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LA Response to EHE Guidelines Consultation.

 

Here is a transcript of the response of Worcestershire County Council LA to the DCSF consultation on EHE guidelines. There is a comments section below that you are invited to use.

 

Worcestershire County Council

 

PO BOX 73

 

Worcestershire County Council

 

WR5 2YA

 

1 Do you agree that it is helpful for the DfES to issue guidelines to local authorities?

 

Yes

 

Comments:

It is important for Local Authorities to have guidelines to develop effective policies and procedures. However, these guidelines need to be clear, concise, specific and accurate and not open to extreme interpretation. The guidance needs to reflect current legislation and meet the aims of the national agenda’s and priorities such as, Every Child Matters and Working Together to Safeguard Children.

 

 

2 Do you agree that the description of the law (paragraphs 2.1-2.3) relating to elective home education is accurate and clear?

 

No

 

Comments:

There is no definitive meaning to effective and suitable education.   This description is too vague and is unworkable, as the LA does not have the right to visit or meet with parents and children, and the only submission being the parent’s philosophy.  Relying on the good will of parents to submit reports that vary accordingly from detailed descriptions of activities, resources used and progress made to simple descriptions of what the child has done.  In order for the LA to meet statutory obligations and to prevent parents feeling intervention is intrusive, guidance should be issued regarding minimum standards i.e. formats for reports and practical examples of appropriate material for submission keeping the child central to the objectives, emphasising that the child is receiving an appropriate education which meets the Every Child Matters Agenda and Safe Guarding initiatives and that prepares a child for later life whilst accommodating the family philosophy.  More importantly this will prevent conflict between families and LA’s and the sometimes-unfair criticism levied at both parties as each interprets in their own way the legislation.

 

3 Do you agree that the description of local authorities’ responsibilities (paragraphs 2.5-2.11) is accurate and helpful?

 

No

 

Comments:

It is very difficult to develop accurate information for families when the national guidance is unclear. Different Local Authorities interpret the description in different ways thus causing a ‘post code lottery effect’, which further alienates parents.

 

The use of the phrase ‘reasonable progress’ is undefined. Local Authorities cannot identify ‘reasonable progress’ through one annual report and/or submission of a ‘couple’ of pieces of work. Also, Local Authorities have no proof that the reports/work submitted is that done by the child.

 

Another example of interpreting guidance, which leads to conflict as the parent’s feel the LA’s actions are intrusive and unsupportive providing no real benefit ie funding or resources. Many consider that children have been failed by a system, which is making yet further demands. A clearer description and definition will encourage closer working and more trust keeping the child central to the objectives.

Section 2.7 contradicts 2.5 as it states that LA can intervene if they have good reason to believe that parents are not providing a suitable education however LA have no right to monitor progress whereas 2.5 states that children should make reasonable progress. The quality of the educational provision is difficult to identify through limited contact with families. Educational experiences have been extremely negative for them, therefore building the child’s trust and confidence is paramount whereas, educational attainment is of secondary concern, however a compromise has to be reached. 

 

2.11 does not reflect Every Child Matters and Working Together to Safeguard Children. Whilst respecting the rights of parent’s the rights of the child have not been taken into consideration. Local Authorities should take into consideration ECM and WTSGC and be proactive in seeking views and promoting the welfare of children  but are unable to do this without having the ‘right’ to see the child.

 

Whilst we acknowledge most families provide a ‘good’ education there are some families who require further support in order to help them to fulfil their ambition to provide a good education. It would therefore be most helpful if LA could be provided with minimum standards.

 

4 Do you agree that the section on contact with the local authority (paragraphs 3.4-3.7) is accurate and helpful?

 

No

 

Comments:

 

3.4 positively sets out the duty of the LA although contradicts with 2.7 as 2.7 states that LA have no right to monitor educational provision, whereas 3.4 states ‘those monitoring education provision should seek advice from the Traveller Education Support Services.

 

3.4 also suggests discrimination towards travelling communities as they should be treated the same as any other Home Educating family.

 

3.6 does not present clear guidelines on what may justify ‘reasonable concerns’ or efficient and suitable. Infrequent contact with families does not enable LA to identify efficient and suitable education, as the progress made is difficult to identify.

 

5 Do you agree that the section on providing a full-time education (paragraphs 3.11-3.14) – and in particular, the characteristics of provision (paragraph 3.13) – is accurate and helpful?

 

No

 

Comments:

 

The guidance provided in this section is clear, however, places more emphasis on what parents are not required to do rather than what they are. It would be helpful to make this paragraph positive by stating what parents may wish to consider.

 

3.12 suggests LA should take into consideration a range of information from home educating parents, however, current legislation states parents are only required to submit a parental report philosophy. There should be more guidance provided on what a ‘report’ should contain

 

 

3.13 contradicts 3.12 as it suggests that LA should ‘reasonably expect’ parents demonstrate characteristics whereas 3.12 suggests LA need to recognise that home education has different approaches. This needs clarifying further to ensure parents are aware of their role in providing their child’s education.

 

6 Do you agree that the section on developing relationships (section 4) is useful?

 

Not Sure

 

Comments:

 

This sections provides effective guidance on developing effective relationships, however, child protection issues are not easily identifiable through little or no contact with parents and their children. This does not reflect Every Child Matters or Working Together to Safeguard Children.

 

Ensuring appropriate and effective guidance will again ensure the child is central as all participants in the process work together effectively to support the child and family in an acceptable manner appropriate to all. Intervention should not be regarded as a criticism or a threat but as support.

 

 

7 a) Are the suggested resources in section 5 and appendix 2 useful?

 

Yes

 

Comments:

 

Yes, although for ease of reference they should be categorised and in alphabetical order.

 

7 b) Should any other contacts be included?

 

Yes

 

Comments:

 

It is useful to provide parents with useful contacts resources, but we must stress that they do not have to use these so they are not restricted to solely these contacts.

 

We must also ensure that the contacts/resources provide are ‘quality assured’.

 

END

 

 

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