Please find below a set of bullet points jointly prepared by Headteachers’ Roundtable and WorthLess? Group. In producing them we have taken advice and been supported by a range of colleagues and educational professionals.
We believe it is important that, as a profession, we make an informed and balanced response to the draft Inspection Framework and Handbook documents. We are aware of the heavy workload colleagues are carrying hence this summary; you may wish to use a number of the points below, edited as appropriate, in your reply.
A copy of the points below is in this Word Document – Response to Ofsted’s Consultation Questions – 22.03.19
Please feel free to download the document share with colleagues
The online response form is available here: https://www.smartsurvey.co.uk/s/EIFConsultation/ Please not the consultation closes on the 5th April 2019.
Depending on your overall view of the benefits of the inspection process and its impact; you may wish to tend towards agree/strongly agree or disagree/strongly disagree when responding to individual questions.
It’s still not too late to join us at the Headteachers’ Roundtable Summit on the 29th March 2019. More details are here http://htrt-thinktank.co.uk/
To what extent do you agree or disagree with the proposal to introduce a ‘quality of education’ judgement?
Our response: Disagree
- We support the move towards a greater discussion of curriculum within the inspection process. In determining a school’s curriculum it is important to build upon a coherent philosophy of education; curriculum enacts our purpose for educating. The framework has a very strong focus on cultural transmission; this has limited other philosophical perspectives – personal empowerment, preparation for work or preparation for citizenship. Whilst these philosophies of education are not mutually exclusive they are distinct and lead to different emphasis within the curriculum all of which have value.
- The proposed implementation of the Ebacc is not supported by an evidential base and infers a lack of independence by the inspectorate.
- The new content heavy GCSE syllabi for Ebacc subjects are limiting the range and balance of subjects studied and the completion of GCSE in two years; this may be a particular issue in schools working in disadvantaged areas where attainment on entry is low. There is no recognition of this in the draft inspection framework or handbook.
- The current substantial underfunding of schools and increasing lack of teachers, in certain subjects and particularly at a secondary level, is having an adverse effect on schools’ curriculum. A lack of funding is impacting on many schools; the lack of specialist teachers is disproportionately felt by schools in more challenging circumstances. There is no recognition of these challenges within the framework or handbook.
- Whilst the inspection handbook refers to a broad curriculum or broad range of subjects on nine separate occasions only once does it refer to a balanced curriculum. The support for the aesthetic aspect of the curriculum and the creative arts will be further undermined if this framework is implemented.
- The generic intent, implementation and impact is too general to ensure consistent application within a judgemental inspection process; rather it is a framework to support a school’s/Trust’s thinking about their curriculum. An inspection process and grading of the quality of education is difficult to envisage with a small inspection team that lacks the subject expertise to assess the rigour and vertical integration of a subject’s curriculum in a consistent and reliable way.
- There is already a concern that schools are responding to the proposed framework in a manner that is driving up workload; staff being required to rewrite curriculum policies in “Ofsted speak” and schemes of learning. This is often driven by a fear factor due to the high stakes, cliff edged retention of grading within the proposed framework.
- The focussing of an inspection (inspection trails) has the potential to skew the evidence towards relatively weaker elements of a school’s practice rather than a holistic view is problematic. For example, lesson observations will not be a random sample but rather ‘relevant to the focus of the inspection’. Much care will be needed in forming judgements.
- In the absence of independent empirical evidence to support the four point grading system and our concerns about the damaging impact of the inadequate grade on retention of teachers, we would wish to see consideration given to trialling a no grading inspection system that would support a formative, narrative style report on what a schools should do to further improve the “quality of education”. We believe there is no legal requirement to grade the individual elements of a school’s inspection.
To what extent do you agree or disagree with the proposed separation of inspection judgements about learners’ personal development and learners’ behaviour and attitudes?
Our response: Neither Agree or Disagree
- The proposed separation of inspection judgements about learners’ personal development and learners’ behaviour and attitudes lack a coherent and substantial rationale. For example, the first two bullet points on learners’ personal development are curriculum based; these could arguably be included in the “quality of education” judgement.
- The range and scope of these two separate judgements appears substantially different to the overarching approach to the “quality of education” judgement; by comparison the latter covers a disproportionately high number and range of aspects.
- Due to a lack of funding, schools have been forced to make difficult decisions about the level of educational and pastoral care and support they can provide and cut the provision, in many cases quite substantially. The issue is further exacerbated by underfunding of the High Needs Block and a substantial and sustained cut in external services, previously available to schools; multi-agency approaches are diminishing.
- Schools with large numbers of pupils with high needs would seem to be at a particular disadvantage that is not addressed by the proposed framework. Support for pupils with the high needs is not evenly borne by all schools; this creates an uneven context upon which high stakes, cliff edged judgements are made.
- The proposal for a separate behaviour judgement makes Alternative Provision and schools supporting large numbers of pupils with SEMH appear increasingly vulnerable to an adverse behaviour judgement. The lack of inclusion of SEMH as a recognised special need, in the Special & Alternative Provision section of the handbook, is a matter of concern.
- The focussing of an inspection (inspection trails) has the potential to skew the evidence towards relatively weaker elements of a school’s practice rather than a holistic view. For example, lesson observations will not be a random sample but rather ‘relevant to the focus of the inspection’. Much care will be needed in forming judgements.
- There is a particular concern that schools will be held to account for societal or parental issues that they have limited control over. This may be particularly acute in the most disadvantaged and challenging areas.
- In the absence of independent empirical evidence to support the four point grading system and our concerns about the damaging impact of the inadequate grade on retention of teachers, we would wish to see consideration given to trialling a no grading inspection system that would support a formative, narrative style report on what a schools should do to further improve the “behaviour” or “personal development”. We believe there is no legal requirement to grade the individual elements of a school’s inspection.
To what extent do you agree or disagree that the judgements will work well for: (Early Years Settings)
Our response: No response to this specific question
- The contents of large parts of the framework and handbook seem less relevant to these settings. However, we believe there are other organisations that are better placed to give an informed and detailed response to this question.
To what extent do you agree or disagree with the proposed focus of section 8 inspections of good schools and non-exempt outstanding schools and the proposal to increase the length of these inspections from the current one day to two days?
Our response: Disagree
- Given the overwhelming percentage of schools that are already graded as good or better the loss of the light touch Section 8 health-check is a retrograde step and poor use of Ofsted’s limited resources.
- There is no evidence presented that Ofsted would be able to increase the reliability of its processes or validity of its conclusions by extending inspection of good schools from one to two days. The option to convert to a section 5 currently exists and should be used proportionately and only when necessary as per the current arrangements.
- We agree with the NAHT position that Ofsted should instead focus its resources on providing a stronger diagnostic insight for those schools which are struggling to improve. This may create the opportunity and space for the development of a rigorous peer to peer quality assurance process between schools/trusts.
To what extent do you agree or disagree with the proposed introduction of on-site preparation for all section 5 inspections, and for section 8 inspections of good schools, on the afternoon prior to the inspection?
Our response: Disagree
- The proposal to move to a no notice inspection is unacceptable. It shows limited understanding of the role of school leaders in developing local and regional partnerships and maintaining an outward facing element to their role.
To what extent do you agree or disagree with our proposal not to look at non-statutory internal progress and attainment data and our reasons why?
Our response: Disagree
- The reasons put forward by Ofsted for not looking at non-statutory internal progress and attainment data are coherent and appropriate. The same is true of the other evaluative methods contained within the handbook proposals: work scrutiny, discussions and part lesson observations.
- There is the clear and very real potential for work scrutiny to be a significant driver of workload for teachers, in particular, and school leaders. The perceived need to include evidence of the vertical integration and subject rigour of the taught curriculum, for scrutiny by school leaders and inspectors, is likely to be immensely damaging. The use of work scrutiny; as much work is contemporaneous does not match with espoused definition of learning as a change in long term memory.
- In localities/regions that have split infant and junior school provision there are often concerns raised about the enhanced Key Stage 1 results, used as the baseline for progress to Key Stage 2, compared to the Key Stage 1 baseline in primary schools. Junior schools in these situations may be adversely affected in the high stakes inspection process.
- Special schools and Alternative Provision use internal data as the key indicator of progress for pupils. Using external data, but not internal data, as the key indicator of progress will fail to show progress within context especially the social emotional and development progress learners make.
- A reliance on book scrutiny and work samples in Special Schools, Alternative Provision and schools with large numbers of high needs pupils will place them at a significant disadvantage. Some of these pupils show a reluctance to work in books, are often reluctant writers and on occasions may destroy their work if someone says it’s good.
- The more natural conclusions of the concerns raised by Ofsted in terms of the reliability of non-statutory internal progress and attainment data is the profound difficulty of evaluating a school’s performance – particularly with respect to an arbitrary four point scale. It would emphasise the need to move towards a no grade inspection system with a narrative style report on a school’s strengths and areas to develop.
- It would be preferable to use rolling three year contextualised data with proportionate accountability for pupils who attend the school – rather than the attendance during the SATs in Year 6 or third Thursday in January system for assigning pupils to a school’s roll. We are also open to the work conducted on the use of comparative family of schools as part of the accountability measure. This would help provide a school effectiveness metric – rather than a school intake one – and give due credence to the work done by inclusive schools and those with challenging intakes using aggregates performance over time.