Speakers: Charles Tyers and Dean Woodgate, Managers, Independent Schools, VRQA
Charles: Myself and Dean Woodgate, we’re the dual managers of independent schools in the VRQA. Our responsibility is for looking at registration and review activities for independent schools. The application process will be coming through to both Dean and myself. And in terms of what we are assessing your application against, it will be against the guidelines, the minimum standards and the requirements for school registration.
You can see here, a copy of the guidelines. And if you haven’t seen that document before, I very much encourage you to get a copy and, have a look through all the details there. We’ll hear a bit more today about some of the specifics and some examples of schools that have not been able to demonstrate sufficient evidence to get registration, some fictional examples about what to look out for.
So, I encourage you to pay attention to those examples and see that you can navigate past those. The Ministerial Order 1359 is new from mid-2022. You’ll hear a little bit more about that. But again, very detailed guidelines are available on our website. I’ll hand over now to my colleague Dean to talk through some of the minimum standards and areas that we’ve got a couple of case studies on and, I’ll return talk about one of the case studies and then hand over to our colleagues at the VCAA.
Dean: Thanks, Charles, and welcome everyone to this webinar. I’m going to be covering areas, particularly focusing on the minimum standards.
First up today looking at curriculum and student learning, particularly enrolments, staff employment and school infrastructure. And we’ll also have a look at Ministerial Order 1359 which is about the care, safety and welfare of students.
Every school must substantially address 8 learning areas. And these are listed on the screen here. I’m not going to go through each one in turn. And importantly, your application must include a curriculum plan and timetables to show how the curriculum will be organised, and the number of teaching hours delivered in each of the 8 key learning areas.
Every school must substantially address the 8 key learning areas unless they are a specialist school or unless they’ve sought an exemption from the VRQA. Not being able to teach one, there needs to be exceptional circumstances in those cases.
So, let’s have a look then at some of the enrolment policy and enrolment agreement, aspects of what we’d be looking to see in any application and particularly, it needs to be clear from the school as to who can and can’t enrol. What selection criteria you might use.
The process for application needs to be very clear, so that we can understand how you work through that process, and the decision maker in that process needs to be clearly identified and grounds upon which enrolment may be terminated.
It must be clearly stated as well. But as a minimum on the right-hand side of the of the slide, it must clearly have a code of conduct. The fees, the educational services provided, and termination grounds.
That’s the inclusions that must be in the agreement.
Now, the curriculum that can be offered needs to be in one of those 5 listed on this on the screen. Obviously, we’ll be hearing from the VCAA later today, but they’re the curriculum frameworks that are currently approved and recognised by the VRQA.
So, we’ve gone then into a case study on student enrolment and curriculum. In this case, a secondary school is seeking registration with the VRQA to deliver Victorian curriculum Years 7 to 10 and VCE Years 11 and 12.
Enrolment policy clearly states who the school can enrol, and the criteria that it will use to select students, but it does not include an enrolment procedure. It’s unclear who makes the decision to accept or decline enrolment applications. And what we often see in applications that come into the VRQA is that policies are often there, but the actual procedures of how those policies are run and rolled out is not included.
So, this is an example of where something is missing.
So, to continue, the enrolment agreement is also vague about when the enrolment of an individual may be terminated. Stating that the only reason is for non-payment of tuition fees and the enrolment agreement does not include a code of conduct for students, parents, and guardians.
Instead, it just says students must behave appropriately at all times. Many of the school’s policies and procedures have been copied from another school, and the name of the other school still appears in the footer. So, if you do have other campuses or other schools that you are using policies of and learning from, please ensure that these are specific to your school and your site. These policies have also not been contextualised for the specific cohort of students that is anticipated to be at the school.
The curriculum plan is ambitious, offering students in Year 9 and 10 several elective studies. To accommodate these studies, Languages are only taught in Years 7 and 8, students elect either an arts subject such as music, visual arts, or design and technology. And the submission also includes that the school has employed 10 teachers 3 of whom hold provisional VIT registration and a fourth permission to teach. One teacher has a condition on their registration application.
The submission does not address how the conditions were managed by the school and the school is in a commercial building shared with several other tenants, including a gym, an auto body repair workshop, and a residential tower block, and it doesn’t have direct access to the building car park. There are no outdoor or sporting facilities and the disabled toilet is shared with gym.
So that’s a that’s an example of hopefully not a real-life case study, someone else can probably [...] advise me of that, but that’s an example of some of the materials that we might receive where the material is incomplete or not clear.
So, I guess the lesson from there in that particular example is to be very clear in your in your application, particularly with respect to the policies and then the subsequent procedures, so that we can make a clear assessment on whether you meet the guidelines.
So, as we’ve said the timetables must show how much time is spent on each learning area. And the benchmark is 25 hours of instruction per week. Staff employment, as we mentioned in the case study, teachers must be VIT registered or at least have provision to teach. And consideration of appropriate experience in the delivery of the curriculum and courses, that you’re going to offer. And non-teaching staff need to have the appropriate working with children clearances.
Likewise, the infrastructure is vitally important to the application process and what we will review. In particular those listed there catering for students with a disability, hazards. The facilities to actually offer an education program. The maximum capacity of the site. And importantly the school must have a 9B permit. We cannot accept an application without the 9B permit.
Charles: Thank you Dean.
So, we’ve heard about the requirements for infrastructure. So, another, just for illustrative purposes again, fictitious scenario, but built upon different applications over the years. In this case study, we’re looking at an instance where it’s a fictional school with a primary school application.
The application is for a school in a bushland setting. So, the elements the school needs to consider in the application and to have demonstrated solutions around, is the fact that there will be new buildings requiring to be constructed. However, at the time of engaging with us, the works have not commenced on that building.
Also, not having a planning permit which has been submitted with the application and they’ve been made aware that through council, a local environmental group intends to lodge an objection to the school with VCAT regarding the construction of the buildings.
The applicant is does not know when the buildings and facilities will achieve compliance with local planning and regulations, and with the Building Code of Australia, the class 9B. Added to this, the applicant is unlikely to be able to obtain registration in time.
Thus, given those elements in play and so the advice to a school that would find itself in that situation would be to talk to the council early. In terms of lessons learned if you’re finding yourself, in anything similar to this dynamic. So, making sure that you’re aware the planning permit and the occupancy certificate, the 9B can take some time. And so, you need to be able to factor that in working backwards from when you’ll be able to get that to support your application.
Also, just for illustrative purposes you can see that in the construction space we’ve seen in recent years that some construction has been impacted by a, I guess, economic situation. So, making sure that if you have further reliance on third parties that you have worked that into your overall application process.
So, in terms of what the school is dealing with for our application, we would say that the planning permit would need to be provided at the time of application and the 9B certificate can be provided later, but it has to be with us before commencement of the school. The school will not be registered without that 9B.
In continuing the scenario, just in terms of what you might need to navigate, the scenario is that the objection was lodged with VCAT from the environmental group. And as a consequence, there’s going to be delays in that building process. So, if the school wanted to proceed, they would need to have an alternate site. So, a plan B scenario.
Also, with respect to the bushland setting, there would need to be some consideration around the need to clear trees in order to have a road. So, the cost of that, you need to consider whether or not you have the finances to be able to work through that process.
There may also be child safety implications around bushland settings, children not being visible or having hazards such as snakes or any kind of local bodies of water, and so that any implication for reasonable adjustments that might need to be made for any students.
So, in a nutshell, that particular example would be a school that would be quite challenged in order to put an application in and meet the deadlines.
Just a couple of scenarios to consider.
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