Mr Merlino’s standard response

Home Ed Regs Forum
February 22, 2017
HEN’s submission on the Draft Regs
March 1, 2017
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Mr Merlino’s standard response

Most who have taken the trouble to write to the Minister detailing their concerns, have received a standard letter by return – we now have hundreds of copies of this document with a different name at the top of each one:






























These standard letters are frustrating and insulting:

  • The Minister DOES NOT address the individual concerns raised.
  • The letter imparts information that the recipients already know – i.e. it is unnecessary to tell them a review is underway when that is what they wrote to him about.
  • The 60 day public consultation period is framed as a bountiful favour to the public. This is misleading when “The minimum public consultation period is 28 days. However, Victorian Government policy is that, wherever feasible, consultation should be for at least 60 days.”[Victorian Guide to Regulation: A handbook for policy-makers in Victoria p53] The government has therefore tried to portray best practice as a favour to the community and, in setting their 60-day period as the Christmas holidays when all schools were closed and MPs unavailable for meetings, was inconsiderate and clearly planned to avoid public engagement.
  • The Minister complains of a lack of data on home education and yet DET has conducted no research in order to gather data to inform the proposed regulations.
  • His claimed ‘responsibility’ to ensure we are providing a good education is ironic when so many of us home educate because the government failed to meet our children’s educational needs.
  • DET could easily understand types of home education being used in Victoria by reading the research, and the claim the proposed regulations will “support more targeted engagement and policy development” clearly means “push people into school wherever possible”.
  • “The Department has knowledge and expertise in all forms of educational practice and approaches, and is able to assess the particular approach or methodology that a home school family uses to ‘substantially address’ the eight key learning areas.” In reality, the Department clearly does not understand home education or these regulations would not have been so poorly designed. They have no experts on home education and clearly have no plans to hire someone with appropriate expertise. In addition this statement contradicts the one before – if their ‘experts’ don’t have enough information to inform policy, their expertise is an odd kind.



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