The Bill is discriminatory and marginalises beneficiaries

Date: 20 October 2012

POST TO: Secretariat Government Administration Committee Parliament Buildings WELLINGTON 6011

SUBMISSION Social Security (Benefit Categories and Work Focus) Amendment Bill

Name of Individual / Family / Organisation:

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I/We wish to appear before the Committee to speak to my/our Submission NO

We OPPOSE Social Security (Benefit Categories and Work Focus) Amendment Bill

The Bill falsely assumes that all children of beneficiaries are at risk.

In her interview with TVNZ Q+A (Sunday 23 September 2012), Paula Bennett stated that children that are vulnerable are defined as: those in a low socio-economic group, those who have been at the attention of CYPS previously, and those that are simply disadvantaged. The proposed legislation scoops all beneficiaries into one box, and does not target those who are truly at risk. Instead it threatens to impose sanctions on all non-conforming parents, the vast majority of whom are good parents.

The Bill falsely assumes that children are better off in the care of the State than with their own family. The Bill falsely assumes that the current New Zealand ECE climate will do a better job at educating our young children than their loving parents or extended family members.

There is a multitude of research that clearly indicates that this is usually not the case. I will address this with some supporting evidence below.

The Bill makes a moral judgment that solo parents or widows are better off in work than in their chosen profession as a home-maker and full-time parent.

It has no consideration of the difficult position that these women find themselves in and penalises them for their efforts to raise healthy and happy children in their own environment. In the difficult situation of a parent raising a child on their own, a child obviously needs even greater stability and parental involvement, as a solo parent is often trying to juggle both roles. To coerce a parent to separate from their child, by threatening to remove half their benefit (or anything for that matter), is unacceptable.

Paula Bennett’s personal view, that ‘mothers should work when their children are at school because it is demoralising’ (to Radio NZ 18 September 2012), is threatening to wreck havoc on thousands of lives, where many women count it as a privilege to raise their children and to create a safe, clean, healthy and loving home. Her personal view is not shared by all, and I would argue, also not by the majority of citizens. This was evident when Ms Bennett’s majority in her electorate last election was reduced to 9, which many media commentator’s attributed to her unpopular welfare policy decisions.

There has been no research conducted on the ill effects that this policy will have on these children who will be forced from loving homes into ECE environments that are far from being anything close to the benefit of being raised, cared, and educated in the home. In relation as to whether ECE is beneficial or not, Ms Bennett has merely said, ‘based on the advice she has received’ (on TVNZ Q+A), which I concur is biased and one-sided with the motive to push a political agenda that is based on bottom-lines, propping up the economy, and coercing parents to vaccinate their children.

The Bill is discriminatory and marginalises beneficiaries.

The Bill violates a parent’s right to choose where and how their child is to be educated; a right protected in the Care of Children Act 2004 (Clause 16(2)(d)), and in the United Nations Universal Declaration of Human Rights, International Standards (E/C.12/1999/10, Article 13.29).

With the State having the power to impose financial penalties (ie. removal of a benefit unless the child is placed in ECE) a parent is thus prevented from living out these rights in full.

One might argue that parents still have the right but under this legislation they will have to choose to come up with their own means to make it possible. But I assert that the very fabric of what the Welfare System was built upon is being challenged, as this Bill will set a fundamental shift in a System which has historically been to assist families in need regardless of their health and education intentions for their children. What the Government is attempting to pass here is saying to a genuine family in need that because they are not educating their children how the State wants them to or meeting certain health requirements that they deem necessary, then they will have their benefit cut. They are undermining parents to make these choices.

If the Government is truly looking at ways to increase support to solo mothers and widows for instance, they should in fact be increasing the amount of benefit paid to these families, and actively supporting them in their choice to raise their young children.

Paula Bennett said in February 2012: “The New Zealand welfare system will always be there to support those in genuine need but we are no longer going to hand over benefits and leave people to their own devices.” Later on in this document, the Government lists the timeframe for introducing the reforms, and includes widows and solo parents. So in targeting solo parents in this proposed Bill, the Government is essentially saying that these parents are being left to their own devices, that they do not represent a ‘genuine need’, and the Government are ignoring the legitimate need of this group. It is deeply concerning.

Other Specific Concerns

Redefining the DPB

I am opposed to the redefinition of the Domestic Purposes Benefit for solo mothers or widow’s with children over age 14 as ‘jobseekers’. For one, it assumes that developmentally, all children age 14 or over are capable of being left on their own. The current provision in the law is that children from the age of 14 CAN be left on their own, but only parents would be in the best position to determine if a child SHOULD be left at this age. For example, what of a special needs child? What of a home-educating solo parent? Solo parents and widows should categorically NOT be forced to make a decision to work where it violates their right to parent their children. They should be given options, support, financial assistance, and if they would like to re-enter the workforce for a number of hours per week, they may choose to do so without having the terms of their employment (eg. hours) specified by the State. They DO represent a genuine need and therefore should be entitled to receive assistance in the form of a benefit.

I am also opposed to the redefinition of the Domestic Purposes Benefit to ‘Solo Parent Support Benefit’ for solo parents and widows with children over 5 and under 14, who under the proposed law will need to be available for part-time work. This gives no provision for solo parents who want to parent full-time. The single parent who wishes to responsibly raise their children and not hand this over to State-funded early childhood care should be allowed to choose not to without being penalised.

Early Childhood Education (ECE)

As a starting point, let’s call this what it really is: ‘Early Childhood Education (ECE)’ is the more neutral, less emotionally-charged term for the less desirable term ‘day care’. At three and four years old, it is essentially having paid adults babysit children with some sort of organised and/or structured play as part of the environment. The system attempts to replicate in an institution what usually takes place in the home, which is socialisation (learning the accepted ways of behaviour) and socialising (peer group play time). Towards the end of the pre-school experience, children are prepared for the transition of school. The fact that many children are starting school at 5 unable to write after most having attended these places (as the media have reported this earlier this year) just further demonstrates that the ECE environment is not necessarily the best place to learn. Home educated children are statistically proven to do better in every sphere of society (for example, see

The ones who may reap some benefit from being in ECE are the ones deemed vulnerable, who by Ms Bennett’s own admission, are already at the attention of CYPS. They represent a small minority whose interests should certainly be a policy focus, but who should not be used as the political poster for implementing welfare reform that is being pushed for other reasons. This is obvious to any follower of the broader policy objectives of this Government.

It is not my intention in this part of my submission to dismantle the role of ECE/day care as such, but rather summarise a number of writings that emphasise being with parents in the home is usually the best place for the majority of young children. And this is the choice that many parents, including beneficiaries, intentionally make. Solo parents and widow’s should continued to be supported by the State to achieve this more favourable outcome, as all of society eventually benefits from morally, emotionally stable children. Assisting parents to stay at home with their children at this vital stage in their development does in my view constitute a ‘genuine need’.

What follows is just a very small sample of both research and experience (which also carries merit in addition to scholarly research). I also acknowledge there have been studies that have found ECE is an adequate environment for children, however, I’m trying to bring balance to the statement Ms Bennett has made regarding ‘the advice she has received’ as there is clearly another side to the picture.

1. In ‘The Day Care Decision’, William and Wendy Dreskin tell the story of having set up a high-quality day care centre in San Francisco. The teachers had graduate training, there were low child-to-adult ratios, and there was excellent curriculum and equipment. But they discovered that happy preschool-age children started to withdraw, lash out and inconsolably cry. They witnessed the problem with their own centre and other centres – that day care was disrupting natural family bonds as children were being forced to be away from parents before they were ready. They closed their centre. (William and Wendy Dreskin,” The Day Care Decision”, New York, M Evans and Co, 1983)

2. Raymond S. Moore states: “Harold McCurdy, a distinguished psychologist from the University of North Carolina and a leading student of genius, says that genius is derived from the experience of children being most of the time with adults and very little with their peers. So when you start assembling children in very large numbers for long periods of time, you are on the wrong course for producing strong character and intellect. The more children around your child, the fewer meaningful human contacts he will have.” (Excerpt from an interview with Raymond S. Moore in “Human Events”, September 15, 1984, on

3. Child development expert Stanley Greenspan sums up the developmental needs of babies and children in six major areas, and concludes that these essential needs are almost impossible to achieve in the day care setting, but automatic within the family. (Greenspan, The Four-Thirds Solution, p41).

4. The most comprehensive study to date (also government-sponsored), beginning in 1991 and consisting of 25 researchers at 10 US universities, known as the NICHD Early Child Care Research Network, reported preliminary findings in 2001 related child care arrangements to maternal attachment and child behaviour. Principal researcher Jay Belsky reported the strong correlation between longer hours of non-maternal care and behavioural problems; ie. specifically, aggressive, non-compliant behaviours, temper tantrums, demanding, disruptive, explosive behaviour, cruelty, and gets into fights, just to name a few. These findings were evident despite the study having a low representation of children from families that would normally display these aggressive behaviours (eg. low income, solo parent, etc). Having previously been a proponent of day care, Belsky now found that in actuality studies over the previous twenty years had pointed to similar negative effects of maternal absence on child development, but these had been buried in academic journals. (US Department of Health and Human Services. (January 2006). “The NICHD study of early childcare and youth development: Findings for children up to age 4½ years”. NIH Pub. 05-4318).

5. Sociologist J Conrad Schwartz found in 1986 that group care was associated with lower intelligence, poorer verbal skills and shorter attention. (From “Attachment Disorder: What the experts say” as quoted in “Day Care Deception: what the child care establishment isn’t telling us”, Brian C Robertson, Encounter Books, California, 2003).

6. Clinician and researcher Selma Frailberg writes that institutional day care, no matter what the quality, is unable to satisfy the need every child has for devotion from one special adult as even the best trained caregivers are unable to treat every child with this level of devotion. This is compounded by the inevitability of caregivers who leave their place of employment and break the attachment a child has made. This is evident also in children over the age of 3 (From “Every Child’s Birthright”, Selma Frailberg, 1977 quoted in “The Day Care Dilemma: Women and Children First, Marian Blum, Lexington Books, 1983, pp 92-93).

7. A 2011 MIT study suggests that early childhood education “comes at a cost: children are less likely to discover novel information”. ECE has a negative effect on children’s “exploration and discovery” (Bonawitz, E., Shafto, P., Gweon, H., Goodman, N. D., Spelke, E., Schulz, L. (2011). The double-edged sword of pedagogy: Instruction limits spontaneous exploration and discovery. “Cognition”, Volume 120, Issue 3, September 2011, Pages 322-330).

8. There are too many studies to list here, so I just mention in short that there are numerous studies that have been conducted, particularly in the US and UK, which demonstrate that children in day care are significantly sick more often, hospitalised more often, and catch infectious disease more often. I was startled to discover that some of the more serious illnesses, such as pneumococcal disease, influenza, giardiasis (diarrhoea), Hepatitis A, were sometimes 36 times higher in day care children than in children in the home. I was also surprised to learn that some studies show that disease transmission is not dependent on the quality of care.

In much of my research on the effects of ECE/day-care, I found a number of well-respected advocates for children staying home with mothers in their early years, have since changed or lightened up their position due to pressure placed on them from day care advocates. They have done this with no further evidence offered but simply because they were pressured to. Some of the bigger names include: T Berry Brazelton (a leading paediatrician in the US who once warned of the detrimental effects of parent-child separation but has since withdrawn his comments for fear of having caused offence); Dr Benjamin Spock (a long-time opponent of day care who changed his mind and in doing so called his own actions in this regard ‘cowardly’); and Penelope Leach (famous for her influence in attachment theory but has since accommodated mothers who feel guilty in her writing).

I raise this point to bring the perspective that often even sound research and writing from the most respected experts can be swayed purely by public opinion although no further evidence offered, and it is these subsequent ‘recanted’ writings that are used by policy advisers to prop up a political agenda where there is actual little actual scientific basis. It is my hope that this is not the case with this Bill.

In summary on this point: where there is so much research, of which I have only given a tiny sample, that demonstrates that ECE may not be beneficial for all children, as a society we simply cannot endorse a policy decision that may have such far reaching effects for children, their futures and their families, if we make ECE mandatory for any sector of the population, vulnerable or not. It is irresponsible to pick out only the research that supports our view, and ignore the vast amount of research that is to the contrary. I say it again: if the jury is still out on the benefit versus the harm of ECE, then we simply cannot require any parent to put their child into that environment.

General Points

In Paula Bennett’s official letter to Barbara Smith of the Home Education Foundation, she clarifies that home education does not constitute “early childhood education”. I wish to make it clear that a home should NOT become a regulated environment or be included in the definition of an ECE. ECE is an alternative to the home, and should remain a choice.

Even if there was such a provision for home educators of pre-school age children, the law would have to make provision for children (of beneficiaries and potentially others) from the age of 3 to be exempt from attending an ECE centre, which I believe to be a ridiculous notion for a developmental stage where children are developing at different paces. A parent would essentially have to outline to the State how they intend to parent their child from age 3 to qualify for an exemption.

Again, ECE is an alternative to the home and should remain so. Good parents should never have to justify how they parent.

Paper E provides insight into Paula Bennett’s apparent reasoning.

Apparently, 90% of all three year olds and 95% of all four year olds currently attend some form of ECE. Of the 31,500 three and four year old beneficiary children, the number of children not already participating in ECE is unknown but believed to be low. With so many children already attending ECE, it is hard to understand what major societal benefit Paula Bennett expects to result from making this compulsory for all children up to 6 years.

It is at this point that I question the need and benefit of this legislation with such a small percentage not attending ECE. I believe that the real reason is two-fold and stems from the Government’s overall policy objectives: firstly, it is to drive more women into the workforce to fuel a lagging economy. Secondly, it is to require children to complete Well Child checks, enrol with a GP, and by consequence, to ensure children are fully vaccinated. I will address this area next.

Well Child Checks

This Bill will make Well Child checks and enrolment with a GP mandatory for beneficiaries, or else they lose their half their benefit.

Completed Well Child Tamariki Ora health checks also means completed vaccination schedules (see paragraph below which quotes the Government on this – my underlining added).

Firstly, this falsely assumes that vaccination is beneficial. Secondly it makes vaccination short of being mandatory, as a beneficiary risks losing half their benefit unless they comply. It is coercion using the threat of removal of financial assistance. It is the same agenda that was expressed at the Health Select Committee that recommended to the Minister of Health to link parental benefits to completed vaccination certificates, although it is a different way of implementing this agenda.
Although it is outside the scope of this submission to discuss why vaccination is not considered a feasible option for many families, I do wish to quote the Minister of Health, Tony Ryall, in his response to the Health Select Committee 22 June 2011 (specifically, Recommendation 12 that would investigate linking parental benefits to completed vaccination certificates): “The Welfare Working Group recommended that every recipient of a welfare payment who is caring for children be required to ensure their children complete the 12 Well Child Tamariki Ora health checks, which include completion of the immunisation schedule, unless they make an informed choice not to” (my emphasis added).

He has also said in various correspondence: “The Committee makes it clear that the inquiry was not undertaken to make immunisation compulsory and acknowledges that it must accommodate parents who object to immunisation”, and “… the Committee is not recommending financial penalties for parents who decline to immunise their children”. (Ryall, 4 Jul 2011, ref 11000989)

This Bill takes away a parents ability to retain control of decisions about their children’s health.

Paper E expresses concern that 0.2% of children did not receive any Well Child checks in the first 9 months of life. The Paper expresses concern for this fact, despite that within this tiny percentage are well-informed parents who have chosen not to use the Well Child programme (one possible reason being that they are continually berated by health professionals for choosing not to vaccinate).

Concluding remarks

This Bill is attempting to drive women into the workforce by starting with a vulnerable group. It re-defines what a genuine need is. It doesn’t value the role, rights, and benefit of a parent to raise their own children and it removes their choices with threats of sanctions. Even where a parent was to stand their ground and take the benefit cut over putting their child in ECE, I predict that it will only invite further State involvement into their family by their choice not to comply. It will directly and negatively affect the children that it claims to protect.

The proposed legislation constitutes a fundamental shift in New Zealand’s tradition of valuing the role of family in every child’s early care, and putting it in the hands of paid professionals who do not have the emotional investment in these children but are merely employees being paid to do a job. It potentially makes children even more vulnerable.

This shift in values that the Government is currently pushing is evidenced in other policy decisions currently being made. I quote Bill English, who is about to veto a bill extending paid parental leave from 14 weeks to six months:

“[Extending Paid Parental Leave] is a desirable policy but it’s not our top priority,” he said. Mr English said he was not prepared to borrow more to fund it when the Government had already borrowed to increase Working for Families by 5 per cent on April 1 this year in a cost-of-living adjustment. The top priority for families had been maintaining income support and increasing early childhood education.” (From NZ Herald, 18 October 2012 – my emphasis added).

This proposed legislation is the first step towards compulsory ECE for all preschool children, which the Government has set forth in its intentions; ie. increasing participation to 98% by 2016 (“Delivery Better Public Services – Supporting Vulnerable Children Result Action Plan, August 2012”). They are starting with a vulnerable group that do not have the means and ability to object loudly. I am joining my voice to theirs to say this proposed legislation is unacceptable and must be utterly rejected in its entirety.

ECE attendance rates are already high. Many families have made a principled decision not to send their children to approved ECE providers. It is these families that will be penalised under the proposed compulsory obligations, not the irresponsible families. Likewise, the 0.2% non-attendance rate at Well Child checks can also be attributed to families who simply prefer to opt out. These parents just get fed up with the pressure to vaccinate, after having made a well-informed decision not to. And at times, the pressure is immense, as non-vaccinating parents are viewed as dangerous, careless and negligent. The sanctions proposed will unfairly target those families who have made a personal choice NOT to, and invite unnecessary involvement from the Government in the form of CYPS officers, case managers, and so forth.

Deeply concerning is the overall re-direction of our Welfare System which was built on the very basic premise to care for the most vulnerable and needy in our society.

This Bill does not put the needs of these groups first, to which we have a moral obligation, and is counter-productive to such an outcome. It assumes that beneficiaries (who have already gone through the process of obtaining a benefit and therefore met the criteria of receiving financial assistance) do not have the ability to make their own choices and are neglecting their responsibilities as parents. This is inaccurate and presumptuous. To say that the State is attempting to care for the vulnerable and then impose sanctions such as cutting benefits is blatant abuse of power. The Welfare System should exist to support these solo parents and beneficiaries with children who lack the means to fully care for themselves.

If the Government wants to support these families who have found themselves in a situation where they are in need of financial help from the State in the form of a benefit, I propose they can provide the following:

  •  Ease of access to health services (such as WellChild checks), should they choose to use them.
  •  Full awareness of their rights and what services they can access, should they choose to use them.
  •  Support of their decisions regarding the health and education of their children, with comprehensive information provided so they can make informed decisions, should they choose to take up the options offered to them or not.

As previously mentioned in this submission, this Bill is a breach of United Nations Universal Declaration of Human Rights, International Standards (E/C.12/1999/10, Article 13.29). Parents have the right to choose the kind of education their children will receive. Coercing them to participate in ECE breaches not only this right, but also the right of children to be raised within their parents’ culture, ethnicity, and religion.

There is no consideration of individual cases and situations in this Bill. It targets the wrong group within our free society, and I believe (as I’ve already stated) that there is another agenda at work here than simply helping vulnerable children and families.

It targets intelligent, well-informed and loving homemakers, homeschooling mothers, and parents who make sound decisions about the health and education of their children, and must be rejected in its entirety.

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