By Sue Wight
Let’s look at the deeply flawed Regulatory Impact Statement (RIS) used to justify increased regulations for home education.
School is not great
The RIS assumes that the state school system provides “high quality” education for all. This is demonstrably false
e.g. up to 46 per cent of Victorians do not have the literacy skills required to cope with everyday life and work.
The RIS contains a further assumption that home education is inferior and requires, “… more intensive monitoring that would induce greater effort and reduce the risk of suboptimal learning progress.” (p32)
On the contrary, there is strong Australian evidence that home education produces good results. It is insulting to suggest parents require oversight to produce greater effort!
In fact, 60% of home educating families have withdrawn at least one child from mainstream school. For 24% this is a matter of last resort i.e. as a direct result of an inadequate school system.
A solution in want of a problem
Good regulations should identify a clear problem. The ‘problem’ identified is “some home-schooled children may not receive a quality education.” The regulatory increase is disproportionate with the possibility of a problem.
- DET identified no evidence of harm.
- DET examined school results for previously home educated students and found no problem.
- DET tracked home ed alumni and found no problem.
Unable to find data demonstrating poor home education, the RIS acknowledges, Anecdotal evidence and the limited available data support the contention that most home schooling families are providing their children with regular and efficient instruction, and their children are attaining acceptable outcomes (p27).
The secondary ‘problem’ identified was a lack of data in which case the Victorian Guide to Regulation requires that further evidence be gathered but DET made no apparent attempts to do so. Instead, they decided to adopt a “more active approach” based on too little evidence.
The RIS indicates that the results of previously home educated students were tracked using Victorian Student Numbers (VSNs) and found comparable to the fully schooled population. The RIS made the outlandish claim that where students have been partially schooled it is impossible to determine if the results are typical of home educated students. Given the wide variety of reasons home educated kids enter the mainstream school system (social, divorce, family illness, changing finances, home education difficulties, and so on), this data can reasonably be expected to represent the broadest outcomes of home education and yet DET dismissed it.
If the data had shown home education in a poor light it would have formed the central pillar of the RIS. The exclusion of the details appears to suggest that the results did not match DET’s chosen narrative and were therefore glossed over.
Where data does exist DET chose to ignore it or cherry pick from it. The NSW BOSTES study, for example, examined NAPLAN, year 10 and HSC results for thousands of school students who had been home educated in the past and their results were equal to or higher than the NSW average across all tests. DET ignored it.
All the available data was dismissed as having too small a sample size (without revealling the sample sizes). On its own, one sample size of one study might be too small to reach a conclusion, but when multiple such studies all have similar results showing home education has academic outcomes equal to, or better than school, a serious attempt should be made to collect and analyse this data to inform regulations and provide transparent reasons for the changes proposed.
The submission from Distance Education Centre Victoria “expressed concerns about the educational outcomes of home-schooled students, and noted some students experience difficulty when transitioning to a formal school setting”. This was accepted without explanation or elaboration. For example, what percentage of students ‘experience difficulty’ and, given that transition of any kind can be difficult, wouldn’t it be more useful to look at the results of all previously home educated DECV students? No, DET just accepted DECV’s unsubstantiated claims as fact.
And vague concerns raised by the submission by The Commission for Children and Young People “about vulnerable children who may be home-schooled” was used to partly justify the increased regulations without any evidence of actual harm or risk.
So, with no data or research to validate the declared problem and following a Multi Criteria Analysis designed to favour a predetermined outcome, DET proposes to spend an additional $698k to increase regulations based on assumptions that are not supported by the available evidence.
And that is our bureaucracy hard at work!