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Memorandum submitted by Pam Perryman
Executive Summary (a) Mr Badman was saying 'that the status quo cannot remain' before the end of his review. I feel therefore we had a situation where the outcome was already a foregone conclusion. (b) Legislation has already been put in place to monitor home educators in the Improving schools and safeguarding Bill. It states that this Bill is acting to protect vulnerable children by "improving monitoring arrangements for children educated at home." See http://www.commonsleader.gov.uk/output/Page2831.asp Again this suggests that the outcome of the review was a foregone conclusion. (c) The Review recommendations are premised on incorrect evidence and use of statistics. It also suggests that home educated children are more vulnerable than the rest of the population, but does not back this up with any valid statistics. (d) The recommendations that came out of the Graham Badman Review are so many and so far reaching that it should not be called a Review, but rather a Consultation. Reviews are normally followed up by consultations, but the consultation which has followed this review is merely looking at the details of how to implement the recommendations - it is not asking key stakeholders their views on the recommendations themselves. Although this was a 'review' and not a 'consultation' the select committee enquiring into the review states that it invites written submissions on "the conduct of the review and related consultations......." I feel therefore, by implication, that the Inquiry is accepting the review as a form of consultation. (e) The Review and ensuing consultation has flagrantly ignored the Berr code of practice for consultations on many of its points. See http://www.berr.gov.uk/whatwedo/bre/consultation-guidance/page44420.html (f) We had an extensive consultation in 2007 and out of this came the present government guidelines on elective home education. See Guidelines for local authorities on elective home education. Both home educators and government had accepted these guidelines. Why then are we having yet another Review/Consultation so shortly after this when there has been no significant change to the status of home education? Too many reviews/consultations surely are in breach of the Berr guidelines number 5.1 'the burden of consultation'. (g) Home educators are the main stake holders in this review and yet their views are so obviously lacking in the report. Of the two thousand responses to a call for evidence, over 75% were from home educating parents or home educated children. Yet Mr Badman chose to quote from only two of over 1500 letters and one was to the detriment of the home education case.
Introduction I am an elective home educator. I have a background in Social Work including child protection and am also a qualified lecturer for further education. My two children have never been to school (although they have had the choice to do so), but have been 'autonomously' home educated since birth. My husband and I chose to home educate for philosophical reasons - we have no religious or political allegiances that have led our thinking. My 'children' are now 14 and 22. The 22
year old has recently finished a degree in maths and computing at a Russell
group university in Despite achieving such high academic qualifications in maths and computing he did no 'structured' work at home, but followed his own interests (autonomous learning). He took up maths when he was 15, just before entering college to take his A levels. Although I feel that academic qualifications are not by any means the only route to success that was the route my son chose. It is this route that is often queried with the question how can home educated children learn all subjects, especially maths or the sciences, if we are not 'experts' in these ourselves? My individual example and that of many others is evidence that they can succeed in such endeavours. This to me suggests there are numerous ways
to learn and that my experience of home educating my sons gives me a unique
expertise that should feed into the Graham Badman Review. Sadly, despite both
my son and I talking with Mr. Badman at length when he was invited to a home
educators meeting at At this meeting I and other home educators (including children and older teenagers) spoke for a long time with Mr. Badman and yet none of this seems to have been included in Mr. Badman's Review. Also I was very concerned to hear him say at this meeting on several occasions that the status quo cannot remain. Evidence/Factual Information
(1) With regard to (c) above one of the main terms of reference of the review was to find out if there was a greater prevalence of child abuse and forced marriage amongst home educators. This suggests again that the conclusions of the review were a foregone conclusion and the major stake holders have not been properly consulted on such a wide sweeping piece of legislation with such far reaching implications for the British population as a whole i.e. the precedence to be set for government to enter any home without just cause - the old adage 'guilty before tried'. The grounds for the review (i.e. potential child abuse and forced marriage were not founded). The Review clearly stated that it had found no evidence of forced marriage - see recommendation 24, 8.14. With regard to child abuse the statistics used by Mr Badman were found to be incorrect. From W. Wallace, BSc MSc MPhil FSS AFIMA, Statistician. Mr Wallace has worked in local government as a statistician and also as a university statistics lecturer and research fellow. "The methodology as shown does not stand up as plausible or acceptable statistically.... .. There are at least two main flaws to be noted: 1. the inappropriate use of one measurement instead of the target measure. Using 'known to SS' rather than recorded abuse (often termed an error of operationalisation). 2. Using a non-probability sample. No standard errors or confidence intervals can be computed. Only some qualitative value may be possibly obtained. This is error in sample selection. I can say without any hesitation that the information on methodology casts grave doubt on any use of the results from the Badman Review."
With regard to point (e) above, the following evidence quotes the berr guidelines on consultations: (2) 1.2 It is important that consultation takes place when the Government is ready to put sufficient information into the public domain to enable an effective and informed dialogue on the issues being consulted on. But equally, there is no point in consulting when everything is already settled. The consultation exercise should be scheduled as early as possible in the project plan as these factors allow. Berr guidelines.
My bold and italics. This seems to suggest that everything was already 'settled'.
(3) 2.2 If a consultation exercise is to take place over a period when consultees are less able to respond, e.g. over the summer or Christmas break, or if the policy under consideration is particularly complex, consideration should be given to the feasibility of allowing a longer period for the consultation. Berr guidelines.
The Graham Badman Review was held at the beginning of the summer and the Consultation has followed on straight after the Review and is being held during the height of the summer. Added to this we now have an Inquiry into the review. I would say that the burden to consultees of attempting to reply to all these elements over the summer period is too much. Added to this should we be having a consultation about the Review if there is also an inquiry going on into the Review? This seems to me to open the Inquiry to the criticism that it is merely a whitewash.
(4) 2.4 When planning a consultation, it is important to take steps to raise awareness of the exercise among those who are likely to be interested. In particular, departments should consider ways to publicise consultations at the time of or if possible before, the launch-date so that consultees can take advantage of the full consultation period to prepare considered responses. Berr guidelines.
This was not done.
(5) 3.1 Consultation exercises should be clear about the consultation process, i.e. what has taken place in the development of the policy prior to the consultation exercise, how the consultation exercise will be run and, as far as is possible, what can be expected after the consultation exercise has formally closed. Berr guidelines.
The underlined was not done. There was a consultation exercise in 2007 and government guidelines on elective home education published. At no point since then has it been explained by government why we are having another review/consultation or what the evidence for holding another one is. Therefore major stake holders have been denied the right to make their views known on whatever these issues are/were.
(6) 3.2 Consultation exercises should be clear about the scope of the exercise, setting out where there is room to influence policy development and what has already been decided, and so is not in the scope of the consultation. Berr guidelines.
It was never officially made clear to home educators that there was no room to influence policy or what had already been decided, particularly with regard to registration, monitoring and seeing the child alone.
(7) 3.3 Estimates of the costs and benefits of the policy options under consideration should normally form an integral part of consultation exercises, setting out the Government's current understanding of these costs and benefits. A "consultation stage Impact Assessment"11 should normally be published alongside a formal consultation, with questions on its contents included in the body of the consultation exercise. An Impact Assessment should be carried out for most policy decisions and consultation of interested parties on the Impact Assessment and on equality assessments can bring greater transparency to the policymaking process and should lead to departments having more robust evidence on which to base decisions. It is important to read the guidance on specific impact tests, including the race equality impact assessment which is required by statute. Berr guidelines.
With regard to (7) and (8) above there has been no impact assessment for the recommendations of the Badman Review, therefore no consultation on it. In these lean times an impact assessment is necessary as the cost may be deemed too high by all parties including government itself. See an impact assessment commissioned by the Home Education Advisory Service at: http://Tiny.cc/uTqTB The cost implications of this Review are serious indeed!
(8) 3.5 The subject matter, any assumptions the Government has made, and the questions in the consultation should all be as clear as possible. A mixture of open and closed questions will often be desirable, and consideration should be given to offering consultees the opportunity to express views on related issues not specifically addressed in the questions. Berr guidelines.
In the Review there was no "opportunity to express views on related issues not specifically addressed in the questions." In fact there were only 6 question for the 'public' and 59 for the Local Authorities. This does not seem very democratic. Added to which the questions were 'leading' and gave little scope for individual answers.
(9) 4.4 Thought should also be given to alternative versions of consultation documents which could be used to reach a wider audience, e.g. a young person's version, a Braille and audio version, Welsh and other language versions, an "easy-read" version, etc., and to alternative methods of consultation. Guidance on methods to support formal consultation exercises to help reach specific groups and sectors (regional, public meetings, online tools, focus groups, etc.) is available. Berr guidelines.
This was not done. There was no version for younger people and yet the recommendations affect them directly. There were no alternative versions to take account of ethnic minorities or 'difficult to reach' sections of the population. The consultation/review was online only - how did the government intend to reach those people who do not have access to computers? See Berr guideline 4.3 also.
(10) 5.1 When preparing a consultation exercise it is important to consider carefully how the burden of consultation can be minimised. While interested parties may welcome the opportunity to contribute their views or evidence, they will not welcome being asked the same questions time and time again. If the Government has previously obtained relevant information from the same audience, consideration should be given as to whether this information could be reused to inform the policymaking process, e.g. is the information still relevant and were all interested groups canvassed? Details of how any such information was gained should be clearly stated so that consultees can comment on the existing information or contribute further to this evidence-base. Berr guidelines.
The burden of consultation for home educators has been extensive. This represents the fifth consultation/review relevant to HE since 2005. Previous consultations/reviews include the Consultation on Elective Home Education 2007, the Consultation on Raising Expectations 2007, the Consultation on Guidance on Identifying Children Missing an Education, Sept 2008 and Mr Badman's Review in 2009. At no point were home educators given the opportunity to "comment on the existing information or contribute further to this evidence-base". We were never asked to nor were we given the 'existing information'.
(11) 6.1 All responses (both written responses and those fed in through other channels such as discussion forums and public meetings) should be analysed carefully, using the expertise, experiences and views of respondents to develop a more effective and efficient policy. The focus should be on the evidence given by consultees to back up their arguments. Analysing consultation responses is primarily a qualitative rather than a quantitative exercise.6.2 In order to ensure that responses are analysed correctly, it is important to understand who different bodies represent, and how the response has been pulled together, e.g. whether the views of members of a representative body were sought prior to drafting the response. Berr guidelines.
This has not happened with the review. Mr. Badman has dismissed research carried out by well known and very competent academics on the subject - Paula Rothermel, and Alan Thomas to name only two. He has even quoted Paula Rothermels research incorrectly saying she had used a very small sample whereas in fact she used a large sample of 1000 families studied over 3 years http://www.pjrothermel.com/Research/Newspaper/ace.htm Alan Thomas has done a great deal of research on home education, written several books on the subject and is now looking at autonomous home education and how it works http://www.howchildrenlearnathome.co.uk/ . His research indicates that it does work but Mr. Badman saw fit to dismiss this by saying he doubted its efficacy and felt more research was needed. It would seem that existing research and home educators own submissions did not give Graham Badman the answers he was after. Key stake holders (home educators) do not seem to have been thought about at all in this review. Mr. Badman visited 3 home education groups, but there is not one quote from any of the so eloquently spoken young people, parents or home educated adults. If he had done so the Review would have shown the success of autonomous education, many young people having attained good academic qualifications, engaged in excellent work in areas they were interested in. Other submissions to Graham Badman consisted of children and parents telling him how abused their children had been at school and giving him very full details of their cases. Why was this not generalised and put into his report. So basically Mr. Badman dismissed academic research and first hand reports as evidence - what evidence then did he use to support his recommendations?
(12) 6.4 Following a consultation exercise, the Government should provide a summary of who responded to the consultation exercise and a summary of the views expressed to each question. A summary of any other significant comments should also be provided. This feedback should normally set out what decisions have been taken in light of what was learnt from the consultation exercise. This information should normally be published before or alongside any further action, e.g. laying legislation before Parliament.16 those who have participated in a consultation exercise should normally be alerted to the publication of this information. Berr guidelines.
None of this was undertaken. Home educators have been obliged to resort to attaining this information through Freedom of Information requests.
(13) 6.5 Consideration should be given to publishing the individual responses received to consultation exercises. Berr guidelines.
This was not done - some of these have recently been attained again by Freedom of information requests.
(14) 6.6 The criteria of this Code should be reproduced in consultation papers alongside the contact details of the departmental Consultation Coordinator. Consultees should be invited to submit comments to the Consultation Coordinator about the extent to which the criteria have been observed and any ways of improving consultation processes. Berr guidelines.
It was not produced alongside the consultation paper.
Recommendations for Action
(1) Immediately instigate an Impact Assessment of the Review.
(2) Review the statistical and research evidence used in the Review.
(3) Make sure that the recommendations contained in the Review are not immediately implemented as it has largely disregarded the Berr guidelines, founded its conclusions on fallacious evidence and largely ignored the major stake holders (home educators).
(4) Call for the consultation and the legislation contained in the Improving and Safeguarding Bill to be halted on the same grounds as above.
August 2009 |