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Does QLD need Provisional Registration?

Updated: Apr 15, 2022

We think so. But The Government is proposing to remove it in the review of the Education General Provisions Act (EGPA).


Welcome to part 2 of the HEA's Position Paper in response to the Consultation Paper

released by the QLD Education General Provisions Act (EGPA) Review. This is what we think about the proposals made. Our full paper and ways you can be involved are at the bottom of this page.


Application Process


Provisional Registration is protective of children. It provides a pathway for families to remain engaged with the educational system during times of crisis without adding to the stress they may be experiencing. Provisional Registration (s207) is one of the best features of the QLD EGPA, as it mitigates the long processing time for applications of 90 days, and makes home education a choice that families can make as and when the need arises.


The only part of the proposals in this section that the HEA supports is:

  • Applying for home education provides for an exemption from compulsory school attendance and enrolment of a child at a school for 14 days after the last day the child attended school.

However, we recommend the proposal be amended to provide that the 14 days is from cancellation of enrolment rather than actual attendance as students experiencing significant health issues may have been absent from school in the lead-up to the decision to home educate.


Would a shift to one application process provide a more streamlined experience for parents?


The HEA opposes this proposal.


The dual pathways of applying for Provisional Registration (s207) and/or full registration (s208) provides choice and flexibility, meaning that families are able to choose the pathway that best meets their needs. This ensures that more students' needs are met. Students whose needs are met do better, and when they do better our whole community wins.


It is not the dual application pathways that cause confusion. It is the use of the term ‘provisional’ to describe Provisional Registration (s207) as well as the period from application under s208 until completion of processing that is confusing.


We suggest that this could be resolved by changing the language used, rather than the process itself. It could be as simple as:

  • Provisional registration (s207)

  • Full Registration (s208)


If the DoE is to adopt a single registration pathway, we suggest the WA legislation as a template. WA provides that Registration must be provided on application with conditions very similar to Queensland's Provisional (s207). An assessment, called moderation, takes place within 3 months of application, and then annually. That process streamlines the planning and reporting components into a single process. Although there is no Provisional Registration, the effect is the same - up to 3 months’ automatic registration without needing to submit an educational program or summary in order to begin.



Are the time periods proposed reasonable for applicants and decision-makers?


The HEA opposes this proposal.


The time periods are not reasonable, and represent a significant reduction of time available to home educators with no corresponding reduction in processing time by the regulator.


Further, this proposal is based on the assumption that children are not receiving a high quality education during periods of provisional registration. There is no evidence presented to support this assumption.


We have significant concerns about the proposal to remove Provisional Registration (s207). These include:

  1. A significant reduction in the time available to home educators to develop their educational program summary.

    1. Under the current system - 60 days Provisional registration, plus (see below)30 days from the date of application to provide the education summary

    2. Under the Government’s proposal 30 days to submit the summary after applying for full registration

  2. Loss of choice, with corresponding loss of the system to meet the needs of children and families.

  3. Provisional registration provides a stepped pathway into home education. The loss of this may mean some families simply choose not to register.

  4. The only other state to have a 90 day processing time for applications is NSW. The absence of provisional registration causes a lot of problems in that state, and frequently increases distress of children and young people. Families in the processing period often receive unwelcome calls and visits from school personnel, truancy officers and even police. These calls and visits also increase the cost to the government with no corresponding increase in compliance or improved educational outcomes. The loss of provisional registration could see these issues occur in Queensland also, undermining the DoE’s desire for “a contemporary risk-based approach to regulation of home education which provides for the greatest degree of compliance at the lowest cost to all parties.” [Consultation Paper, p.6]


Should subsequent applications in a 12-month period be accompanied by reporting about education in the previous registration period (if no report was provided in that period)?


The HEA opposes this proposal.


This proposal introduces unnecessary complexity which may cause confusion and which is likely to discourage compliance.


Additionally, there has not been sufficient data provided to support this proposal. The Consultation paper indicates that a minority of Provisional s207 applicants - approximately 10% - collectively fall into the 4 categories where this may occur. No comparative data has been provided to compare how many applicants apply under s207 and s208.

One of the 4 categories was where children have returned to school and then undertake another period of home education. Penalising parents who return their children to school will deter people from returning to the system.


This proposal does not reflect a contemporary risk-based approach to regulation of home education which provides for the greatest degree of compliance at the lowest cost to all parties. It increases the regulatory burden on both families and the regulator, with minimal benefit to less than 10% of Provisional s207 Applicants.


Recognising the need for the Government to have a regulatory system that caters for all situations, we suggest an alternative proposal:

  • retain Provisional (s207) but limit it to one period of provisional 207 per calendar year, except where the young person has been enrolled in school between applications.


Does the proposed process adequately cater for unforeseen circumstances?


No, it does not. When families experience significant upheaval, such as trauma, mental health issues, natural disasters, interstate moves and the like, 30 days is often not enough time to recover and produce an educational summary.


Regulations that lack flexibility are likely to reduce the number of applications without a corresponding decrease in the number of actual home educators.


How can you be involved?

  1. Send your response to the consultation paper either

    1. directly to the Department (use your link) or

    2. to the HEA for anonymous submission (email to contact@hea.edu.au)

  2. Write to your MP

  3. Ask your friends and family to write to their MPs


What resources are available to support your participation in the review?

  1. The HEA has released a position paper in response to the consultation paper

  2. A form response letter for the review

  3. A form response letter for your MP


View the HEA's full position paper here:

Position Paper - QLD EGPA review
.pdf
Download PDF • 267KB

Need help to write your response to the DoE consultation paper? Here's a template you can use:

Response to DoE Form Letter
.docx
Download DOCX • 18KB

Write to your MP

Letter to Member of Parliament
.docx
Download DOCX • 9KB

Media Enquiries:

Book a time to talk with HEA President Karen Chegwidden, or

Dr Rebecca English (PhD)

Senior Lecturer

QUT

(07) 3138 3323


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