Written evidence submitted by {a member of the public]


[Note: This evidence has been redacted by the Committee. Text in square brackets has been inserted where text has been redacted.]


Response ID [response ID]


Submitted to Home Education – Call for Evidence and revised DfE guidance

Submitted on [date and time]




1   What is your name?



[member of the public]


2   What is your email address?



[email address]


3   Are you responding as an individual or on behalf of an organisation?




4   If you are responding on behalf of an organisation, what is your organisation?




5   Which of the following best describes the capacity in which you are responding to this consultation?


Choose answer from dropdown list:

Other (please state)


If Other, please give details:

Grandparent of home-educated children


6   Which local authority area are you based in?


Please select:



7   Would you like us to keep your responses confidential?




Reason for confidentiality:

In order to control the potential for harm from those who take a different view on this matter.


Information about home educated children


8   How effective are the current voluntary registration schemes run by some local authorities? What would be the advantages and disadvantages of mandatory registration of children educated at home, with duties on both local authorities and parents in this regard?


Registration - text:

There are already measures, if properly administered, to safeguard children of school age, regardless of how and where the majority of their education takes place and nothing would be achieved by making registration of parents who choose home-education for their children mandatory .


9   What information is needed for registration purposes, and what information is actually gathered by local authorities? Would it help the efficacy of these schemes, and the sharing of information between authorities, if there were a nationally agreed dataset or if data could be shared by national agencies, such as DWP or the NHS?


Data - text:

None, as far as I am aware. I am opposed to mandatory registration as potentially intrusive and open to abuse.


10   Does experience of flexi-schooling and similar arrangements suggest that it would be better if the scope of registration schemes included any children who do not attend a state-funded or registered independent school full-time? If so, do you think that local authorities should be able to confirm with both state-funded and independent schools whether a named child is attending that school full-time?


Other settings - text:

No to both parts of this question.


11   Would the sanction of issuing a school attendance order for parental non-compliance with registration be effective, or is there another sanction which would be more useful?


Sanctions - registration - text:

No. Words such as "non-compliance" and "sanction" are unhelpful in this context.

"Co-operation" and "collaboration" are more likely to lead to a better environment in which children are educated, whether attending a school or not.


12   What steps might help reduce the incidence of schools reportedly pressuring parents to remove children to educate them at home?


Pressure on parents - text:

I have no evidence to be able to support whether this is an accurate report or not.


13   Is there an argument for some provision which allows a child to return to the same school within a specified interval if suitable home education does not prove possible?




Monitoring educational provision made at home or for home-educated children


14   How effective is local authority monitoring of provision made for children educated at home? Which current approaches by local authorities represent best practice?


LA monitoring practice - text:

Arguably this is not the prime responsibility of the local education authority, but rather of the parents.


15   If monitoring of suitability is not always effective, what changes should be made in the powers and duties of local authorities in this regard, and how could they best ensure that monitoring of suitability is proportionate?


Changes: monitoring - text:

See answer to 14 above.


16   Should there be specific duties on parents to comply with local authorities carrying out monitoring if such LA powers and duties were created, and what sanctions should attach to non-compliance?


Monitoring: duties on parents - text:

No / none.


17   Is it necessary to see the child and/or the education setting (whether that is the home or some other place), in order to assess fully the suitability of education, and if so, what level of interaction or observation is required to make this useful in assessing suitability?


Seeing the child - text:

It is not necessary.


18   What can be done to better ensure that the child’s own views on being educated at home, and on the suitability of the education provided, are known to the local authority?


Children's views - text:

In general, children lack the necessary experience in this area to be able to submit views which are relevant.


19   What are the advantages and disadvantages of using settings which are not registered independent or state schools, to supplement home education? How can authorities reliably obtain information on the education provided to individual children whose education ‘otherwise than at school’ includes attendance at such settings as well as, or instead of, education at home?


Other settings - text:

To my knowledge, groups of home-educating parents are in the best place to be able to judge the advantages and disadvantages on any particular settings.


20   What are the advantages and disadvantages of using private tutors to supplement home education? How can authorities best obtain information on the education provided to individual children whose education at home includes private tuition, or whom attend tuition away from home?


Private tutors - text:

As 19.


21   Are there other matters which stakeholders would wish to see taken into account in this area? If so please insert comments below.




Monitoring: other considerations - text:

Local education authorities are already overstretched, without having more duties thrust upon them.


I question their ability to be able to undertake ANY further work in this or in other areas without significant additional resources, which in any case are needed to fulfil their other responsibilities. The potential danger of "playing safe" and/or "fearing the worst" when undertaking the proposed mandatory registration risks alienating parents who are otherwise educating their children in an effective way, and ultimately harming a child's longer-term prospects.


Support for home-educating families


22   What might be done to improve access to public examinations for children educated at home?


Access to examinations - text:

Waiving of some of the fees charged currently.


23   What good practice is there currently in local authority arrangements for supporting home-educating families? Should there be a duty on local authorities to provide advice and support, and if so how should such a duty be framed?


LA support - text:

I am not currently aware of any, but from my past experience as a former governor of a state-run school, I suspect the natural inclination of local authorities is to discourage, or openly resist parents who wish to home-educate. At times, home education is the only alternative in cases where a child has been excluded from school, so much of current practice devolves from similar situations, which are far from the norm for most home-educating parents.


Other matters


24   Should there be a financial consequence for schools if a parent withdraws a child from the school roll to educate at home?




Financial consequences of withdrawal - text:


25   Should there be any changes to the provision in Regulation 8(2) of the Education (Pupil Registration) (England) Regulations 2006 requiring local authority consent to the removal of a child’s name from the roll of a maintained special school if placed there under arrangements made by the local authority?


Children attending special schools: removal from roll - text:



27 What data are currently available on the numbers of children being educated at home in your local authority area?


Data on numbers of home educated children - text:

Not aware of any.


26 Are there any other comments you wish to make relating to the effectiveness of current arrangements for elective home education and potential changes?


Other comments on effectiveness of current arrangements - text:

LAs already have adequate powers which should be properly exercised, provided they obtain clear evidence that education, whether undertaken at home or in another setting, is not being delivered adequately.


28   Do you have any comments on any of the contents of the call for evidence document in relation to equality issues?


Equality issues - Call for Evidence - text:

My concern here is only in respect of children whose parents choose to educate them at home, but this would include any tendency to impinge on their rights by other matters, such as equality issues.


Draft revised DfE guidance on home education: for local authorities


29   Comments on Section 1: What is elective home education?


What is elective home education?:

Not seen.


30   Comments on Section 2: Reasons for elective home education - why do parents choose to provide it?


Parents' reasons:

Not seen.


31   Comments on Section 3: The starting point for local authorities


The Starting Point:

Not seen.


32   Comments on Section 4: How do local authorities know that a child is being educated at home?


Local authority knowledge:

Not seen.


33   Comments on Section 5: Local authorities’ responsibilities for children who are, or appear to be, educated at home


LA responsibilities:

Not seen.


34   Comments on Section 6: What should local authorities do when it is not clear that home education is suitable?


LA action when not clear if home education is suitable:

Not seen.


35   Comments on Section 7: Safeguarding: the interface with home education



Not seen.


36   Comments on Section 8: Home-educated children with special educational needs (SEN)



Not seen.


37   Comments on Section 9: What do the s.7 requirements mean?


S.7 requirements:

Not seen.


38   Comments on Section 10: Further information


Other matters:

Not seen.


Draft revised DfE guidance on home education: for parents


39   Comments on Section 1: What is elective home education (EHE)?


What is elective home education?:



40   Comments on Section 2: What is the legal position of parents who wish to home educate children?


Legal position of parents:

In defining a full-time education, should this not be corrected to state "5 Hours tuition a day for 190 days a year" (not a week). Sections 2.10 (b) & (d) refer to standards which are ill-defined, unlike eg 'literacy' and 'numeracy' in (c).

41   Comments on Section 3: So what do I need to think about before deciding to educate my child at home?


So what do I need to think about?:



42   Comments on Section 4: If I choose to educate my child at home, what must I do before I start?


What must I do before I start?:

The lack of any legal requirement to inform LA if a child has never been enrolled at a school should remain, although parents of such children should be better informed of support services available through the LA.


43   Comments on Section 5: What are the responsibilities of your local authority?


LA responsibilities:

While I support the general thrust of 5.19, that there should be "a willingness to co-operate so as to secure the proper education of your child should be shown by everyone involved", there must be no undermining on the part of bodies such as the LA and Ofsted of the principle under English law that parents are responsible for a child's education, whether by regular attendance at school or otherwise.


44   Comments on Section 6: Further information


Further information:



Draft guidance documents: equality issues


45   Do you think that anything in the revised guidance documents could have a disproportionate impact, positive or negative, on those with 'relevant protected characteristics' (including disability, gender, race and religion or belief) - and if so, how?


Equality - guidance documents: text:



November 2020