The period of this report has seen a significant contribution by AHISA in responding to the shape and direction of educational policy and practice in Australia and advocating for autonomous leaders, their communities and school students.

The following is not a complete snapshot of the advocacy work undertaken across 2017-1019 but outlines some of the major submissions and participative activities undertaken by AHISA's National Office.

Submissions in 2017

Australian Education Amendment Bill

On 11 May 2017, the Senate referred the Government’s controversial Australian Education Amendment Bill – which made funding provision for Australian schools to 2027 – to the Senate Education and Employment Legislation Committee for inquiry and report. AHISA’s submission to the inquiry gave in principle support to the funding arrangements as outlined in the Bill, noting that they represented greater equity and transparency. The submission also noted that the new arrangements would create some disruption to the financial planning of most independent schools, especially those experiencing a reduction in funding. Our AHISA submission supported the submission of the Independent Schools Council of Australia and in addition expressed concern over the tenor of public debate on schools funding.

AHISA was invited to attend an inquiry hearing at Parliament House and was represented by then National Chair, Karen Spiller OAM and then Board member Sholto Bowen OAM. At the hearing, AHISA offered the following statement:

AHISA welcomes significant increased federal investment in the Australian school education sector over the decade to 2027. We give in-principle support to the new federal schools funding arrangements as outlined in the Australian Education Amendment Bill 2017, recognising that the conditions to be attached to recurrent funding are yet to be determined, as are criteria relating to transition arrangements for schools that will lose funding. We welcome the promise of greater consistency and transparency in the allocation of federal funding under these proposed arrangements, although we recognise that some stand-alone independent school communities will experience hardship as their funding entitlement is reduced. We therefore welcome the government's commitment to consultation over transition arrangements. We also welcome the opportunity for educators to contribute to the review to achieve educational excellence in Australian schools.

AHISA also stated:

Proposals for entirely different criteria for calculating relative need for base recurrent grants are better addressed through a full funding review, not through an inquiry into refinements of the existing model. Non-government schools need certainty and stability for forward planning, and this will best be achieved for 2018 if the amendment bill is passed and the SRS model retained, with the recommendation that a full funding review take place if and when school SES scores are adjusted to reflect the 2016 census data.

2030 Innovation Strategic Plan Issues Paper

AHISA submitted a response to the 2030 Innovation Strategic Plan issues paper in May 2017. The submission questioned the ‘deficit model’ thinking about schools apparent in the issues paper, which adopted wholesale the view that the quality of Australian education was in decline as evidenced by results from NAPLAN, PISA and TIMMS.

AHISA offered a broader spread of indicators of Australia’s education performance drawing on a range of national and international benchmarks, including PISA and IB results.

AHISA also described innovative practices first developed by independent schools and now accepted as elements of a good education, such as careers advisers, school counsellors, pastoral care programs, service learning, internationalism, outdoor education, and wellbeing and positive education programs. The submission also presented examples of current innovative practice in independent schools, including collaboration with tertiary institutions.

AHISA argued that schools should be recognised as dynamic learning communities with entrepreneurial capacity in their own right. Given that it could be demonstrated that schools were ahead of government policy making in forging ‘next practice’, AHISA further recommended the establishment of a National Schools Innovation Fund to support innovation and entrepreneurial effort in schools.

The Australia 2030: Prosperity through Innovation plan was subsequently released in January 2018 by Innovation and Sciences Australia, with education identified as the first ‘imperative’ for action. The plan maintained that the performance of Australia’s school system is declining and offers five recommendations:

1. Strengthen training for pre-service and in-service teachers
2. Better prepare students for post-school science, technology, engineering and mathematics (STEM) occupations
3. Raise student ambition and achievement in literacy and numeracy
4. Review the Vocational Education and Training system
5. Continue and strengthen reforms to the Vocational Education and Training system

Impact of changes to 457 visa arrangements

After surveying members to ascertain the depth and breadth of the impact of changes by the Australian Government to 457 visa arrangements on the employment contracts of some members and on recruitment and retention of staff in members’ schools, AHISA prepared a submission for both the Minister for Education and Training and the Minister for Immigration and Border Protection. The submission presented results of the survey and made three recommendations:

1. Immediate return of key occupations, including ‘School Principal’, ‘Education Managers’, ‘Primary School Teacher’ and ‘Middle School Teacher’ to the medium-term to long-term Skilled Occupations List (SOL) and therefore eligibility for four-year 457 subclass visas

2. In the event that changes to classifications within the short-term and medium-term and long-term occupation lists are not possible for 2017-18, the Government to immediately establish case by case review and exemption procedures for individuals and organisations negatively impacted by these changes.

3. Inclusion of the Independent Schools Council of Australia as a stakeholder for bilateral consultations when SOL arrangements are reviewed.

AHISA worked closely with ISCA to progress the issue, and ISCA supported AHISA’s submission in its own submission.

AHISA continues to make submissions at each review of the Skilled Occupations Lists (SOL).

School to Work Transition

The inquiry into school to work transition was conducted by the House of Representatives Standing Committee on Employment, Education and Training. AHISA’s submission (31 July 2017) discussed the future of the world of work for young Australians and the role of schools in preparing students to participate successfully in this world, with a focus on the inquiry’s interest in how students are supported in post-school transitions.

As with its submission in response to the 2030 Innovation Strategic Plan issues paper, AHISA attempted to offer a more accurate view of Australian schooling than the view promoted by some politicians, media, industry groups and other commentators that Australian schools are ‘failing’. The submission reiterated the recommendation that a National Schools Innovation Fund be established.

At a hearing before the inquiry on 4 September AHISA’s CEO summarised AHISA’s submission:

Our submission to this inquiry discusses the role of schools in preparing students for post-school pathways at a time when we are entering what has often been described as the fourth industrial revolution. Our submission also sought to address what we see as a danger in national education policy discourse, and that is the deficit model of thinking about schools. We argue that schools and expert educators who work within them have the adaptive and entrepreneurial capacity to evolve educational provision for students to meet 21st century demands. We advocate for policies and programs that release and support that development of innovation and entrepreneurial action in schools. The key points of our submission are that the best way to future proof students is a rich and varied school education, or what we term holistic, that is, incorporating strong curricula and co-curricula programs. Secondly, that schools are already adapting to preparing students for a digital future, and the entrepreneurial capacity of schools and their capacity to innovate should be recognised and supported in government policymaking.

Independent Review into Regional, Rural and Remote Education 

This review was instituted by the federal Minister for Education, Senator the Hon Simon Birmingham and is led by Emeritus Professor John Halsey of Flinders University.AHISA’s submission  (28 August 2017), incorporated the results of two surveys: one of members leading day and/or boarding schools in regional and remote areas, and the other of members who lead boarding schools in major cities. Topics addressed in the survey aligned with the key focus areas of the review, including: challenges in provision; curriculum offerings; meeting individual learning needs; post-school transitions; teaching quality; the use of ICT; connecting with community; and fostering entrepreneurialism. As the review discussion paper raised several concerns over boarding as an appropriate solution for education provision, the submission also included a major section on boarding and other residential programs as a legitimate and viable option for the education of students from regional and remote areas. The submission also drew on key learnings and recommendations from AHISA’s 2015 and 2016 submissions to the inquiry into educational opportunities for Aboriginal and Torres Strait Islander students.

The final report of the Independent Review into Regional, Rural and Remote Education was released in April 2018. The report makes 11 recommendations within four priority areas:

1. Establishing a national focus for regional, rural and remote education (through actions such as the formation of a taskforce or the appointment of a Commissioner for Regional, Rural and Remote Education)
2. Leadership, teaching, curriculum and assessment (with attracting and retaining experienced leaders and teachers to be ‘front and centre’ of planning and work ‘to enhance RRR achievements and opportunities’)
3. Improving access to and use of ICT
4. Transitioning into and out of school, such that all young children start school healthy and well prepared and to expand the availability, affordability and accessibility of work experience placements, VET and post-school education opportunities.

Review to Achieve Educational Excellence in Australian Schools (the Gonski 2.0 Review)

AHISA’s CEO Beth Blackwood and Senior Consultant Lyndal Wilson attended a consultation with two members of the Review panel in October 2017 and prepared both a full submission and a summary document for the Review in November 2017. The submission was in two parts: the first addressed the Review Terms of Reference; the second part responded to questions in the Review Issues Paper.

AHISA made two overarching recommendations:

1. That the Review Panel’s deliberations should acknowledge four key understandings:
   • Recognition of teachers’ and school leaders’ professional expertise
   • Recognition that most schools are already operating strategically within a continuous cycle of development or improvement
   • Recognition of the value of school leaders’ autonomy in determining the best strategies at any particular point in time in a school’s cycle of development
   • Recognition that NAPLAN and PISA tests are very narrow measures of the capacities of students and of what schools actually do
2. That the Review Panel considers shaping criteria for the evaluation of any policy measures it recommends in relation to school-based practice, including:
   • If regulated, would this policy support the evolution of Australian education to meet the needs of students in a rapidly changing global environment?
   • If regulated, would this policy support schools to be ‘agile’ organisations with innovative and entrepreneurial capacity, able to respond effectively to rapid social and technological change?
   • If regulated, would this policy support or enhance diversity in educational options for students and their families by supporting diverse educational philosophies and diverse pathways to student ‘success’?

The final report of the Gonski 2.0 Review was released by the Australian Government on 30 April.

Child Safe Organisations

AHISA contributed a response to the Draft National Statement of Principles for Child Safe Organisations (National Principles) released for consultation by the National Children’s Commissioner within the Australian Human Rights Commission. AHISA’s response drew on its five submissions to the Royal Commission into Institutional Responses to Child Sexual Abuse and the member surveys that informed those submissions.

Submissions in 2018

2018-19 Pre-Budget submission

AHISA used the opportunity offered by the pre-Budget submission process to expose Treasury officials to a positive message about Australian schooling generally and independent schools in particular by recommending the establishment of a National Schools Innovation Fund as a means to leverage and develop the entrepreneurial capacity of schools.

 

Draft National Alcohol Strategy 2018-2026

AHISA submitted in support of the consultation draft National Alcohol Strategy 2018-2026 and in particular the establishment of a new Alcohol Reference Group within the National Drug Strategy governance framework.

AHISA argued that, as schools are key to delivering Priority 4 of the Strategy (promoting healthier communities) and for targeting adolescents as an at-risk population, principals are well-positioned to contribute to the work of the Reference Group and to progress the National Alcohol Strategy. We therefore recommended that the National Drug Strategy Committee considers appointing to the Reference Group a nominee of the four national principals’ organisations (Association of Heads of Independent Schools of Australia, Australian Primary Principals Association, Australian Secondary Principals Association and Catholic Secondary Principals Association), both to provide a schools’ perspective to the Reference Group’s deliberations and to create a conduit for the ready dissemination of information through a wide national network of school leaders.

STEM Industry-School Partnerships

AHISA responded to an issues paper published by the STEM Partnerships Forum, which invited comment on optimising STEM industry-school partnerships. The Forum, which was established by the COAG Education Council under the National STEM School Education Strategy 2016-2026, was chaired by Australia’s Chief Scientist, Dr Alan Finkel AO.

The primary purpose of the submission was to counter, once again, the deficit-model thinking about Australian schools that is driving national education policy development. The Forum subscribes to the view that ‘our primary and secondary schools are not equipping our students in STEM subjects as well as in years past’, that student achievement is ‘declining’ and that school funding ‘needs to be better targeted’.

As well as challenging the Forum’s view of Australian schooling, AHISA also addressed several issues raised in the consultation paper: pre-requisites for tertiary STEM courses; introduction of a Unique Student Identifier; and teacher professional development.

Religious Freedom Review (the ‘Ruddock Review)

The Review was announced by the Prime Minister in November 2017 to examine whether Australian law adequately protects the human right to religious freedom in Australia.

In its submission AHISA did not advocate for a specific form of legislation or bill of rights to protect religious freedoms. Instead, AHISA highlighted issues in the operation of schools with a religious affiliation where conflicting rights may need to be taken into account in the framing of any legislated protections by exploring two questions raised by Review panel member, Fr Frank Brennan:

Review of the socio-economic status (SES) score methodology

This review was conducted by the National School Resourcing Board, established as a result of amendments to the Australian Education Act in 2017 to consider the methodology used to determine the capacity of non-government school communities to contribute to the operational costs of their school.

AHISA’s submission supported the submission of the Independent Schools Council of Australia, affirming ISCA’s description of key characteristics of the current SES score methodology and its application to the SES model:

• It is widely accepted by independent schools
• It provides stability in federal funding arrangements
• The administrative burden on schools is manageable
• It encourages private contribution to Australian school education
• It is ‘fit for purpose’.

AHISA acknowledged ISCA’s detailed analysis of Census and schools data to confirm that ‘the fundamentals of the SES methodology remain the most appropriate methodology to determine capacity to contribute’ for the purpose of allocating federal general recurrent grants to non-government schools.

Closing the Gap Refresh

The Closing the Gap Refresh review was a large scale, community-wide consultation being undertaken by the Department of Prime Minister and Cabinet on behalf of the Council of Australian Governments. The aim was to review the national Close the Gap targets to improve the education, health and welfare of Aboriginal and Torres Strait Islanders. 
AHISA’s submission took up a theme stressed by the Prime Minister’s Indigenous Advisory Council at its meeting on 15-16 August 2017 and reiterated in initial community consultations with Aboriginal and Torres Strait Islander peoples undertaken as part of the Refresh review, that it is important to take a strengths-based approach to identifying and bridging the wellbeing and opportunity gaps for Indigenous people and to recognise that Indigenous cultures are ‘integral for thriving communities’.

The submission presented evidence from innovative education partnerships between independent schools and Indigenous communities in support of a strengths-based approach to school education for Indigenous students, underlining the importance of language, culture and identity to the achievement and wellbeing of Indigenous students.

Australian Learning Lecture & Mitchell Institute Forum: Reforming the transition from secondary to tertiary education, 23 May 2018
AHISA participated in a one-day forum organised by Australian Learning Lecture (ALL) and Mitchell Institute. Forum participants were asked to submit a short paper prior to the forum on issues relating to ‘constructive next steps which could be taken to provide a better pathway for students in senior secondary through to tertiary education and work’ and how any suggestions might address problems raised.

AHISA described some of the conflicting views prevailing in this space, the work already underway in schools and the regulatory environment that constrains that work.

AITSL TEMAG Forum: School-university partnerships and initial teacher education

AHISA participated in a forum organised by AITSL (26 June 2018) as part of consultations to progress recommendations arising from the 2014 Teacher Education Ministerial Advisory Group (TEMAG) report.

AHISA repeated its call for a federally funded national mentoring program to provide training for teachers as mentors of ITE students, graduate teachers and experienced teachers.

Senate Environment and Communications Reference Committee inquiry: Gaming micro-transactions for chance-based items

AHISA’s submission (27 July 2018) focused on the risk of harm to young people from simulated gambling games and elements within digital games that are akin to gambling. 
The submission referred to the growing evidence base on the engagement of children and young people in Australia in gambling activity via digital games and noted a range of concerns and risks associated with this exposure.

AHISA argued that the scale of exposure of Australian children to simulated gambling games and within-game gambling represented by 'loot boxes' and other chance-based micro-transactions signals the need for a special focus on children and young people as a sub-set of Australia's gambling population.

Minister for Foreign Affairs and Minister for Education and Training: Joint submission with Australian Boarding Schools Association regarding PNG students at Australian boarding schools

In an address to the Lowy Institute in Sydney (18 June 2018), PNG’s Deputy Prime Minister and Treasurer, the Hon Charles Abel, called for closer ties between the Australian and PNG education systems, including providing for between 500 and 1000 places in Australian boarding schools each year for high achieving PNG students from Year 9. 
The AHISA-ABSA submission (30 July 2018) recommended that should the Australian Government consider accepting and progressing PNG’s proposal, an important first step would be to create an advisory group to inform the development of a program that achieved Australian and PNG national objectives and which also met the needs of PNG students and Australian schools.

AHISA and ABSA offered to consult with Government officials to assist in the scoping of a program of boarding scholarships for PNG students and/or teacher exchanges.

Senate Legal and Constitutional Affairs References Committee: Inquiry into legislative exemptions that allow faith-based educational institutions to discriminate against students, teachers and staff

The inquiry was called following leaking of and misreporting of elements in the report of the Religious Freedom Review (the ‘Ruddock Review’), which caused community concern over the right of schools with a religious affiliation to discriminate against LGBTIQ students, teachers and staff for religious reasons. 
AHISA’s submission raised some concerns with the Ruddock Review recommendations, as leaked, and called for any amendments to employment and anti-discrimination laws to be properly considered and thoroughly tested for their impact on the management of all schools – government and non-government, with and without a religious affiliation, single sex and co-educational – prior to their adoption. AHISA’s CEO appeared by teleconference in a public hearing held by the References Committee in Melbourne. 

The Australian Law Reform Commission is currently considering recommendations arising from the Review of Religious Freedom.

 

House of Representatives Standing Committee on Employment, Education and Training: Status of the teaching profession

AHISA’s submission (20 December 2018)  brought to the Committee’s attention issues affecting the status of the teaching profession but which are not widely canvassed in the media, including:

• The importance of recognising teachers’ professional expertise to balance and help repair the negative narrative that has dominated public discourse on school education in Australia over the last decade, and to support teacher recruitment strategies.
• The need for government policy making and programs to focus on strengthening the teaching profession in Australia.
• The imbalances in teacher supply and demand and the need for Australia to prepare for engagement in a war for teaching talent with nations whose teaching training systems are similar to our own.
• The need for new approaches to teacher professional development.
• The challenge of adapting schooling provision and teacher professional development to meet the growing demand by teachers for flexible working arrangements.

Submissions in 2019

Senate Legal and Constitutional Affairs Legislation Committee: Inquiry into Sex Discrimination Amendment (Removing Discrimination Against Students) Bill 2018

The inquiry (18 January 2019) covered the Private Member’s Bill introduced into the Senate by Senator Penny Wong and the subsequent amendments moved by the Government to clarify impacts on schools and other religious institutions in regard to their freedom to teach the tenets of faith of the religion adhered to and who would be eligible to impact that teaching within those institutions. 

AHISA expressed concern that the ambiguity of the Bill in the form as presented by Senator Wong could create unnecessary conflict in school communities and initiate costly litigation to ‘test’ interpretation of the law. To ensure that legislation is framed with a view to its full impacts and free from media misinformation or political game play, and in light of the failure of the major parties in the Australian Parliament to reach consensus on legislative solutions to the issue of how the Sex Discrimination Act can best be amended to protect both the rights of students and religious freedoms, AHISA expressed support for the Australian Government’s intention to refer the issue to the Australian Law Reform Commission for independent and expert drafting.

Expert Review of Australia’s VET System

AHISA’s submission (25 January 2019) was informed by responses to a survey of members on VET provision in schools.

The submission demonstrated that while schools enthusiastically pursue VET pathways to meet the diverse needs of students, VET provision in schools is under stress, with significant resourcing and staffing issues made more complex by an extreme compliance burden affecting RTO certification and obtaining and maintaining qualifications of teaching staff.

The submission outlined a number of ways in which governments, industry groups, employers and external VET providers can support schools if they are to continue to deliver excellent outcomes for students and meet public policy goals. It also argued that governments must exercise caution before introducing major system interventions that cannot be sustained beyond a change in government.

The Australian Government accepted many of the recommendations of the Review. Initiatives funded in the 2019 federal Budget just prior to the announcement of the federal election included: establishment of: a National Careers Institute and a National Careers Ambassador; a National Skills Commission; a competitive grants program aimed at building innovative partnerships between schools, employers and the VET sector; and 10 Training Hubs in regions with high youth unemployment to create better linkages between schools and local industry.

NAPLAN Reporting Review, COAG Education Council, 14 March 2019

The Review was conducted by the ACT Government on behalf of the Education Council of the Council of Australian Governments. Led by Emeritus Professor Bill Louden AM, the Review examined the current approach to presentation of NAPLAN data, including its publication on the My School website.

To inform its submission to the Review, AHISA conducted a brief survey of members, with questions addressing the four key themes of the Review:

1. Perceptions of NAPLAN and My School data, including the potential for misinterpretation or misuse of data
2. How My School and NAPLAN reporting contribute to understanding of student progress and achievement
3. How schools use achievement data, including NAPLAN, to inform teaching
4. How My School and NAPLAN data are reported to students and parents.

The survey results revealed a wide spread of opinion among members in regard to NAPLAN, the validity and usefulness of its data and the manner of its reporting on My School. Location, school size and the community served by the school – as well as the educational philosophy of the Head – were major factors influencing responses to the survey. AHISA’s CEO was also directly consulted by Professor Louden in a private meeting in Perth.

Review of the Melbourne Declaration on Educational Goals for Young Australians

Conducted under the auspices of the Education, the Review (14 June 2019) aimed to refresh the national goals for schooling, last agreed in 2008. The Review entailed extensive consultations with education authorities, educators, parents and carers and students, as well as a submission process. 

AHISA’s submission took into account a submission prepared by AHISA NSW in conjunction with the Association of Independent Schools of NSW. Main points in AHISA’s submission included:

• While a refreshment of the goals may refer to early childhood learning and transitions from school to further learning and work, their focus should remain on K-12 education.
• The evolution and recalibration of Australian schooling in response to rapid social and technological change is already underway – in large part initiated by educators themselves, yet still occurring within the parameters set by the 2008 National Goals. Given the likelihood of continued and accelerated disruption in the sector through ongoing technological development, including the application of artificial intelligence, AHISA cautioned against trying to capture the evolution of schooling at one moment in time in either the goals or the areas of commitment to action. The goals and focus areas should define the foci of national effort in school education but not be so prescriptive as to discount the professional expertise of educators.
• The national goals as they stand have proven to be sufficiently high level to support a common platform for educational endeavour and at the same time allow room for experimentation and innovation and diversity in models of provision – not only at state system level but importantly also at school level. AHISA suggested that the goals could be strengthened by an explicit reference to what that nation expects of its schools as institutions and communities.

 

AHISA’s submission also explored the proposition that rather than new national goals for schooling, Australia will be better served by a new approach to national education policy making. The resultant Alice Springs (Mparntwe) Education Declaration was endorsed by Education Council in December 2019.

Inquiry into Family Assistance Legislation Amendment (Extend Family Assistance to ABSTUDY Secondary School Boarding Students Aged 16 and Over) Bill 2019

In conjunction with the Australian Boarding Schools Association (ABSA) wrote to the Senate Standing Committees on Community Affairs’ Legislation Committee in support of enactment of the Family Assistance Legislation Amendment Bill.

The submission drew on research undertaken by AHISA for the Inquiry into Educational Opportunities for Aboriginal and Torres Strait Islander Students, which showed that schools engage in a wide of range of strategies to engage and support Indigenous students. The submission argued that the breadth of strategies used indicates that extending the eligibility of families of Abstudy students to receive the Family Tax Benefit until their children complete Year 12 will not represent a ‘quick fix’ to promote retention but will, however, remove what amounts to a financial disincentive from the complex mix of pressures that influence students’ decision making on whether to complete their schooling.

Other submissions to the inquiry pointed out that Abstudy arrangements were not sufficient to cover the cost of boarding and called for a review of the program.

Religious Discrimination Bill 2019 

At the end of August 2019, the Australian Attorney-General, the Hon Christian Porter, released for community consultation three draft bills tagged as a protection for religious freedom in Australia. AHISA submitted on the main bill, the Religious Discrimination Bill; two other bills contained amendments to other legislation that would be necessitated by passage of the Religious Discrimination Bill. 

After consultation with Ben Tallboys of Russell Kennedy Lawyers, AHISA focused on ambiguity in aspects of the Bill that created uncertainty for independent schools in terms of policy and practice and which, by the nature of their uncertainty, could lead to expensive litigation and court interpretation of what is considered religious practice. 

AHISA’s submission contained three recommendations:

• That there be greater consistency in terminology across federal anti-discrimination laws to avoid uncertainty around potential differences in intent of the laws and their application, and therefore uncertainty as to the freedom of religious bodies to maintain and express their religious ethos
That the exposure Bill be amended to exempt all non-government schools from the presumption in Part 2, Section 8 of the exposure Bill [relating to provisions for organisations with revenue $50 million or more], irrespective of the school’s size or turnover
• That the definition of ‘statement of belief’ in Part 1, Section 5 of the exposure Bill be amended to apply only to a belief that ‘is in accordance with the doctrines, tenets, beliefs or teachings’ of the religion of the person expressing the statement.