（Attachment）Survey result of the inquiries to relating agencies and schools for foreign nationals in Japan

1. Method of Implementing the Survey

    This study was conducted as a survey issued by the International Affairs Division of the Minister’s Secretariat of the Ministry of Education, Culture, Sports, Science and Technology on condition that the names of the prefectures and the individual names of the international schools would not be disclosed. The period for the written survey was November 2011.

• Number of departments in charge of schools for foreign nationals situated in prefectures with international schools not accredited as miscellaneous schools and quasi-incorporated educational institutions: 5.
• Number of departments in charge of schools for foreign nationals in the prefectures stipulating accreditation criteria for miscellaneous schools which already apply to schools for foreign nationals: 7.
• Number of international schools which are members of the Japan Council of International Schools: 26.
• Number of schools for Brazilian nationals which have been accredited as miscellaneous schools: 12.

(References)

    At present, Hiroshima International School serves as the organizer for the Council. To become a member, the following five requirements must be met.

1. As part of its structure of governance, all schools should have a body appointed or elected to oversee all aspects of the school’s operations.
2. Schools must demonstrate reasonable stability and continuity; schools may only be admitted to JCIS after a period of three years of successful operations as an established school, and after fulfilling all other criteria for membership.  Schools shall have a clearly formulated set of objectives and educational philosophy which shall be set forth in a written statement.  Each school must be accredited, officially accepted as a candidate for accreditation, or should give valid reasons why accreditation may not be appropriate to the school.
3. Each school should have a fully articulated curriculum which is taught in English. Full member schools should demonstrate a complete educational programme for one or more of the following: Preschool, Elementary School, Middle School, High School.
4. Each school should be serving an international/expatriate community, and should attempt to reflect the diversity of a multi-national student body within the delivered curriculum.
5. The school must demonstrate sound financial planning, and financial resources and administration of the school shall be capable of sustaining the educational programme consistent with the stated philosophy and objectives.  The school facilities, basic furnishings, and teaching equipment shall be adequate to support the total school programme.

    Approximately one year is required from the time of application to the Council to accreditation, and following the document screening, after an inspection, a decision is made on whether or not the school will be allowed to join the Council.

2.1  Research on the prefectures stipulating accreditation criteria for miscellaneous schools to be applied to schools for foreign nationals

(1)  Time and reasons for stipulating the accreditation criteria for miscellaneous schools to be applied to schools for foreign nationals

    The time for formulation of the criteria was FY 1993, FY 2004, FY 2006 (two prefectures), FY 2007, FY 2008 and FY 2011.

Since the number of foreign residents has increased, the number of non-accredited schools for foreign nationals with compulsory education programs has also increased. Such schools are not able to receive public financial support (preferential tax breaks, discounts on student commuter passes), and also since they are not able to receive prefectural subsidies, opportunities for learning are not guaranteed for the children of foreign nationals. In order to be able to improve such state at the earliest possible opportunity, it was necessary to enact criteria for miscellaneous schools in accordance with the tough financial circumstances of the schools for the children of foreign nationals. In addition, criteria for accreditation of schools for the children of foreign nationals as miscellaneous schools were established, which eased the self-ownership requirements and funds requirements for school grounds and buildings, due to the fact that examples already existed of accreditation criteria being established for schools for the children of foreign nationals in other prefectures, a notification being sent out by MEXT on the easing of the self-ownership requirements of school grounds and buildings and the fact that the Ministry of Internal Affairs and Communications issued a policy relating to the promotion of a multicultural society to the prefectures seeking the easing of the accreditation criteria for miscellaneous schools. A request was received from one school for the establishment of a miscellaneous school borrowing school grounds and school buildings. It was also determined that there was a need to support the accreditation of schools for foreign nationals as miscellaneous schools and quasi-incorporated educational institutions. Aiming as a prefecture to become an international exchange metropolitan area and to enable foreign residents to participate safely in regional community development, it is important to prepare an educational environment for their children. Municipalities and political parties made requests taking public financial support as an urgent regional issue in the midst of the problem of non-school attendance in regions in which a large number of foreign nationals of South American origin reside. In particular, with regard to schools for Brazilian nationals, some schools were not able to receive accreditation as miscellaneous schools since they are unable to meet the requirements for “self-ownership of school grounds and school buildings” in the existing accreditation criteria. Since foreign workers, including Brazilian nationals, are easily affected by employment changes owing to economic conditions as a result of which the number of students tends to fluctuate greatly in schools for Brazilian nationals, there is the problem that it is difficult to conduct stable school administration. In May 2010, the key points of the MEXT policy taking into account the views of the Policy Roundtable Meeting on the Education of the Children of Long-Term Foreign Residents were issued, and the opinion was expressed that “there is a need to promote the formation of miscellaneous schools and quasi-incorporated educational institutions so as to enable the stabilization of the administration of schools for Brazilian nationals and the provision of enhanced educational contents”. Accordingly, the prefectures were asked to “continue with the optimization of the criteria within an appropriate extent”. Therefore the requirements have been eased in order to ensure the stabilization of the administration of schools for foreign nationals and to secure learning opportunities for the children of foreign nationals.

(2)  Results Expected through Flexibility in the Criteria

By easing the self-ownership requirements and funds requirements and allowing accreditation by lowering the hurdle for accreditation, it is expected that learning opportunities for the children of foreign nationals will be secured and educational conditions will be improved such as through being able to receive the abovementioned public financial support and subsidies. Schools for foreign nationals play a major role in society as the basis for the education of students of foreign nationalities, and it is possible to promote school incorporation, the elimination of non-school attendance and support for school attendance by easing the requirements of accreditation. If schools for foreign nationals have a rather weak financial base it becomes possible for them to receive subsidies by becoming incorporated educational institutions. In addition, the burden on students will also be reduced if the schools become miscellaneous schools since student discounts will then apply to public transportation. By being accredited as a miscellaneous school, it becomes possible to receive preferential tax breaks, to receive public support, to achieve the stabilization of school administration and to reduce the economic burden of the parents, and to prepare an educational environment for the children of foreign nationals. By accrediting the educational facilities for the children of foreign nationals functioning as private cram schools as private miscellaneous schools, their status and educational conditions will be improved. The educational environment of the children will be improved and, in turn, this will contribute to the realization of a multicultural society. The administration of schools for foreign children will be stabilized and learning opportunities for the children of foreign nationals will be guaranteed.

(3) Whether any problems arose to do with the education or administration of the schools for foreign nationals after the implementation of more flexible criteria

    Six prefectures responded that, at the present time, no particular problems have emerged. In addition, one prefecture reported that one school had decided on closure since the expected subsidies could not be acquired, but was able to remain open owing to donations from local businesses.

2.2  Research on prefectures in which international schools which have not been accredited as miscellaneous schools or quasi-incorporated educational institutions are located.

(1) In cases where an application or consultation was received pertaining to accreditation as a miscellaneous school or a quasi-incorporated educational institution, are there any cases that the prefectures determined it inappropriate?

    Three of the prefectures determined that the applications or consultations were cases that were not appropriate for accreditation, and two of the prefectures had received no applications or consultations which were deemed to be inappropriate.

(2) What is the obstacles to accreditation in the case of above question (1)?

The school grounds or buildings were not owned by the school. The grounds, buildings, operational funds, etc. did not satisfy the asset requirements. The objective was not clear (private cram school, etc.).

(3) How does the prefecture consider that a profit-making corporation establishes a miscellaneous school?

    Four prefectures determined that it was not suitable for the establisher of a miscellaneous school to be a profit-making corporation and one prefecture did not offer a response. The following reasons were given for determining the establisher not to be suitable.

There were some concerns that since the primary objective of a profit-making corporation such as a stock company is to yield a profit, profit-making as a corporation is likely to take priority over the good of the community and continuity as an educational institution, and therefore appropriate school administration is unlikely to be conducted. It was thought that it was more suitable for an incorporated educational institution with the aim of establishing a private school to establish a miscellaneous school.

(4)  How is the future direction of the accreditation criteria for miscellaneous schools?

    With regard to borrowing school grounds and buildings, four prefectures gave permission while one prefecture did not give permission and furthermore had no plans to give permission in the future.

    With regard to the requirements for operational funds, there were no plans to ease the requirements in any of all five of the prefectures.

    With regard to the criteria for schools for foreign nationals, two prefectures had established such criteria while three prefectures had not established any criteria and had no plans to do so in the future.

    With regard to the requirements of the establishers (restricted to quasi-incorporated educational institutions), two prefectures allowed more flexibility while three prefectures did not allow more flexibility and had no plans to do so in the future.

    With regard to the requirements for miscellaneous schools, there were some prefectures employing flexibility while some did not and therefore there were some differences noted between the local governments.

(5)  Why does the prefecture have no plan to allow more flexibility than the current accreditation criteria for miscellaneous schools?

Criteria already exist, which have eased the borrowing requirements and funds requirements of school grounds and buildings when compared to those of other miscellaneous schools, and there were no cases where further easing was deemed to be necessary. Moreover, there were some fears that if the financial base or the organizational structure were to be easily deregulated then it would become difficult to make such guarantees as securing the permanent administration of the schools and the quality of education. Flexible criteria that would enable the stable operation of the schools were unclear. There was no real need to allow flexibility in the miscellaneous schools criteria simply owing to the school being a school for foreign nationals. Such requirements as allowing the borrowing of school grounds or buildings had already been eased.

3.  Research on Schools for Brazilian Nationals Accredited as Miscellaneous Schools

(1) Advantages of being accredited as a miscellaneous school or a quasi-incorporated educational institution

Subsidies may be received in accordance with the number of students. It is possible to use student discount commuter passes such as for the JR line. Consumption tax for tuition fees became exempt. It became easier to visit the town or city council and local assembly for observation tours and to visit and hold exchanges with public elementary and secondary schools. We had been striving hitherto to become a school open to the community as a school for Brazilian nationals, but it has become easier to interact with the public administration and the schools in the surrounding community, and we have been able to play a role in realizing a multicultural society in the community. External credibility was increased. It has become possible to continue school administration because we have been able to receive subsidies and have become a tax-exempt business operator.

(2) Problems to do with being accredited as a miscellaneous school or quasi-incorporated educational institution

A long-term lease contract was required for the school grounds. Our school was able to acquire accreditation as a miscellaneous school only because the prefectural government had eased the criteria for schools for foreign nationals as miscellaneous schools. With the previous accreditation criteria, since schools for Brazilian nationals had a short history and school administration was difficult, it was sometimes a challenge to obtain broad cooperation from Japanese society and it would have been impossible for our school to financially meet the establishment criteria of the prefectural government. Even with the easing of the standards, at the time, due to the Lehman shock a number of parents lost their jobs in the recession or their jobs became unstable which led to a reduction in the number of children attending our school. Therefore we applied at a time when it was proving difficult to maintain the school, which meant that the application was difficult even with the new criteria. Not only did we face problems to do with the school grounds, buildings and self-financing, but we had to carry out repairs to meet the accreditation criteria such as for the corridors in the school buildings, and therefore, repair to meet the criteria involved large expenses. There were a lot of documents for the accreditation application, which covered a wide range of topics, and since it was too difficult for a Brazilian national to fill in the documents, we had to hire an expert which involved high expenses. In the midst of a severe administration climate, it was difficult to secure the number of teaching faculty required by the guidelines because of the need to secure the quality of the teaching faculty and the increase in personnel expenses. It was difficult to understand the application process since there were a large number of documents and there were parts that were difficult for a school for foreign nationals to understand.

(3) Opinion about the future direction of the accreditation criteria for miscellaneous schools and quasi-incorporated educational institutions

We would like the criteria for the school grounds and buildings to be further eased. Although the criteria for the self-financing required for accreditation was lowered to holding the cash or savings equivalent of one-quarter of the annual expenses, we would ask that the criteria be eased a bit more. Maintaining a fixed number of teachers is financially difficult when the number of students has decreased and so we would like some changes to be flexibly allowed. By becoming a miscellaneous school, it has become possible for the students to use student discount JR school commuter passes but due to the public transportation routes, most children use schools buses. The cost of the schools buses to commute to school in addition to the tuition fees places a significant burden on the parents and so we would like measures to be taken to help ease this burden. The accounting year according to the Private Schools Act is stipulated as being from April 1 to March 31, but the accounting year for schools for Brazilian nationals is from February 1 to January 31. If the commencement of the business period differs then it is difficult to secure the number of children and teachers and therefore we were wondering whether it would be possible to make the accounting year consistent with the commencement of the business period. The accreditation criteria should be uniform for each prefecture. We think that it is appropriate for the accreditation period to be March, but we would like to see the applications for accreditation and screening to be accepted at any time.

4   Research on International Schools

(1)  Problems of schools which have not been accredited as miscellaneous schools

    Out of the 26 schools targeted in the survey, there were seven schools which were not accredited as miscellaneous schools. The following reasons were given for such. In addition, the applications of two of the schools to become miscellaneous schools were pending.

Debt asset ratio requirements. We do not have quite enough cash in our reserves The cost to acquire land and buildings is expensive. We do not have a long-term lease which is preventing us from applying for miscellaneous school status.   We have not encountered any major obstacles.

(2)   Problems arising from not being accredited as miscellaneous schools or quasi-incorporated educational institutions.

Higher taxes.  Students can have difficulty entering some Japanese universities. Recognition from the general public as a legitimate school; grants from governments; student train pass discount.

(3)  Legal status of schools not accredited as miscellaneous schools

    With regard to the 19 schools which had been accredited as miscellaneous schools, the current legal status of eight of the schools was determined to be appropriate while the status of 11 of the schools was determined not to be appropriate. The following points were raised in connection with legal status.

The fact that not all Japanese junior high and high schools recognize our diplomas is a very awkward point. We are unable to receive the same kinds of benefits such as subsidies, application for use of public facilities, train/bus pass discounts, application to the Police station regarding road use for parades.  The benefits that are extended to miscellaneous schools are not as generous as those extended to public schools and private schools. The current status allows the schools to have independence in their curriculum.  This is important.  Therefore in this regard the status is suitable I would like to see English-median international schools to be in a separate category from miscellaneous schools as we are not a vocational school or a school that specializes in education of one specific field or subject.

(4)  Future prospects for schools accredited as miscellaneous schools

International schools may be able to extend and enhance the opportunities of providing the unique and specialized education to the community more efficiently and more flexibly. I wish that Japanese law permitted our school to be recognized as equals alongside other Japanese public and private elementary, junior high and high schools.  It would allow for the smooth transfer of students back and forth between Japanese schools and international schools. Ideally we would like to be treated as a full school without the need to follow MEXT curriculum. International schools need to be independent of a national government in terms of the curriculum they offer.  However the mutual benefits of global citizenship would seem to indicate that some form of recognition of a link between the host country and the school would be mutually beneficial. At the moment our status places us on the outside of the mainstream system. Our students cannot compete for instance with other Japanese schools at sporting events. Stronger links may be fostered by a more open approach. We have a world-wide reputation and every year our graduates attend some of the top of the universities in the world.  We would like to Japanese government to recognize us properly. With funding from the government and access to grants, we will be able to make vast improvements to our facilities and the programs we offer. We would like to be recognized as a regular school and be given access to governmental funding and grants.  Our income is derived mainly from tuition and ensuring that we comply with earthquake and safety regulations is expensive. We do not receive any subsidy from the Japanese government or from governments of any other country. 　We only get a very small subsidy from the Tokyo Metropolitan Government. Therefore the fees are very high compared with private schools in Japan. 　We have a limited amount of funds for scholarships and this is a financial burden for the school but we cannot accept all the foreign students who cannot afford the tuition fees. 　Therefore there are foreign students in Japan who face difficulties in receiving education appropriate for them. There are benefits to being a school with school cooperation status. It allows us to be a non-profit school and lightens the tax burden, plus it gives us a certain level of status. I would be afraid that MEXT might impose challenging rules and regulations that would allow international schools to be unique institutions based on Western standards of education if the Japanese government chose to change our status and fully recognize us as schools on par with Japanese schools. I think a proper balance has to be struck and that balance should be reached through a dialogue between international schools and MEXT itself. We do not ask for the criteria to be modified, but unless a school type other than miscellaneous schools is created it will be difficult for schools for foreign nationals to become accredited schools. Criteria are indeed necessary in order for there to be an increase in the number of non-accredited schools becoming accredited schools but one future issue is for the criteria to be eased. We hope the scope of incidental business may be broadened.

(5) Other opinions and comments

As a recognized International School the process for Japanese students to enter the school would be simplified. Most international schools around the world operate with just one Board.  The benefits of having two are not obvious. International schools running internationally recognized curriculum (such as IB) and/or are accredited by internationally recognized accreditation organizations (such as WASC, NEASC, CIS) should be recognized legally as a "school" in the same caliber as local public and private schools. At the moment as a miscellaneous school, our school does not receive student safety and other relevant information from the local education board. We would like to ask Japanese- English bilingual service in terms of administrative documents and announcement. For information we are asked to provide annually to the government, the format and kind of questions asked are often not appropriate for the kind of school we are, with an academic year (mid-August to mid-June) and program that are different from those at Japanese schools. I believe that international schools have an important role to play in creating human resources to work actively at a global scale in Japan. I think that it would be beneficial to Japan to recognize the contributions that international schools make to their communities. Compared to the level of government support for international schools provided in places like Singapore, Hong Kong, Shanghai and other major cities in Asia, Japan’s policies do little to encourage or support international schools in this country.  This short sighted approach fails recognize the contributions our schools make in providing an environment conducive to foreign business investment in Japan.  It is no surprise that many foreign companies have chosen to set up their Asia regional head quarters (or moved their former Japan operations) to these countries.