Affect the implementation of an unsuccessful public policy of reproductive and sexual health and rights of youth that the Government of Croatia has been implementing for over two years.
Civil coalition STOP HIGH-RISK SEXUAL EDUCATION
C/o CESI – Centre for Education, Counselling and Research
Nova cesta 4
Tel. 01/24 22 800
Fax: 01/24 22 801
Opinion about the Governmental Policy
on Reproductive and Sexual Health and Rights of Children and Youth
Zagreb, January 17th, 2007
Based on procurable documents, information available in the media and in consultations with the actors involved, Civil coalition STOP HIGH-RISK SEXUAL EDUCATION has prepared a short analysis of the policy of the Government of the Republic of Croatia in regards to education of children and youth about sexuality.
We believe that during the last two years the Government has been designing a reactive, irresponsible, inefficient and non-transparent policy, whose result is the extremely problematic, irrational and non-professional proposal for the introduction of an experimental health education program in primary and secondary schools.
Responsibility for the inefficient process and bad outcome of this very important public policy lies with the Ministry of Science, Education and Sports – the implementing body of this inefficient policy.
The proposal by the Ministry of Science, Education and Sports for experimental health education programs for primary and secondary schools, which has been sent for conformance to the Ministry of Health and Social Welfare in December 2006, comprises of two, out of three, modules about sexual education that in its substance and methodology counter the contemporary principles of public health, standards of human and children's rights, and therefore to scientific knowledge.
Even though an implementation of these experimental programs is scheduled, the time frames, budgetary resources, methods and implementing subjects of evaluation have not been defined.
The decision-making procedure of this public policy was extremely incoherent, inefficient and defective in regards to professional and public debate. The Ministry of Science, Education and Sports hasn't presented the reasons for rejecting the final conclusion of the Commission for Health Education to the public. Moreover, it presented its final decision, sent to the Ministry of Health and Social Welfare, as harmonised with that of the Commission.
The public still doesn't have access to the official documentation of two Commissions that dealt with this policy, while proposed experimental health education programs were not presented to the public through official channels.
We believe that only those programs which are entirely based on contemporary scientific facts, professional achievement on sexual education of children and youth, as well as those in compliance with constitutional order of the Republic of Croatia, should be put in public procedure.
THE POLICY IS REACTIVE FROM THE BEGINNING, INSTEAD OF BEEING PROACTIVE
The Government became involved in the matter of sexual education of children and youth only after, in 2004, certain irregularities in the implementation of extracurricular contents related to sexuality in Croatian primary and secondary schools were publicly disclosed, while, at the same time, the pressure by the Catholic Church and other religious communities in regards to laying the basis of the sexual education on religiously acceptable principles increased. (The Silent Cry affair at the beginning of 2004, the protest letter of the Croatian Bishops' Conference (CBC) against MEMO AIDS program, the affair with Teen Star program, the joint letter of religious communities from December 2004)
Commission for the assessment of all sexual education programs implemented in primary and secondary schools was established on January 10th, 2005 as a reaction to criticisms by the Ombudswoman for Children and media articles about problematic contents of extracurricular program Teen Star, rather than in the context of a straightforward Government policy (despite the fact that the relevant tasks and implementing bodies of the activities existed in the National policy for promotion of gender equality 2001 – 2005, and National Program of Action for Youth, to which Ministry didn't refer to ). Nevertheless, the Commission proposed the introduction of a health education program with very concrete suggestions regarding the curricula and schedule for classes - these haven't been taken into consideration at all, nor presented to the public.
Commission for Health Education was formed seven months after the previous Commission ended its work, and only after media headlines and warnings about the delay were revealed by the vice-president of the previous Commission and other stakeholders.
2. THE OVERALL PROCESS OF DESIGNING THE POLICY IS IRRESPONSIBLE AND INEFFICIENT
For two years since the establishment of the first Commission, a decision about the content and implementing bodies of educational programs for primary and secondary schools wasn't clear, nor has it been discussed in expert and general public, while the decision- making procedure is questionable.
The introduction of a health education program for primary and secondary schools that would also include modules about sexual education was proposed by the Commission for the Assessment of All Sexual Education Programs Implemented in Primary and Secondary Schools, in May 2005. Although the Ministry of Science, Education and Sports accepted this proposal, the final conclusion of the Commission, including the explanation for broadening the scope of school curricula from sexual to health education, where sexual education represents only one out of five modules has never been presented to the public. Although it was obviously a compromise proposal, in order to overcome ideological tensions that existed among Commission members and to link sexual education to other aspects of the health of children and youth, this proposal resulted in a reduced number of hours for sexual education. The criteria for scientifically founded school curricula for sexual education obviously haven't been established and respected; otherwise it wouldn't have happened that the Ministry of Science, Education and Sports, in December 2006, approve the experimental programs of GROZD Association, which comprise scientifically unfounded modules about sexual education. Therefore today, two years after forming of the first Commission, dilemmas about the standards of sexual education Croatian Government is ready to support are the same as in the previous debate concerning the problematic Teen Star program!
There are also dilemmas about whether the Ministry has ever respected the final proposal of the Commission for Health Education, which at its last meeting on November 23rd, 2006 seems to have proposed for GROZD program to be accepted only for primary schools, and only after the necessary changes of the module on human sexuality have been introduced, while it rejected GROZD program for secondary schools after the Association refused to introduce requested changes in modules Culture of social communication and Human sexuality . Despite such a final proposal of the Commission, the Ministry accepted as legitimate an additional vote of the Commission member who didn't participate in 12 out of 15 meetings, nor has he sent filled-in assessment lists. The Ministry, thereby, proceeded against the final proposal of the Commission which already took into account that additional vote, but didn't accept it as the addendum to voting. We therefore conclude the Ministry ignored the decision-making procedure of its own Commission by sending to the Ministry of Health and Social Welfare GROZD's program for secondary schools that wasn't reccommended by the Commission!
It is not clear whether GROZD Association introduced the requested changes to the secondary school module Sexual education in the meantime. Furthermore, if it is possible to introduce them at a later date, what is the time-frame and who is in charge for checking the coherence of the final version of the program with the conclusions of the Commission. This inexplicit procedure of conditional approval of the program is an example of irresponsible and inefficient decision-making, since it is quite possible that due to incoherence of the final proposal of the Commission and a decision of the Ministry at a later date , the program, which is contrary to the criteria of the Commission in the segment of sexual education, will be allowed for experimental implementation!
Decision-making procedure of the Commission for Health Education is non-transparent and inefficient.
Based on statements by some Commission members, the impression has been made that the Commission has, on several occasions, made different decisions in regards to whose and what kind of program module about sexual education should be introduced in primary and secondary school curricula of health education ; this lasted for a few months and thorough an unclear communication between the Ministry and Commission (the Ministry has contacted GROZD program on its own initiative, with a request for changes, after the Commission in September 2006 made its first decision, modified a bit later, about the proposition to exchange the module of sexual education in the primary school curricula for the one offered by the Croatian Red Cross).
GROZD Association has on several occasions explicitly refused to comply with the requests of the Commission to revise its modules about sexual education and, to that end, organized a citizens' petition. This is their democratic right of expressing their own beliefs in the coherence and appropriateness of their program. However, in that context the foundation of the final proposal of the Commission regarding conditional approval of GROZD primary schools program is unclear since GROZD had previously publicly expressed its unwillingness to introduce the requested changes.
Systematic experimental implementation of the program, accompanied by serious, independent evaluation and appropriate financial resources, has not been ensured
The announcement published on the official web site, saying that the Ministry of Science, Education and Sports has sent GROZD program for primary schools and GROZD program and Forum for Freedom in Education (FFE) for secondary schools for conformance to the Ministry of Health and Social Welfare is very brief. It is hard to read from it what kind of resources and evaluation procedures have been envisioned, nor is it clear what the time-frame for the response of the Ministry of Health and Social Welfare is.
The proposal to implement experimentally only one program in primary schools, and two in secondary schools, is inconsistent and there are no obvious reasons why there wouldn't be two programs, or just one, implemented at both levels. At the same time, there is also the unclear role of parents giving approval for their children's participation in the whole program (as it stays in the public announcement of the Ministry, of December 29th, 2006), or just the module about sexual education (which is the way the issue of approval was presented to the Commission).
There is no information in the public about the envisioned evaluation of these experimental programs , its time-frame, allocated financial resources, or designated evaluation implementer.
In general, it seems irresponsible for the Government to transfer the entire responsibility for designing these new and very important programs to citizens' associations, while at the same time the institutions, such as the Croatian Institute for the Public Health or Agencies for Education (former Institute for Education) are insufficiently used. It is not quite clear whether the associations have the responsibility to design programs, while some public government body will take on the responsibility for their implementation and evaluation, or whether associations are co-responsible in that aspect too. A lack of trust in specialised public institutions is also evident from the outcome of the evaluation of the program “Human Sexuality and Quality of Living” from spring 2005, whose implementing partners were the Institute for Education and the Initiative for Introducing Sexual Education (number of experts and specialised associations), and which the Ministry of Science, Education and Sports rejected without ever directly informing the implementing partners about the reasons behind its decision.
Apart from the irresponsible shift of the Government's responsibility for health education of children and youth to civil society organisations, frivolity and irresponsibility of the State towards one of the most important questions for every human – personal health – manifests itself also in the fact that the Ministry of Science, Education and Sports considers it adequate to reduce the question of health education to a maximum of 12 school hours per year.
The Ministry of Science, Education and Sports shifted the final responsibility for the approval of the program proposal for health education to the Ministry of Health and Social Welfare, at the same time disrespecting the proposal of its own Commission.
Review of the GROZD program contents, which became public through unofficial channels, shows that the Ministry of Science, Education and Sports didn't respect the basic criteria of scientific foundation, contemporary principles of public health, national policy on gender equality, and constitutional and international standards for the protection of human and children's rights, in its decision to present GROZD program for high schools (as well as GROZD program for secondary schools without an accompanying warning about the need of significant changes in the module on sexual education).
At the same time, it seems that the Ministry failed to inform the public, and maybe also the Ministry of Health and Social Welfare, that the decision of the Ministry of Science, Education and Sports wasn't founded on the final proposal of the Commission for Health Education which conditionally proposed GROZD program for elementary schools and didn't propose GROZD program for high schools precisely because it wasn't harmonised with contemporary scientific achievements on reproductive and sexual health of youth, and the gender equality policy (the Commission has particularly highlighted the dubiousness of instructions for protection of sexually active youth, of negative presentation of sexuality, especially masturbation, which is contrary to scientific achievements, of gender insensitivity, elaboration of issues such as masturbation, contraception, homosexuality, marriage, love and relationships, parenthood and family, as well as the proposal to separate boys and girls in most of the units about sexuality). Such an outcome represents the culmination of irresponsibility of the Ministry of Science, Education and Sports in designing a public policy about the protection of reproductive and sexual health and rights of children and youth in the Republic of Croatia!
3. THE OVERALL PUBLIC POLICY IS NON-TRANSPARENT
The members structure (criteria and process of appointing) of first and second Commission members is non-transparent, especially of the first Commission where the members of Catholic Church were overrepresented, while experts for school medicine, public health and secular bio-ethics were underrepresented.
The structure and mandate of the Commission for Health Education was not indicated on the web site of the Ministry under the column “Councils, Working Bodies and Commissions”. It can be found only by a thorough search of the archive of the official statements from 2005. The decision about establishing the Commission for Health Education doesn't specify the decision-making procedure of the Commission, or obligations of members of the Commission.
Minutes, decisions and final propositions (opinions) of both Commissions were not presented through the official procedure to the public, neither during, nor after the process of decision-making about their conclusions. Therefore, the public doesn't have access to the conclusion of the first Commission – the procedure and criteria proposal for the selection of program for health education - which was supposed to be the mandate of the Commission for Health Education.
Initiative for Introducing Sexual Education, which proposed the program “Human Sexuality and Quality of Living” together with the Institute for Education, has never received an official response of the Ministry of Science, Education and Sports about the reasons for rejection of the proposed program which was signed by 20 leading Croatian experts for reproductive health and rights of children and youth.
The Ministry didn't find it necessary to disclose the programs that were short-listed for health education, neither during, nor after the end of the Commission's work (FFE published its program on its own initiative, which was not the case with GROZD program).
Ministry of Science, Education and Sports hasn't procedurally predicted, not is it conducting professional and public debate about this policy and concrete programs, and it consistently disregards the opinions of experts appointed to the Commission by the Ministry itself.