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Freedom for Children to Grow

The Law Relating to
Home Education


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Notes on DWP Consultation Questions

More information can be found here.

You do NOT have to answer the consultation questions. If you prefer you can just write or email feedback about any of the proposals to welfare.reform@dwp.gsi.gov.uk:

Green Paper Consultation Team
Department for Work and Pensions
Level 2, The Adelphi
1-11 John Adam Street
London WC2N 6HT
It is a judgement call how much to play up the "no choice except to home ed because of bullying, lack of provision for SEN/disability" etc. To some extent we may be operating within taxpayers' perception that home education is a "lifestyle choice" and it may not be strategic to give further ammunition on this. This is my personal opinion (Fiona).

Here are links to several consultation responses from other organisations to give you an idea of what is being said elsewhere. The points which are repeated over and over are that compulsion does not work, that there needs to be adequate childcare which parents are happy to use, plus more suitable local part time work (cost and time of travel to work) to fit with the responsibilities of caring for children, and also that lone parents are often caring for children with disabilities:

London Councils

Wirral Council

Radar, the Disability Network. Press Release.

Child Poverty Action Group Press Release
"Forcing lone parents to face benefit sanctions when their children are still at primary schools is outrageous. Taking money away from families that are already poor will worsen poverty for many children and put their health and wellbeing at risk."

Page of links from Child Poverty Action Group

Cost/Benefit Analysis From DWP Is Flawed

General Points

The Department of Work and Pensions has produced an Impact Assessment for this consultation. Pages 6-7 are particularly relevant for us:

Several points to note about DWP cost/benefit analysis :

  • The figures do NOT include the cost of implementing the scheme !

  • The figures are optimistic guesswork ( or as the DWP says "very initial" )

  • The figures do NOT include any costings for Government spending on childcare, which rather skews the cost/benefit analysis.

  • Lack of costings for childcare in the cost/benefit analysis is particularly relevant when childcare costs would be HIGH eg for anti-social hours or for child with SEN/disability or when childcare might be provided on a one to one basis in the child's home as proposed by Minister Caroline Flint in the webchat on October 15th.

  • For some reason, the figures also do NOT include any guesstimate for the childcare element of Working Tax Credit.

  • The DWP guesses that it would cost £50 million over 3 years to assist lone parents into work.

  • The DWP guesses that since a high proportion of new JSA claimants would find work, the Government might save between £50 million and £300 million because benefits would no longer need to be paid and also new earners would be paying Income Tax and National Insurance. DWP does however concede that tax credits will have to be paid. This is clearly a vast under-estimate of both the immediate and sustained earning capacities of lone parent JSA claimants. It also underestimates the financial burden of personally tailored back to work support systems, compared with the automated unconditional payment of Income Support.

  • The Department of Work and Pensions states in the Impact Assessment that it is aware that it needs more information from stakeholders about the cost of the various proposals. This is where we need to tell them their sums are wrong.

  • One of the most effective argument against the Government proposals may be the economic one. There is some useful background material on this in the One Parent Families Response to the Freud Report April 2007

  • While there is no legal minimum age for a child to be left at home alone, the NSPCC and the Children's Legal Centre consider that children younger than 13 should not generally be left alone for long periods of time.

  • One size does not fit all and a family's individual circumstances need to be taken into account.

  • The Government has set a target of 70% employment rate for lone parents across the board. This means getting a much higher percentage of lone parents into paid work when their children are much younger than 12 as well as driving up the employment rate closer to 80% for lone parents whose children are over 12.

  • The arguments for this targeting of lone parent families are that "children are lifted out of poverty" and that "people who have been out of the job market for some time find it increasingly hard either to enter or to return, so breaks from paid work should be shortened wherever possible. "( The same arguments are being used to target people who receive Incapacity Benefit. )

  • The following "paid work" percentages are from the Government's Impact Assessment

    43% of lone parents with children under 7 are in paid work.
    60% of lone parents with children between 7 and 11 are in paid work.
    70% of lone parents with children over aged 12 are already in paid work.
    A quarter of lone parents who remain on Income Support after their child is 12 have a child with disabilities, which could severely restrict the lone parent's availability for paid work.

Specific Points About The Cost Of Home Education

  • As far as home education is concerned, the cost to the Government of keeping a child in school is around 5,000 a year.
  • Some of the lone parents who remain on Income Support after their child is 12 are those who have taken full responsibility for their children's education by educating their children at home.
  • There are a number of reasons why lone parents home educate. Some children are withdrawn from school on health grounds following severe bullying. Other children are educated at home because state provision for their SEN and disability is wholly inadequate.

The DWP Consultation Questions and Comments

Question 1:
At the moment, lone parents are entitled to Income Support until their youngest child is 16. Is it right that this age should be reduced?

COMMENTS
The Government is proposing to reduce this to age 12 in 2008 and further to age 7 in 2010. 2 basic options with this question: either  you make the blanket statement "No, it isn't right that this age should be reduced/children need a parent at home / what about the emotional well-being of teenagers / many parents say that children need MORE support during teenage years, not less " or  you say effectively that some lone parents are more "entitled" than others eg if they have caring responsibilities or if they home educate. See also the quote from One Parent Families Organisation in QUESTION 5

Question 2:
What would the minimum age be?

COMMENTS
The answer to this would depend on the tack you have taken already with Question 1 as to whether you think there SHOULD be a minimum age below 16 in any circumstances . The arguments to support your case for Question 1 can be repeated and expanded for Question 2, including giving personal examples to make the point more forcefully. See also the quote from One Parent Families Organisation in QUESTION 5

Question 3:
Should we do more to ensure that our support for lone parents is accessible and useful for all groups, in particular those with disabled children and those from certain disadvantaged groups and areas?

COMMENTS
What is meant here by "support" ? Are parents asking for support in entering the job market, do they require support to be able to carry out their caring responsibilities, or are they saying that they just want to be left alone to do their job of raising and educating their children ? See also the quote from One Parent Families Organisation in QUESTION 5

Question 4:
More frequent Work Focused Interviews are currently offered to lone parents in the two years before their eligibility to Income Support is lost. As the age of the youngest child is reduced, should other forms of support be provided, and over what period prior to loss of eligibility?

COMMENTS
Attendance at work focused interviews every 3 months is ALREADY mandatory in the 2 years preceding loss of eligibility to Income Support (currently when child is 16) The wording of the question says that the interviews are "offered" and yet if claimants do not take up the interview offer then benefits are cut. Work focused interviews are "offered" in the same way for lone parents of younger children on an annual basis. Some people might want to say that these annual work focused interviews could be extended to lone parents of younger children, but NOT that the interviews would be mandatory.

Question 5:
For lone parents who move onto Jobseeker's Allowance when they lose Income Support eligibility, what forms of support (in addition to those provided to Jobseeker's Allowance claimants who are not lone parents) should be available, and over what timescale?

COMMENTS
Exceptions must be made to the JSA regime for JSA claimants with extra caring responsibilities in the form of home educating their children and/or if their children are disabled or have Special Educational Needs

THIS IS WHAT ONE PARENT FAMILIES SAYS ABOUT JSA :

The most substantial of these [ conditions for JSA ] is the requirement that Jobseekers be available for work of at least 16 hours. Lone parents who cannot find childcare, particularly the third of lone parents with children in this age group who are caring for a disabled child, may find it impossible to fulfil this requirement.

Exemptions from the requirement to be available for work would have to be put in place for this group. Lisa Harker's report to the department on tackling child poverty recommended that any extension of conditionality to lone parents, such as proposed here, should be dependent on the existence of sufficient childcare. Further concerns arise about the ability of lone parents to fulfil the requirements of the 'intensive activity' or 'options' periods of the New Deals which they would, presumably, be mandated to join after the requisite period on benefit.

Many of the training courses offered under these schemes have not been designed with the needs of those with caring responsibilities in mind.

The sanctions regime for Jobseeker's Allowance is considerably tougher than that for Income Support, with failure to attend an interview at the Jobcentre capable of producing a total stop to benefit.

Were lone parents to be subject to this aspect of the regime the impacts on their children's welfare during a period of sanctioning are likely to be highly negative." Reference

Question 6:
Jobseeker's Allowance recipients can, in certain circumstances, restrict their search for work to a minimum of 16 hours per week. Should additional flexibilities be available if the proposed changes are made?

COMMENTS
It is a judgement call here and elsewhere in the consultation response as to whether people play up the "no choice because of bad schools/bullying/SEN" angle on home education. There may be more strategic advantage to this than in playing up the "lifestyle choice" aspect.

Lone parents who home educate and parents who home educate disabled children will require extra dispensation from the JobCentre and from specialist back-to-work provision and an understanding that the claimant will not be available for the minimum 16 hours which is being proposed for parents whose children are in school. The DWP needs to issue guidance on this matter. See COMMENTS to question 5 about JSA from One Parent Families Organisation.

Question 7:
What form might a 'better off in work' assurance for lone parents take?

COMMENTS
JobCentre statistics focus on unsustainable jobs, with claimants moving off benefit to short term jobs and then returning to JSA. At present this is counted as a New Deal success in getting lone parents "back to work". This does NOT mean that lone parent families are "better off". One Parent Families has more information about this. Parents who home educate will argue that their children are better off by being home educated.

Question 8:
Are any special provisions required for lone parents who move onto benefits other than Jobseeker's Allowance (for example, Employment and Support Allowance or Carer's Allowance)?

COMMENTS
See responses from other organisations, particularly with regard to the conversion of of Incapacity Benefit to Employment and Support Allowance.

Here is a link about Carer's Allowance.

and Employment and Support Allowance (ESA)

There are additional points to be made about lone parents who home educate and who receive Employment and Support Allowance. In many cases this will bring an obligation to be actively seeking work, which is not compatible with home education and caring responsibilities. There is a problem with Carer's Allowance in that a successful claim has to be made for Disability Living Allowance and this is increasingly difficult. The forms are very detailed and off-putting and many claimants don't have anyone who can help them with the forms and with subsequent appeals if the claim is rejected.

Question 9:
In addition to the improvements in childcare provision and the right to request flexible working, is there further support that should be provided to help lone parents into work and support them whilst there?

COMMENTS
Lone parents who educate their children at home have additional caring responsibilities and should be exempt from the elements of compulsion associated with the full JSA regime. JSA will have to be modified and personalised to take these special circumstances into account. See also the quote from One Parent Families Organisation about JSA in QUESTION 5

Question 10:
What more could we do to help working families - especially those from the most disadvantaged backgrounds - improve their earnings and lift themselves out of poverty?

COMMENTS
Half the families in poverty have at least one member working, so the Government would have to address questions of the minimum wage and better pay and conditions for part time workers with family and extra caring responsibilties.

Question 11:
What more could we do to help ethnic minority women, particularly of Pakistani and Bangladeshi origin, overcome specific barriers they face?

Question 12:
In exchange for more specialist support, are we right to ask more of those who have been unemployed and receiving benefit the longest?

COMMENTS
No. Home educating parents will have additional caring responsibilities and should not be penalised for these.

Question 13:
Should there be any exceptions to this approach of increased conditionality and increased support?

COMMENTS
Yes, parents who home educate their children must be an exception. See also the quote from One Parent Families Organisation in QUESTION 5

Question 14:
Is a structured, progressive regime of support and conditionality at fixed intervals the right approach?

COMMENTS
No. Any system must be far more flexible and tailored to meet the individual. Lone parents who home educate will require conditionality terms to be deferred or waived if the Government goes ahead with proposals to move all lone parents on to JSA. See also the quote from One Parent Families Organisation in QUESTION 5

Question 15:
Should some people be enabled or required to enter the Gateway stage more quickly than others, taking account of their employment history or needs? Which groups should be 'fast-tracked'?

Question 16:
Should we require a period of work experience from those who do not succeed in getting work after benefiting from a more intensive level of help from specialist providers? How can we best ensure that this work experience is beneficial?

COMMENTS
Lone parents who home educate will not be available for work experience in the same way as parents whose children are in school. See also the quote from One Parent Families Organisation in QUESTION 5


Food for Thought:
Home Education for Teenagers

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