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Complaint to Cabinet Office

Page history last edited by starkfamily1@... 17 years, 4 months ago


This letter has been posted to the Cabinet Office and Complaints Dept at DfES, 31st January 2007. Thank you to all who took part in writing it.




Better Regulation Executive, The Cabinet Office.


Formal Complaint.


This is a formal complaint about the failure of the Department for Education and Skills (DfES) to involve home-educating families, as primary stakeholders, in an effective manner in consultations and policy decisions regarding elective home education. The DfES has disregarded the Code of Practice on Consultations as described at:





In detail, our complaints are:


1. Failure to Identify and Represent the Primary Stakeholders in Home Education.


The DfES has failed to identify, properly involve and properly represent the primary stakeholders in home education, i.e. home-educating parents and children, in the DfES Consultation on Draft Home Education Guidelines for LEAs in March 2005 and in the preparations for the prospective consultation on the Statutory Framework for Home Education. Specifically:


a. Throughout the 2005 consultation, the DfES only involved local authorities (LAs) and representations from two home-educating groups. With some reluctance and under some pressure, the DfES then accepted further representation from a third home-educating source. With regard to the prospective consultation, which we have been informed has resulted from the consultation in 2005, Adrian Thompson at DfES has confirmed, on 29th January 2007, that the DfES have defined the stakeholders as “selected local authorities and home education organisations. (Home Education Advisory Service, Education Otherwise and the Family Education Trust.)” Family Education Trust is not a home education organisation.


The DfES has consistently failed to take into account the highly diverse nature of the home-educating community and the fact that most home educators are not members of national organisations. Consequently, these primary stakeholders have been, and continue to be, excluded from the process of defining what, if any, issues there are with current guidelines or on monitoring of home education. The DfES did not develop “a comprehensive list of stakeholders with whom you should consult, not just the 'usual suspects,' “ which is contrary to guidance in the Code of Practice on consultations.


b. For the 2005 consultation, the DfES accepted and represented a narrow and partial definition of the issues from a number of self-selecting LAs. Many of these are LAs that are already dealing with home educators in ways that demonstrate a failure to understand how home education works and that far exceed their legal duties and responsibilities. The DfES therefore, failed to take a proper account of the concerns raised by home-education organisations involved.


2. Failure to Attempt to Involve Hard-to-Reach Groups.


With regard to both the 2005 consultation and in the preliminary stages of the prospective 2007 consultation, the DfES has failed to attempt to involve hard-to-reach groups.


The Code of Practice on Consultation provides a list of potential stakeholders on whom policy changes may impact, and states that policy makers “should proactively involve them in consultation”. The Code lists the following groups:


• Children and young people

• Disabled people

• Ethnic minority groups

• Faith community groups

• Gypsies and travellers

• Lesbian, gay and transgender groups

• Local authorities

• Older people

• People in rural/peripheral areas

• People on low incomes

• Refugees and asylum seekers

• Small businesses

• Voluntary organisations


Many of the above groups include primary stakeholders in home education issues. However the DfES failed to make any effort to reach most of these groups and failed to address potential barriers to involvement of home educators, limiting involvement to select local authorities and voluntary organisations.


DfES officials have told those home educators who have enquired about the process that the “full consultation” will be conducted via the internet. This excludes those without internet access as well as those who are not involved in national home-educator networks. The majority of home educators fall into one of these categories.


The DfES has so far failed to provide a sufficient variety of means of involvement to ensure true and fair representation of the home-educating population ignoring the Code of Practice guidance that states: "Different consultation methods produce very different types of responses. This is especially true of informal methods."


3. Failure to Keep Stakeholders Informed Throughout the Process.


By failing to consult the majority of home educators at all stages, the DfES has neglected to "keep stakeholders informed throughout the process."


4. Failure to Involve Primary Stakeholders Early in the Process.


Given that the consultation currently being prepared on "light-touch changes" to the monitoring of home education and the statutory framework for home education is largely predicated upon the limited DfES Consultation in March 2005, the DfES has also failed to involve home educators as primary stakeholders sufficiently early in the process.


5. Biased and Unrepresentative Research and Information Used in Consultation Proposals.


Other principal sources informing the prospective consultation are also biased and unrepresentative of home educators’ views. For example, research undertaken by the NFER is of very poor quality and methodology with extremely limited cohorts and the Ivatts report on electively home-educated traveller children only appears to represent LAs via organisations such as the Traveller Education Services. Travellers themselves do not appear to have been consulted in any serious manner.

6. Policy Development Process Already Well Advanced Before Consultation.

The Code of Practice states that “Consultation is a continuous process that needs to be started early in the policy-development process”. It appears however that much time is being spent by DfES developing the policy regarding elective home education to an advanced stage, prior to the public consultation process.


7. Conclusion.


The DfES has neglected to engage effectively with primary stakeholders throughout the process and thereby failed to account for their views. The DfES approach ignores the Cabinet Office Code of Practice on Consultation, which requires them to:

• promote government transparency and accountability

• improve awareness and understanding of the policy area and can redress uninformed public/stakeholder assumptions

• encourage public ownership of the policy, therefore increasing public commitment to it." (quote from the Code of Practice on Consultation).


We request an acknowledgement of the receipt of this complaint and look forward to prompt corrective action and a detailed reply.


Yours faithfully,

Barbara Stark.

(AHEd Chair) for the committee and membership of AHEd.


cc. DfES

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