Official Report: Minutes of Evidence

The Chairperson (Mr Weir): I welcome Rachel Hogan, who is the Special Educational Needs and Disability Tribunal (SENDIST) representative of the Children's Law Centre (CLC); Liam Mackle, who is the advice manager of the CLC; and Kathryn Stevenson, who is the head of legal services at the CLC. I remind our witnesses that this session will be recorded by Hansard, so anything you say will be fully on the record. I invite you to make your opening statement.

Ms Rachel Hogan (Children's Law Centre): I thank the Committee for allowing us to come here today to give evidence and provide information that may be useful in helping to progress this important legislation. We agree with what was said in the previous sessions in the sense that this is an extremely important piece of law, which will hopefully improve a system that is not working properly for many, many children in Northern Ireland. We would like to take the opportunity to welcome some of the positive changes in the Bill as well as scrutinising areas that pose more difficulty.

First, we welcome the concept of the centrality of the child as a rights holder. It is quite clear from looking at the proposed Bill that the child's rights are a central feature. That is very important, because we have found over the years that the child's rights have been eroded. The child is very often left sitting silent in the classroom, falling behind peers and not asking for help and support. Their voice is not often heard. So, the concept of the child as a rights holder — not an object belonging to others, but a rights older in their own right — is extremely important for trying to effect a culture of change and inclusion within our society and schools.

We also welcome what we see as the promotion of a culture of higher expectations for children with disabilities and special educational needs. Too often, we see a culture of low expectation and setting the bar too low. We encourage children with special needs and disabilities to reach their full potential, to work to their strengths and to have support for any weaknesses they may have in their profile. So, we welcome that culture of raised expectations.

As well as that, we recognise that the policy aims line up well with article 29 of the UN Convention on the Rights of the Child, because they include the aim of earlier intervention to ensure that the child can reach their full potential. We should keep at the forefront of our mind when looking at this Bill what we want to achieve; namely, earlier intervention and effective intervention to ensure that the children reach their full potential.

My colleagues are going to outline a number of issues that have arisen from the paper that we provided, then I will look at some of the remaining issues. As well as our paper, we provided a video of a young client — hopefully, Committee members have the link to that video — named Carla. I will come back to speak about Carla at the end. If you have not had an opportunity to look at that video, I ask you do so. It is short, and it will give you the child's point of view very, very clearly and much more effectively than we can.

Mr Liam Mackle (Children's Law Centre): Good afternoon, members. Thank you for inviting us along. The increase in the numbers of children on the SEN spectrum over the past number of years has been mirrored by the increase in demand for advice and information on the issue in our advice and information service. In 2006, for example, we provided advice in respect of 105 special educational needs issues out of a total of 1,562 issues that were raised that year. So, it was around 6·7% of issues raised at that stage. By 2010, that had risen to 241 issues and 11% of what we were dealing with. Last year, the advice service dealt with 569 SEN issues out of a total issue count of 2,206. So, by last year, 25·8% of issues raised with our advice service were around special educational needs. Other advice services, such as the Special Educational Needs Advice Centre, have seen similar increases in demand. In 2013-14, SEN enquiries accounted for 17% of the issues that were raised with the legal casework team at the commissioner. Issues that are raised by parents in relation to SEN break down more or less 50:50 between the pre-statement stages of the SEN process and difficulties in respect of statements of special educational needs.

I considered this Bill from the point of view of whether it deals with the issues — the operational deficits — that parents bring to the centre's advice service on a daily basis; issues that I know many members will be aware of from their constituency offices. In relation to the pre-statement stages of a pupil's life, will the Bill deal with the delays of moving between stages? Will it address the parental frustration at a pupil sitting at stage 2, for example, for a number of years? Last year, I represented the mother of a pupil. The then MP for South Antrim, Dr McCrea, was a witness for the mother. He had actually referred the case to the centre. That child was first assessed as needing supports in January 2011. The mother had three separate appeals: an appeal in relation to a refusal to statutorily assess the child; an appeal in relation to a refusal to provide a statement for the child; and a further appeal in relation to the provision on that statement. It was not until a Special Educational Needs and Disability Tribunal hearing in February 2014 — some three years after the child had first been identified as needing support — that they got their settled support.

Such delays, which are unfortunately all too common, are the very antithesis of the early identification and intervention that the new framework seeks to bring in. Three years of inadequate provision is unacceptable for any child. It is grossly unfair to expect parents to spend so much of their child's life fighting for services. Will the Bill help to ease tensions that often emerge between parents and schools? Schools often feel highly constrained by education and library board processes. In particular, we are concerned about the use of time-allocation quota systems for educational psychology. Schools are under pressure to prioritise between pupils for referral. Often, they feel strongly that many more pupils than they can refer need to be referred. The new Bill is silent on these issues. Most of the detail is to be filled in, as was mentioned, by regulations and guidance. Such an approach severely hampers our ability to make judgements about the effectiveness of the new system. What will the criteria be for accessing services at the new level 2 stages, for moving between the new levels and for statutory assessments?

We welcome the proposals in the Bill for the Education Authority to publish the services that are available at the new level 2. However, it is vital that not only are the services available, but that they are accessible and that access requirements are transparent and delays are kept to a minimum. The new learning support coordinator needs to be a true partner for parents. This includes being aware of and informing parents about their rights, including their right to request statutory assessments. It is our experience that all too few special educational needs coordinators are aware of this important parental right and able to properly inform parents about that right.

In relation to the post-statement operational deficits, the Bill is, again, silent. We must await new guidance and regulations in relation to the proposed new coordinated support plans. The current code of practice is quite clear that statements should be clear and unambiguous, but this has not been the experience of the parents who contact the centre. Statements that lack any degree of specificity have unfortunately been the default position of education and library boards. It is important that any new guidance on regulations is strong on providing clarity around provision for pupils. It is vital that any therapies, such as speech and language and occupational therapy, when required by a pupil to access the curriculum, are properly provided for in the new coordinated support plans. While the requirement that the Education Authority shall request services from Health and Social Care bodies is important, what is far more important is a requirement on Health and Social Care to provide those services.

Mrs Kathryn Stevenson (Children's Law Centre): Good afternoon. Thank you again for allowing us to come and give our views on this. I want to focus a little bit on the strategic litigation that the CLC has taken in relation to SEN by way of judicial review. Together with the paper that was provided to the Committee, there is the judgement in the case of LC and also a little bit of the press commentary relating to that case.

Leading on from what Liam pointed out, that case highlights some of the key operational deficits in the system as it is in place. It also highlights the importance of parental representations within the statutory assessment process and ensures that there is a very clear requirement on the Education Authority to take into account all available evidence for the statutory assessment and to give value to the parental representations. The judgement was delivered in February 2015. The applicant child is now seven. He had a very complex range of needs. He had severe speech and language difficulties, autism, epilepsy and poor motor skills. The parent took forward the case on his behalf.

The case started really when the child was about to start primary 1, when the mother, at that point, requested a statutory assessment. As Liam outlined, this was a case where the parents had to go through the battlegrounds of two SENDIST appeals — one against a refusal to carry out a statutory assessment and a second in relation to the content of the statement — before matters were resolved and individual provision was put in place. The CLC provided support to the parents throughout the lengthy process of those two SENDIST appeals. What the parents felt in this case was that they really needed to harness home that their parental representations were not taken account of in the statutory assessment process. That was the focus of the judicial review. Basically, the mother talked about the processes being akin to a boxing match for her. She wanted to ensure that she could pave the way for other parents.

In the case, the High Court held that, by ignoring the representations of the applicant's parents, the education board had failed to carry out the statutory duties that it owed and acted unlawfully when it refused the initial statutory assessment. We can understand that obviously it would have sped things up very much for the family if they had not had to go through the tribunal process. Certainly, the code emphasises the importance of parents' input and involvement in the process. The court felt that really only lip service had been paid to the parents and parental involvement in the process.

As Liam indicated in his submission, we see from our Chalky advice line the operational barriers and systematic delays. We see very stressed and exhausted parents who have tried to face down the board in getting access to timely assessments and specific content in their children's statements. This case illustrates all too clearly our experience as a number of key concerns arose in the case. One was that there was a higher rate of refusal in circumstances where parents requested a statutory assessment. If the school put the child forward for a statutory assessment, it was much more likely to go through. Parental views were not taken account of or given the same standing. There was also a very high rate of concessions by the Education Authority to carry out a statutory assessment once a parent lodged an appeal within that particular region. That was what was coming through in our casework for a very long period, because we felt that decisions were being turned around without any clear new evidence being brought to the board.

The case also highlights the immense resilience that is required from parents to take tribunals, some of which are unnecessary and are conceded upon appeal. It also shows that there are systems and procedures that perpetuate considerable delay for parents in accessing the right level of provision for their children. We are also concerned about the detrimental impact that any delay has on a child's learning and development during the period when the parents are fighting this fight. In this case, the parents fought very long and hard to get the provision in place for their child.

I want to highlight from that case the issue of parental representations. We want to see those very much taken account of moving forward in the new processes. We are also concerned about the parents of children with SEN who do not access advice services such as ours. Many parents do not have the skills or confidence to challenge the board or to come forward and seek advice and assistance or to advocate at tribunal. Therefore, we very strongly welcome the proposal under clause 12 that the Education Authority will arrange for an advice and information service for children and their parents. We recommend that some clarity be sought from the Department by the Committee regarding the plans for development of that service, who will provide it, when it will be available, what resources will be allocated and what measures will be taken to make it accessible and user-friendly for children who want to exercise their rights of appeal as they are given new rights under the legislation if it goes through.

We welcome a reduction in the time frame for statutory assessment to help parents move through the process more quickly. As Liam highlighted, the difficulty for many parents who get blockaded at stage 3 is getting to that point. We are rather concerned that the only proposal forthcoming is for the time frame for parental representations to be reduced. That may be to the detriment of some parents, particularly those who require independent advice and support to put together their representations or gather and collate information. They could be the losers from any shortening of the time frame.

We note that there is also provision for moving forward with parental consent. If a parent gets their advice in early, there is no reason to wait until the end of the period to move on with the process. We certainly welcome moving forward if the advice is in early. In our experience from casework — this has been backed up by what Caroline Gillan said earlier — in 81% of cases where the 26-week time frame is not complied with, the delay is due to health provision or health advice coming through. The Education Authority is meeting the time frame. We often see delays in the receipt of health advice, and we recommend, if possible, the introduction of time-based targets for the provision of statutory advice in any new regulations. That would enable health-care professionals to prioritise reporting to the Education Authority and, hopefully, speed up the collation of evidence. Obviously, that would require collaboration between the Health Department and the Education Department. There is the issue of health and social care providers trying to meet their own targets, and we have to balance that with the need to ensure that the statutory assessment process goes through in good time for children. We see that as an opportunity that has to be seized.

We broadly welcome mediation. In our experience, it is much better to intervene at the earliest stage to resolve difficulties with schools and educational authorities. In a large number of our cases, resolution is sought through meetings and negotiations without recourse to formal appeal. Our support comes with the proviso that any mediation does not interfere with appeal rights or delay applications to SENDIST. I am heartened by what Irene Murphy said today about the two processes working simultaneously so that tribunal appeals can be filed while mediation is ongoing, but we will await the time frames in the regulations.

We would also like information on how the service would operate in Northern Ireland. Who will provide the mediation? What training qualifications will they have, and what would be the impact of the mediation? Is there evidence that the process in England has cut down the need for additional appeals? Has it provided a useful diversionary measure, and what is the level of satisfaction among service users with mediation? The Department could provide more information on those things. Also, in the event that mediation is unsuccessful, we would need clarification about what disputes can proceed to appeal. Usually, they would be those within the remit of the SENDIST appeal. If an agreement is reached through mediation, what would be the safeguards for implementation of the agreement?

The last thing that I wanted to talk about was the new appeal rights for children, and we very much welcome those rights being brought forward in SEN cases and disability discrimination. We welcome, as Rachel pointed out, the Department's commitment to recognising that the child is an individual rights holder, and we believe that such new provisions would influence cultural change over time, placing children at the heart of decision-making and encouraging adults to proactively seek children's views on their education provision.

We support, as safeguards, the copying of notices and information on young people's appeals to their parents.

We also support the retention of a residual right of appeal for parents. We are concerned that, when there is a transfer of appeal rights to a child, the parent will be unable to take up that mantle. We certainly would not like to see essential appeal rights being lost. Children may lack confidence, in the same way as their parents might, in challenging boards, and there may be a number of reasons why a child does not want to take forward their appeal, even over the compulsory school age. We would like to see a belt-and-braces approach to appeals going through, whether by the parent or the child, or maybe the parent supporting the child.

We are also concerned about children who are in the looked-after or care sector. If they wish to proceed with appeals and their corporate parent is the trust, they should be entitled to independent advocacy, support and advice to ensure that they are supported properly in pursuing their rights in education.

Ms Hogan: I would like to add a number of points. I will try to be relatively brief because I know that we have limited time. The case that Kathryn mentioned, LC's application, is a very good case for us to bring before the Committee. We believe in general that the existing statutory framework, which the Bill seeks to augment, is a robust framework that has children's rights at its heart. The code of practice is filled with guidance about partnership working with parents and children, and how that statutory scheme should operate. The points that I want to make arising from that are about the balance of the delegation of powers to the Department; that is, the balance between the primary legislation and the regulations and statutory guidance that is to be taken forward.

LC's case was very straightforward and obvious. It concerned a child who clearly had very complex needs, required extra resources and whose needs could not be met from within a school's resources. It was a completely open-and-shut case, and it took us two tribunals and a judicial review to get it resolved. That is where the difficulties lie in the system; not with the statutory system, which is quite good and is being worked on and augmented to a degree. The Committee has rightly pointed out that it needs to scrutinise the regulations and the code of practice in great detail and think about whether there are areas that should be brought into the legislation for proper scrutiny.

The areas that need particular scrutiny are those where there is a degree of silence in the legislation. The three areas that I would draw to your attention are the legal enforceability of the statement or coordinated support plan, as it may be called; the usage of the three levels in place of the five stages that we currently have; and the provisions around the form and content of the statement. Those three areas are currently delegated to the code of practice, which gives the lowest form of protection in terms of scrutiny by the Committee.

You have heard this before, but to be clear on what the three levels are, it is proposed that level 1 be a school-based level, which is our current stages 1 and 2. Level 2 is school-based plus external support, including access to board specialists, educational psychologists, allied health service professionals, speech and language therapy, occupational therapy, behavioural support and so on. Those are to be accessed through this plan, which will be laid out in clause 2 of the proposed legislation. Level 3 is Education Authority based, and it is an amalgamation of statutory stages 4 and 5. It is important to note that stage 4, the request for statutory assessment, which is very important at the moment, will be lost and is going to become a type of process within that new level. The level refers to the provision of a statement. We have a lot of questions around access to the statutory assessment and the appeal rights flowing from that.

The current threshold criteria for access to a statutory assessment are set out in the code of practice, and it is a three-pronged test. The first part of that test is that the child must have significant and/or complex needs. Originally, the Department had looked at putting into legislation a definition of multiple and/or complex needs. There was widespread objection to the use of the word "multiple". Therefore, it was decided not to bring that into the legislation. All three of the thresholds could be manipulated to potentially reduce the number of statements that are made. If you raise the bar of what the needs have to be to get a statutory assessment, you may reduce the number of statements that may be produced in the system.

The second strand is that the school is taking relevant and purposeful measures from within its own resources and through access to external specialists provided by the board. The third test is that the school has had to use resources that are not normally available to a mainstream school in its area. To me, that third test may need further scrutiny. Will it remain as it is? What resources and services will the Education Authority put into its plan? Will it include education services and health services? Are more children going to be moved into the school-based stages, making the argument that the resources normally available in an area are x, as stated in the plan? That could be subject to some manipulation in terms of setting thresholds for access to statutory assessment.

We do not yet know what is to be in the plan or who the stakeholders are who will be consulted on it. It is important to look at how the plan is formulated, how children get access to those services, and whether the threshold criteria for access to a statutory assessment, as linked to the plan under clause 2, will affect the number of children who are either within the school-based stages or the statutory stages.

It is also important to draw attention to the fact that, when we have statutory duties, such as in current stages 4 and 5, authorities draw their resources towards them and resources are prioritised to meet those needs. While it is important to scrutinise that, we have to bear in mind that that affects 16,000 children, or 5% of our school population. However, the children in the school-based stages are much more numerous. There are over 54,000 children in the school-based stages, and they do not have statutory protection in the same way. They have the code of practice to rely on, so they are relying on the thresholds and guidance in the code of practice. If we go to court through judicial review or use other methods to try to enforce those children's rights, it is extremely difficult to access services. Therefore, it will be very important to look at the personal learning plan and how those students are going to access health services such as speech, language and occupational therapy without the mechanism of a statement if they need those services within the school environment.

One of the questions I still have in my mind is this: does the Department intend to reduce the number of statements? Whether that will be the effect of these plans is a different question, but is that the intention? Is it the intention to move more children into the school-based stages? It seems to me that that has been the intention from the outset.

I turn to the form and content of statements or coordinated support plans. It is interesting that the correspondence that the Committee received from the Department on 23 March includes the only reference in the current papers to the use of a coordinated support plan. We are still using the language of "statements" in the legislation, and we will still have statements of special educational need. We question the need to use the term "coordinated support plan", which just adds confusion to the terminology. We do not know what it would look like. It could be that there is an extra section to be added to the statement to deal with outcomes that children should be expected to receive, in which case there would not be a particularly material change to the form of the statement.

It is difficult to progress the legislation without knowing what will be in the statement. Will the provision be specific? Is health provision going be specified and quantified in the statement? Is help and assistance going to be specified and quantified in the statement? How will the statement be monitored? If the annual review process is to be diluted and optional, outside transition and key stages, how will we monitor the outcomes in these statements if parents are not engaging effectively? How are we going to line up the fact that we are giving additional appeal rights when there is no amendment following the review of the statement with the fact that we are not going to have an annual review unless it is requested by the parents through the two-step stages?

The form and content of the statement is regulated by article 16 of the 1996 Order, and that is not going to change. The duty in article 16 is to specify the provision required by the child. That is currently not being carried out in our system so, at an operational level, statements are not specific, clear or quantified. We are doing our best to tackle that using legal processes, but we are doing it one case at a time. We need wholesale change of that practice.

Article 14 of the 1996 Order regulates the duties owed by the Health Department. We have already discussed that there is an increased duty on the Education Authority to seek help but no corresponding duty on Health to give that help. The duty on Health is qualified based on whether or not it has the resources to give that help, so Health can opt out of assisting.

We need joined-up working between Health and Education. The Children's Law Centre supports the private Member's Bill seeking a statutory duty to cooperate between Departments in the Children's Services Co-operation Bill. We feel that there should be a pooling of resources between Health and Education, particularly in relation to children with special educational needs, so that there is access to two pots of money put together into one pool that can be better used.

Given the increase in the number of children with special educational needs and the cuts in budgets over the last five years, we need to look at proper children's services planning and prioritising what children need. Irene mentioned earlier the early years pilots, which seem to have been really successful in drawing Health and Education together within nursery settings. We support extending that out to the greatest degree possible as a model of good practice in working together.

Finally, in many of the other submissions that the Committee received, including those from the College of Occupational Therapists, the Children with Disabilities Strategic Alliance, the Southern Health and Social Care Trust and psychologists, that duty of cooperation or need for joint working is fully supported among all the stakeholders. I am happy to take any questions that the Committee might have. There was a lot to say.

The Chairperson (Mr Weir): That was very comprehensive. As we move ahead, if there are areas of clarification that could be provided, we would be happy to facilitate that. Mention was made today of at least one aspect where you got evidence directly from the Department, which ensured that a previous anxiety was answered. To be fair to the Department, there will be some aspects where it would be unrealistic for it to put flesh on the bones at this stage. If, for example, we are talking about provision in the legislation for a pilot scheme at some stage during the next 10 years — I appreciate that there will be differing views on that — it seems unlikely that the Department would be able to give details on how that would operate.

You highlighted one of the key areas, which is trying to ensure that the balance between primary legislation, secondary legislation and the code of practice fit in the right boxes. The caveat that Liam offered was to say that the key test would be how this deals with the practical situations, and a lot of this will be in regulations. To some extent, it is difficult for all of us to judge the contents of those in the abstract. I think that everybody would accept that.

Mr Rogers: When you talk about the system as it is at the minute and listening to the people who are in need and come to you — many of them come to us at a stage before that — and we hear those terrible stories of how long it takes, I get a feeling that, while the present system is supposed to be child centred or child driven, it is really resource driven, and that seems to be the problem. While there are many pluses in what we know at the minute, do you feel that the new legislation could go down the same road?

Ms Hogan: I think that we have to be very wary of that. There is a distinct probability that the problems that we already see could become further entrenched. We really want to grasp this opportunity. In light of the fact that we now have a single authority, and bearing in mind all the disparate policies that we once had, there is an opportunity here to encourage the Education Authority to put in place policies that are legally compliant with the statutory provisions. For example, statements should be specific; children should have access to intervention when they need it; that intervention should be early and appropriate to the child's needs; parents should be listened to; and the child should be listened to.

Bringing the child into the centre is a very important move in the current legislation because it gives the child rights. The child has to be heard, and there will be an obligation enshrined in law to hear the child. That will bring the child into meetings if the child feels equipped to do that, and we often do that with our young people of all different age groups. We invite them to participate in the process, and it is absolutely amazing to watch the change in that process when you bring the chid in because the child is sitting there as an individual saying, "Here are my circumstances; this is what it is like for me; this is what would help me to cope better at school." That makes a big difference.

Mr Rogers: Yes. Thank you.

The Chairperson (Mr Weir): Trevor.

Mr Lunn: I did not indicate.

The Chairperson (Mr Weir): Oh, right; sorry.

Mr Lunn: But I might.

The Chairperson (Mr Weir): OK. Nobody else has indicated —

Mr Lunn: Then I will, Chair; I thought that you were going to call somebody else. There is just one small point, if you do not mind. On the vexed question of the duty on health trusts to cooperate, your solution seems to be to place a mandatory statutory duty under the 1996 Education Order to do that. Is that possible?

Ms Hogan: I think it calls back a point that was discussed earlier about who should be around the table in those discussions. In my own discussions with various people that we come into contact with all the time, health professionals have a lot to say about the topic. The Health Minister and the Health Department would need to be involved if there is to be a solution around that. I do not get the feeling that there is a proposed solution in terms of a statutory duty on Health. That does not seem to be what is being proposed here, but, if the duty is not statutory, Health has so many demands that it simply will not comply with it.

Mr Lunn: Surely it would need to be statutory. Some of us think that anyway, but I am not too sure how you can amend an Education Order to place a mandatory duty on a health trust.

Ms Hogan: It could not be done without the sanction of the Health Department for that amendment to be made.

Mr Lunn: I wish that we had spoken to these three people before we spoke to the Department. Have you had a discussion with the Department about your concerns?

Ms Hogan: We have. I must say that the Department has been very open to discussion. There has been plenty of engagement by stakeholders. There has been much work done by everybody on this topic, including the Committee, MLAs and the Department. We will have further discussions, as required, with the Department. The door is open for further discussions.

The Chairperson (Mr Weir): I do not know whether — it would be imposing on the school — as the three of you are here and the three members of the Department are here, the school wants to lock the six of you in a room. [Laughter.]

Ms Hogan: We might be there for a very long time.

The Chairperson (Mr Weir): That might be going beyond the powers of the Committee.

Mr Lunn: Could we not send the presentation to the Department for comment? There were so many questions raised.

The Chairperson (Mr Weir): Yes, I do not think there would be any particular problem with that.

Mr Mackle: I have spare copies. I can give them three copies to take away.

Mr Lunn: We could maybe get something formal back from the Department in response to those particular queries. They are very explicit.

The Committee Clerk: Chair, as members are aware, all the submissions are available on the website. The Department has seen CLC's submission, but the Committee might well want to write and follow up on a number of the issues.

The Chairperson (Mr Weir): We will have the Hansard report, but there are a number of particular issues that the CLC has asked for clarification on to do with how it will work in practice and what is planned. It may be worthwhile if the Clerk drew those together. As I said, I think there will be certain aspects that, to be fair, will probably be beyond the bounds of the Department to answer at this stage, but there are also issues on which it should be able to provide clarification, so I think we can forward those concerns.

Ms Hogan: It is hard to deal with. There are so many different issues that it is very difficult to deal with it in a limited time.

The Chairperson (Mr Weir): I appreciate that. As well as your direct submissions, we will have the Hansard report, which can be looked at in terms of issues that you have directly raised orally. I appreciate that the bulk of those will also be covered in your written submission, but I think that will help to clarify matters.

Ms Hogan: One of the other key issues is the involvement of stakeholders in the formulation of the regulations, particularly the code of practice. Practitioners use the code of practice day and daily, and there has not been any engagement with stakeholders yet on that.

The Chairperson (Mr Weir): Again, there is a combination of issues to clarify. We can certainly write to the Department highlighting issues that have been raised that we would like clarification on, both from your submission and what will be in Hansard. That is one of the follow-up actions that we can do.

Rachel, Liam and Kathryn, thank you for your evidence. There may be an opportunity to informally meet the departmental officials. We thank you for your submission.