This is the first article in a three part series on Registration 'Pain Points' for Schools. You can access part 2 here and part 3 here.
As a school leader and a school director, I have been personally involved in many re-registration audits. They were usually time consuming, hard work and, generally, quite stressful for all involved. Why? Because, generally speaking, in the years leading up to the re-registration audit, the school had not worked towards ongoing compliance. We had done the opposite of what we sought to train our students to do in relation to exams and assignments. We had often ‘left everything to the last minute’. We were so busy on a day-to-day basis dealing with the education and safety of our students that sometimes, unless we had a dedicated risk and compliance person on staff, the ongoing compliance was shuffled down the list of pressing jobs.
However, and I think it’s imperative to state this up front, I do not consider school and school governing body accountability to the regulators to be a bad thing. I believe that schools and their governing bodies must be ultimately accountable for the safety of all students and staff and for the standard of education of the children. I also believe that schools should be held accountable for the use of government funds (e.g. per capita), parent fees, compliance (both registration and legislation), enterprise risk management, sound financial management practices, teaching and learning facilities and, above all, for their own culture and their religious or educational ethos.
Therefore, although registration may be a process that schools often face with a sense of dread, it is here to stay and it ensures that schools are held accountable for delivering what they promise to provide to their students and parents.
Each jurisdiction in Australia has its own regulator that manages the registration of all non-government schools in that state or territory. In all states and territories, the relevant Education Acts require non-government schools to be registered or provisionally registered before operating as a school.
The sources of obligation are always the relevant Education Act and Regulations, and these are distilled further via registration standards, manuals, guides or guidelines.
The re-registration process also varies from jurisdiction to jurisdiction. It generally involves some form of a desktop audit of policies and other controls such as WWCC staff lists and teacher registration details and then, in most cases, an onsite visit to tour the school. In Western Australia, for example, the onsite visit includes meeting and interviewing members of the board and the school community.
The registration standards, manuals, guides or guidelines in most states and territories set out the evidence and other requirements of compliance that the regulators expect to sight during a school’s re-registration process.
The regulators also tend to update their requirements either annually or at least every two to three years. This means that schools that go through re-registration and are given a set term of registration (usually up to five years) often find that they are no longer compliant by their next re-registration if they have not kept on top of any new or changed requirements in their jurisdiction’s registration manual since their last re-registration.
This is because, in some schools, their policies often languish in ‘staff information files’ (hard copy or PDF) and basically ‘sit on the shelf’ between re-registration audits. It is almost a situation of complete, pass, accept and forget- until it all comes around again.
This then leads to a mad scramble by schools in what I have heard described as the “re-registration nightmare”. Here are a few ‘quotable quotes’:
Schools that are going through re-registration will also often ask the following questions:
Basically, schools need to understand that the regulators are not toothless. They need to see that you are compliant with the standards as a minimum (and rightly so), or they can:
So, what do schools need to do if they are coming up for re-registration?
Schools should anticipate the above requirements and expectations by proactively implementing internal registration compliance systems that: