The registration requirements for Australian schools can be confusing, time consuming and varied in their extent and their stringency. But the Victorian Registration and Qualifications Authority (VRQA), in what School Governance believes is a national first, has opened up the evidence requirements for registration to public consultation, asking the public, schools and education providers for feedback on the relevance of the evidence schools are required to provide to prove their compliance with the Minimum Standards.

Victorian Registration Changes

As we mentioned in our previous article, new Minimum Standards for the registration of schools were introduced with the commencement of the Education and Training Reform Regulations 2017 (the Regulations). They come into effect on 1 July 2018. A new Standard was introduced (School must be conducted in accordance with the scope of its registration), and substantial updates were made to the Standards for:

• School Governance
• School’s Philosophy
• School must be not-for-profit
• School must have policies, procedures and suitable arrangements in place.

The current Guidelines to the Minimum Standards and other requirements for registration of schools including those offering senior secondary courses, released on 31 July 2017 to reflect the Education and Training Reform Regulations 2017, are expected to be used until the completion of the VRQA's public consultation process to review the evidence requirements for registration.

Quality Education Evidence Review

At the beginning of March 2018, the VRQA released the Quality Education Evidence Review (the Review) to help "review the evidence guides that reduce the burden of compliance and support the provision of a quality education system."

The aims of the Review are to make sure the evidence guides:

• are clear, up-to-date and reflect contemporary practice
• reduce the regulatory burden at a school and provider level, and
• support the provision of quality education.

Schools and other Education Providers have dedicated portals where each Standard can be reviewed and commented upon in terms of evidence requirements. The general public can also give general feedback about any of the evidence requirements.

Comments on the Review will close in May 2018 with revised guidelines to be considered by the VRQA Board in August 2018, and final guidelines released to schools by November 2018, a substantial time lag from the compliance date for registration requirements of 1 July 2018.

State Registration Ripe for Review?

Around Australia, despite nearly every jurisdiction updating their registration system in 2017, only one other State (SA) has opened up registration requirements for public review. In SA, public consultation was sought on the Standards for Registration in 2017.

But the unfortunate pattern of registration across all jurisdictions is that the majority of regulators implementing revised registration requirements have left schools in the dark as to the extent of their obligations, particularly, as outlined in our previous article, with:

• lack of clarification
• lag in the issue of guidance materials, and
• the use of the same concepts with different definitions.

The lag is particularly problematic for schools. It is a regular pattern in all states and territories that the law is changed by Parliament first, but the registration authority takes time to respond and provide guidance materials.

Some might argue that, as we have stated in our previous article, there is a need for a national system of school registration. While the Victorian consultation process occurs, Victorian schools should instead be focused on continuous compliance, particularly since the current Minimum Standards require continuous review and evaluation of registration compliance.

Schools shouldn’t just try to comply once every five years at registration renewal, but should be aiming to continuously comply with their registration requirements. They should develop an integrated approach to compliance, conducting periodic internal reviews which align with, and liaise with, their regulator, to identify compliance gaps and develop a school improvement plan.

It remains to be seen what impact the consultation process will have on the Victorian registration requirements. If a success, other states and territories may follow.