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My select committee submission on Communities of Online Learning (COOLs)

online-educationSubmission from Dianne Khan, Save Our Schools NZ (SOSNZ)  to the Education Select Committee regarding the Education (Update) Amendment Bill Part 3, Communities of Online Learning



The Education Minister must fully consider the COOLs proposal before proceeding, must have clear evidence to support her assertion that COOLs would be a positive addition to the NZ education system, and have a comprehensive outline of how COOLs will run before the proposal is adopted.

In particular, the Minister must ensure that:

  • there is clear evidence that COOLs are likely to be effective in promoting student achievement.
  • all relevant stakeholders are properly consulted.
  • COOLS will be mentally and physically safe for students.
  • the full financial analysis of the COOLs proposal is understood, including an evaluation of the impact they are likely to have on other areas of the education system.
  • there is clarity around expectations upon students’ whanau.
  • the blurred line between COOLs and homeschooling (in particular around funding) is addressed.
  • the criteria by which COOLs are evaluated is honest, fair for all parties and transparent.
  • a comprehensive plan is outlined before the proposal is signed into law.

I will now look at those points in more detail.


I am concerned is the lack of consultation regarding communities of online learning (COOLs). Although Ministry has discussed the proposals with Te Kura, there has been little or no wider consultation. I recognise that Te Kura has a level of expertise about online learning, and it is encouraging that they were consulted, however – given the huge shift this proposal puts forward – it is essential that far wider consultation is engaged in. It is critical proposals are discussed with current heavy users of online learning such as Regional Health Schools and the homeschooling community as an absolute bare minimum, and prudent to involve educators, mental health workers, and overseas experts, too.


If COOLs are to continue in any form, it is imperative proper due diligence is first undertaken. It is unclear to what degree this has taken place already, but key stakeholders report that they have not been consulted and have had no input into the COOLs proposal. Therefore, I ask the Select Committee to request that the Ministry of Education release its research and findings regarding online school systems so that it can be scrutinised. Before embarking on a policy that has had such incredibly poor results elsewhere, we must be confident full consideration has been given to all aspects of the proposal.  


The plan for COOLs is at a very early stage and not yet outlined in nearly enough detail or consulted widely enough on for anyone to be sure they would provide good quality education in New Zealand.

In 2015 findings into the USA’s online schools were released by three renowned independent research institutions, Stanford University’s Centre for Research on Educational Outcomes (CREDO), the Centre on Reinventing Public Education (CRPE), and Mathematica Policy Research. These reports concluded that online schools were largely failing students and that the issues surrounding online learning are very serious.

Referring to numeracy and literacy, the CREDO report noted that

“students of online charter schools had significantly weaker academic performance in math and reading, compared with their counterparts in conventional schools,”  


“While findings vary for each student, the results in CREDO’s report show that the majority of online charter students had far weaker academic growth in both math and reading compared to their traditional public school peers. To conceptualize this shortfall, it would equate to a student losing 72 days of learning in reading and 180 days of learning in math, based on a 180-day school year.”

Before offering New Zealand students this model, it is essential that the reasons for those huge shortfalls are investigated thoroughly, in all their complexity, so that safeguards are put in to prevent similar poor quality outcomes for our students.


The Education (Update) Amendment Bill states that “The Minister may set conditions on the provisional accreditation of communities of online learning, including conditions that… specify the outcomes for student achievement that must be met”. However, words are cheap, and it is of little assurance to see this clause given the Minister’s failure to act when charter schools have failed to meet similar outlined conditions. Therefore, I urge the Committee to investigate in detail what such conditions would be (for all age groups and  cohorts), how exactly they would be monitored and how failure to meet the conditions would be addressed.


A particular concern is the relationship in NZ between education outcomes and ethnicity/socioeconomic status/mental health. It is worth noting, then, that CREDO’s research deems online schools to have failed to address these issues for US students, stating that the “pattern of weaker [student learning] growth remained consistent across racial-ethnic subpopulations and students in poverty.” This should raise huge red flags for NZ. Therefore, the must be an impact analysis addressing COOLs and vulnerable groups such as those mentioned above. It would be unforgivable to risk undermining further the education of those already deemed to be at risk of underachievement.


Making ‘Overall Teacher Judgements’ (OTJs) on a student’s skills, knowledge and abilities is a complex task that involves frequent observations, discussions with the student, in-class tests (both formal and informal), and analysis of work undertaken. How will COOLs ensure they get a true picture of a student’s abilities? I fear that OTJs might be pushed to the side in favour of using online test results. It would be a grave error to move towards trusting tests alone to give a fair picture of what a student knows/can do. No test is extensive enough to provide a true evaluation.

I also urge the Committee to seriously question any move to use National Standards as a valid measure of any student’s progress, given their unreliability and the fact that the Standards have not yet been benchmarked in any meaningful way.


Regarding “the capacity to meet its pastoral care and student well-being responsibilities” (Education (Update) Amendment Bill, 35T Provisional accreditation of communities of online learning (3) (c)), I am concerned that there is no specific detail on how a COOLs shall properly identify and meet students’ pastoral needs remotely.

There are two main issues. The first is that those students who can identify their own issues will nevertheless not feel able to bring them to the attention of their teacher/s, as students are less likely to share concerns with someone they do not have a bond with. The second issue is with those students who cannot identify when they have a need that should be addressed. In these circumstances, virtual teacher will be less likely than a physically present teacher to notice the problem and address it with a student. Both situations are problematic.

If the student has a very supportive home environment, the impact is likely to be smaller, but those without a whanau safety net will suffer a double blow regarding the lack of adult support – absent teacher support and absent family support. This is likely to impact our neediest students the most and could be disastrous for them.


I am concerned that students’ safety needs may not be met adequately by COOLs.

The proposal states at 35T Provisional accreditation of communities of online learning (3) (a) that

“For a body to be provisionally accredited as a community of online learning, it must have or be likely to have … a learning environment and processes that are safe and secure for its students”

but there is no detail regarding what this would look like. Student safety covers many very important things in any educational environment, including online, mental health and physical safety and can be difficult to monitor even when teachers and support staff are physically present.

Before launching any online school, there must be explicit investigation into the potential safety pitfalls of the model and stringent safety criteria must be drawn up, especially regarding mental health.


I am concerned that 100% online learning could lead to unhealthy habits such as disrupted work hours, poor posture, sedentary behaviour, increased solitariness, skipping meals and increased screen time, all of which are health warning triggers.

Safe computer use is a known concern, and ACC have a one hundred page booklet about that issue alone. How would safe use be monitored and good practices successfully promoted to ensure good physical health?

More worrying still is the potential for bad practice to lead to and/or exacerbate mental health problems. New Zealand has significant number of children with mental health issues, with high levels of self-harm and suicide. The Ministry of Health reported that “The highest rate of suicide in 2012 was in the youth age group (15–24 years)” and “the highest rate of intentional self-harm hospitalisations for both males and females was in the 15–19 years age group”. I would suggest Ministry work with experts such as those in Regional Health Schools, the Mental Health Foundation, Child and Adolescent Mental Health Service (CAMHS) in Wellington and Kapiti, Whirinaki Child, Family and Youth Mental Health in Manakau, The Werry Centre at the University of Auckland etc. in order to properly identify the possible pitfalls and set down for COOLs preventative and remedial measures.

It is imperative that student safety is paramount, and the goal must be comprehensive and stringent guidelines covering a COOL’s responsibilities regarding students’ physical and mental health.


Online school principals in the USA identify ‘maintaining student engagement’ in this environment of limited student-teacher interaction as their greatest challenge by far.

So we must ask, how will students be kept on-task? Will COOLs be open only to those deemed able to self-manage their learning? And if so, is this in keeping with requirements for inclusive school practices?

I have seen first hand students’ diverse needs regarding teacher input during my work Central Regional Health School (CRHS) and at a number of primary schools. Even at senior school, it is a minority of students that are independent enough to be capable of identifying and addressing their own learning needs. Most school students need significant teacher input as they still have a limited ability to recognise their needs and ask for help. In those cases, a high level of supervision is needed while independent learning skills are taught and the student learns to self-manage. How will this be managed well in an online setting?

I fear there is a very real danger that some students would slip under the radar, especially if teacher/Student time is limited. Mathematica reported that online schools typically provide students with less live teacher contact time in a week than students in conventional schools have in a day. What levels of teacher/student interaction would be needed to ensure adequate support, and how would that be mandated and checked?


Another important issue is that of parent support. The Update states that “a system for ensuring that information about a student’s performance is given to the student’s parents in a timely manner and in a form that is readily understandable” which implies parents will not be an active participant in their child’s learning. This raises huge issues. Mathematica reported that online schools place significant expectations on whanau as teacher “perhaps to compensate for limited student-teacher interaction”. The level of parent support in US online schools is significant: “43, 56, and 78 percent of online charters at the high school, middle, and elementary grade levels, respectively, [are] expecting parents to actively participate in student instruction”. This is a huge family commitment, yet it has not been addressed in the COOLs proposal.


It is not yet clear what will technically differentiate between a student who is being homeschooled and one that is at an online school. Is it age? Levels of parent involvement? Or something else? And if it is linked to levels of parent involvement, how will it be evaluated and monitored? This is especially thorny given the high levels of parent support likely to be needed in a student’s daily ‘school’ life, as outlined above.

It is also unclear how funding for COOLs will impact payments to homeschoolers. Clarity is desperately needed.


The research into the USA’s online schools gives significant cause for concern and serves as a warning to New Zealand, therefore the Education Minister must consider the plan for communities of online learning in greater detail and in consultation with relevant experts and stakeholders before passing the proposal into legislation.

Dianne Khan, SOSNZ

Further reading:

Education Amendment (Update) Bill – Communities of online learning (COOLs)


Inside Online Charter Schools, Cambridge, MA: Mathematica Policy Research, Oct 27, 2015, by Brian Gill, Lucas Walsh, Claire Smither Wulsin, Holly Matulewicz, Veronica Severn, Eric Grau, Amanda Lee, and Tess Kerwin (Summary is here)

About Save Our Schools NZ

"One needs to be slow to form convictions, but once formed they must be defended against the heaviest odds." Gandhi


One thought on “My select committee submission on Communities of Online Learning (COOLs)

  1. Fabulous, thank you for doing this.


    Posted by Greg Patel | November 12, 2016, 6:39 pm

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