What a school student learns from a pre-determined, inflexible curriculum is unknown. A curriculum is arbitrary - a guess. Claiming it is "high-quality" for every child is unethical, even dishonest. Programs at State schools are decided by the Minister (Act, section 12). Parents and children are not involved in their creation.


2. Do you support proposed definition?

A. No - because it is not what the Act interprets as the requirements of High Quality education. These requirements are about its provision. not its content. Parents do not have to justify the contents of their home education program, just the way it is delivered. Any curriculum designed for mass compulsory education (like ACARA) can never be called High Quality education.


3. Considerations needed to support home education philosophies?

A. The HEU staff already are required to support Home Education philosophies (see (1) above) They need to be held to this requirement..


Page 10 (top). Boxed questions:


1. Remove report on educational progress?

A. Of course. It is not obligatory for school children, is arbitrarily assessed by HEU staff and the reviewer is not required to give their reasons for cancellation re non progress (except in a court of law). Because the HEU have not published how HEU staff have been assessed on (1) above, then no one knows if reviewers are qualified to assess reports.


2. What helps reporting for the "decision maker".

A. Currently the HEU reporting package does not comply with the Act, the Explanations or the Reporting for Home Education Form. This demonstrates that the HEU either do not understand the requirements or are rejecting them. What's needed?. Decision makers who understand and respect the legislation and home education culture (as currently required - see (1) above).

Compliance with the existing legislation requires - 1. parents report on progress wherever it occurs 2. Samples, annotations and a review can be included (as per the current Reporting for Home Education Form). 3. Parents supply Summary for next year.

If the HEU staff cannot comply with the existing legislation then surely they should be relocated or retrained and the newer "qualified" staff could ponder this question.


Page 10 (bottom) Boxed Questions:


1. Is sampling report submissions for noting compliance OK?

A. Yes


2. Sample on what basis?

A. Sample initial reports and then subsequently sample every two to three years.


3. All reports in first year?

A. If everyone was sampled in the first two or three years then why would future reports even need reviewing every year? We need professional staff at HEU - with home education experience.


4. New Q On what basis should a report be assessed?

A. First - assessed by Qualified (by home education standards) Assessors. Second - Assessment criteria compatible with home education philosophies, practices and processes (see (1) above).


Page 11, Boxed questions:


1. Need to issue Certificate of Registration?

A. Some people need something similar for accessing some benefits or facilities.


2. Would a written notice of registration suffice?

A. Perhaps an App. or paper where necessary.


Page 12, Boxed questions:


1. Shifting review timeframes to calendar days?

A. No - why should home educating parents to be assumed to be working on weekends.


2. Should current timelines stay?

A. Yes,


Page 12, Question box:


1. Additional grounds for registration cancellation appropriate?

A. 1. The Act requires the home education be provided primarily at the child's usual place of residence. This is NOT the same as the Paper's "being delivered" statement (p12). This is clumsy on the part of the authors. Words matter! Nor does "provided by" mean "taught by" - HEU got caught out on that one. Nor does "progress" mean only "improvement" - they got caught on that, too. Signing a stat. declaration, affirming the education was provided as per the Act's definition, would be sufficient.


2. Are there any grounds for cancellation that should be considered?

A. Well, what are the grounds for the cancellation of a Teacher's registration or a school's registration? Can we look at them and see if any conditions reasonably apply to a parent home educator who has neither classroom teaching qualifications (nor requires them); nor school accreditation qualifications (nor requires them)?

The measurement of educational progress as a major qualification for maintaining the registration of the child applies to neither schools nor teachers. Is this requirement aligned with home education philosophies, practices or processes? Is it aligned with the High-Quality criteria in the Act? Does it align with best practice as recognised by educators and home educators?



Supporting material
RE HIGH QUALITY EDUCATION - from sections 5,6 and 7 of the Act (EGPA)
The (only) objects of the Act are (edited for home educators) - to make available to each Queensland child or young person a high-quality education that will- (i) help maximise his or her educational potential and (ii) enable him or her to become an effective and informed member of the community.
The objects are to be achieved mainly by - *placing responsibilities on parents and the State in relation to (this) education (and) *ensuring education programs are responsive to the individual needs of children and young people and *encouraging a parent's involvement in his or her child's education and * encouraging (children) to participate in a way that achieves the best learning for them.
The principles intended to guide achievement of the Act's objects are - * parents have the responsibility of choosing a suitable education environment for their children *education should be provided to a child or young person in a way that - provides positive learning experiences and * promotes a safe and supporting learning environment and * recognises his or her educational needs and * children and young people should be actively involved in decisions affecting them to the extent that it is appropriate having regard to their age and understanding.

Final Considerations


Q. Anyone see the word "progress" in this lot?

Q . Anyone believe that how High Quality education is approached in the Act somehow does not cover home education?

Q. Anyone believe that the Act should define what a child must learn?


Meanwhile.....


Section 12 of the Act requires for each student attending a State instructional institution (e.g. school), there must be provided by the Minister an educational program that, among other criteria, * has regard to the age, ability, aptitude and development of the student; * recognises and takes into account the nature of knowledge (also known as epistemology),


The State school educational program is not required to guarantee "progress", just to promote continuity.


The Minister is NOT required to provide programs for Home Educating children. It's the prerogative of the parents.


The Minister, not the Act, chooses the program for State schools. If the definition of a High Quality education included its contents then this would be the parliament dictating the knowledge requirements for all children. Not acceptable.


Finally - comparisons with other jurisdictions are not the same as comparing against "best practice". It is here that I am sure hoe educators will separate from bureaucrats.


Hope this has helped and feel free to get in contact with us if needed.

(contact details on home page)


Use it as you choose,

Wirraglen Home Education Support Group

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