Select Committee on Education and Skills Minutes of Evidence


APPENDIX 10

Memorandum submitted by the National Union of Teachers (NUT) (OFS 10)

FULL SUBMISSION

  1.  This submission from the National Union of Teachers (NUT) focuses on the new school inspection framework as set out in recent OFSTED consultation documents. It also addresses issues of concern relating to the work of OFSTED's Early Years Directorate and OFSTED's inspection responsibilities for post-16 education.

THE NEW SCHOOL INSPECTION FRAMEWORK

  2.  There is now a bank of research evidence which demonstrates that, while teachers understand the need for accountability, they reject the failure of the current arrangements to enable inspectors to provide developmental advice, as well as criticism.

  3.  The current arrangements lead to punitive consequences for those schools which have been deemed as "failing".

  4.  This approach has led to the alienation of teachers from the process of quality assurance and evaluation. The arrangements have failed to channel teachers' expertise, experience and their commitment to the evaluation process. The NUT is concerned that OFSTED's proposals do not redress sufficiently the balance between internal and external evaluation.

  5.  The NUT would question, therefore, the statement in the introductory section of the consultation version of the new school inspection framework that inspection "findings are intended to help the school to plan for improvement". It has been a matter of long-standing concern for the NUT that Section 10 inspections have not been seen by schools as supportive to their developmental needs and that inspectors should, as well as identifying problems, also offer potential solutions or approaches for schools to consider when addressing issues highlighted for attention as a result of external inspection. Would the Chief Inspector agree that any future development of the school inspection framework should include appropriate support and guidance to schools in addition to the identification of weaknesses?

  6.  The NUT notes the statement in the initial OFSTED consultation document "Improving Inspection, Improving Schools" that "we see no need at this stage to alter the fundamental structure of the arrangements put in place in 1993." The history of school inspection in the past decade is that it has been subject to evolutionary change rather than informed review. Will OFSTED agree to put in place annual review arrangements which maintain a "running check" on the effectiveness of the proposed changes, following its usual consultation mechanisms?

School Self-Evaluation

  7.  The NUT has welcomed the increased emphasis on school self-evaluation within the consultation version of the framework for inspecting schools. Such an approach could be a step towards the model of school self-evaluation for which the NUT has consistently pressed.

  8.  As the Committee knows from its previous submissions on the work of OFSTED, the NUT has consistently promoted a more productive relationship between school self-evaluation and independent, external inspection. It was disappointed to note, however, in the initial OFSTED consultation document "Improving Inspection, Improving Schools" the phrase "Whilst self-evaluation will never be a substitute for independent, external inspections . . ." (paragraph 38). All the work conducted by the NUT, including the studies it commissioned from Professor John MacBeath, have never concluded that school self-evaluation should become a substitute for independent external inspections. The model promoted by the NUT seeks to secure external and developmental evaluation of each school's internal self-evaluation procedures. How would the Chief Inspector define the relationship between internal and external evaluation? Does he envisage any changes in that relationship in the future?

  9.  The NUT believes that school self-evaluation instruments and approaches cannot be imposed and that the format for recording schools' self-evaluation work should offer maximum flexibility, so that schools are able to make use of their existing documentation rather than be required to complete additional paperwork simply for the purposes of the inspection. The NUT is concerned that if OFSTED-prescribed self-evaluation forms were used, these might distort schools' own work in this area and lead to an over-emphasis on OFSTED's approach to self-evaluation, to the detriment of the contribution self-evaluation can play in overall school improvement. Would the Chief Inspector expand on the format, role and purpose(s) of self-evaluation in the revised school inspection framework?

  10.  The NUT notes the comments made by HMCI in the Commentary of the "Annual Report of HMCI 2000-01":

    "the constraining factor in further improvement of school self-evaluation is a shortfall in non-teaching time for those involved."

  It is important that OFSTED takes such constraints into account, both at national and individual inspection level, as these constraints could prevent schools participating effectively in both the proposed and any future model of self-evaluation for inspection. In order for self-evaluation to become embedded in all schools, it is vital that all schools are resourced sufficiently to enable such important developmental work to take place. How will OFSTED inspections take into account barriers to school self-evaluation, which are beyond the school's control?

Inspection and Teacher Workload

  11.  There are currently few schools which do not over-prepare for inspection. The pressure from headteachers to ensure that lesson plans and records, for example, are at presentation level will continue simply because of the high stakes nature of inspection unless direct action is taken by OFSTED.

  12.  According to the PricewaterhouseCoopers (PwC) report on teacher workload, 36.9% of teachers cited "inspection related activity" as having a significant effect on their workload, the highest ranked activity by some 17%. The report also found strong evidence to support the view that Section 10 inspections are very often the driver for overly detailed and elaborate short and medium term planning by teachers. This situation was compounded by the behaviour of inspection teams:

    "the comments teachers told us had been made by individual OFSTED inspection teams could also be taken as implying a need for greater documentation. Where this feeling manifested itself strongly, it led to a lot of record keeping—much of it, we believe, unlikely to be looked at by anyone and also undermined attempts to reassure teachers that they are valued and regarded as professionals."

  Para. 1.25, PwC Teacher Workload Study, 2001.

  13.  The PwC report also recommended that OFSTED should seek to address this issue as a matter of urgency. The revision of the "Framework for Inspecting Schools" would appear to represent a particularly useful opportunity for OFSTED to ensure that schools do not produce more than is necessary and "fit for purpose" in terms of planning. OFSTED needs to provide clear and specific guidance on these issues, to reinforce to both inspectors and teachers that the purpose of planning and assessment should be to benefit children's learning and that lengthy and beautifully presented lesson plans are not necessary for external monitoring purposes. As teachers' planning will continue to be scrutinised by inspectors, will OFSTED provide detailed guidance on what is expected of teachers in terms of the documentation of planning and objective setting for pupils?

  14.  The NUT welcomes the inclusion of the management of teachers' workload in the "Framework for Inspecting Schools", as part of the evaluation of school management's effectiveness. OFSTED should now take the opportunity, recommended by PwC's teacher workload study, to require inspection teams to inspect school management's effectiveness in preventing excessive workload being experienced by teachers. Would the Chief Inspector expand on how the management of teachers' workload will be evaluated? How will OFSTED ensure that the judgements made about the management of workload take into account the external demands, which are beyond the control of the school's leadership and which would, indeed, have an impact on the workload of school leaders also?

  15.  The NUT welcomed the emphasis given to reducing bureaucratic requirements on headteachers in the consultation version of the revised inspection framework, in particular, that "wherever practicable, inspectors will accept data in the form held by schools". This could be strengthened still further, however, by a commitment that OFSTED would only require information from the school that is not available from any other source.

  16.  The NUT would question the recommendation that headteachers should update the various forms relating to inspection annually "so that when an inspection is due all the required information is immediately to hand". Whilst acknowledging that the inspection forms can make a contribution to school management processes, the NUT believes that this might be seen as a compulsory requirement by some schools, because of their apprehensions about the inspection regime.

  17.  In addition, such a requirement might be seen to contradict OFSTED's own commitment, as noted above and constitute unnecessarily bureaucratic procedures. This is particularly disappointing given the current national policy context of reducing levels of bureaucracy on schools. It would certainly have an impact on headteachers' and other staff's workloads. Would the Chief Inspector agree that OFSTED has responsibility in ensuring that its requirements are manageable for headteachers? What mechanisms are in place for monitoring and reviewing such demands on a regular basis?

Use of Comparative Data by OFSTED

  18.  The OFSTED consultation documents refer to an increased reliance by inspection teams on value-added data.

  19.  The NUT would wish to register caution about any over-reliance on value-added data. It recognises that value-added mechanisms for the statistical data available to inspectors about schools can lead to greater accuracy in reflecting school achievement. The absence of value-added progress, however, does not necessarily mean failure but could indicate changes in pupil intake, including high mobility, or maintenance of current achievement despite significant external pressures. This sensitivity should be part of the heath check which inspection teams should use in testing the reliability of value-added data. Would the Chief Inspector acknowledge the need for sensitivity in the use of such data?

  20.  In addition, the NUT is concerned about inspectors making comparisons between schools which are deemed to be similar through information provided by Performance and Assessment (PANDA) reports when other information may indicate that the circumstances of such schools are anything but similar. The NUT believes that OFSTED should review the way in which benchmark data is used by inspection teams. Would the Chief Inspector acknowledge the limitations of such data in making comparisons between schools?

Parents and Pupils

  21.  The fact that pupils have a high stake in the quality of their schools' educational provision is incontestable. Indeed, as the recent research by the Hay Group shows, pupils' views about their teachers are frequently more positive and constructive than teachers themselves imagine. OFSTED must recognise, however, that pupil questionnaires could be open to abuse. As the Hay Group report itself says, "the climate of inspections and assessments has led many teachers to have a very guarded view of their performance in the classroom." The NUT's own survey, conducted by Warwick University on teacher attitudes towards pupil behaviour indicates that more than 80% of teachers in schools of all types, in rural, urban and inner city areas, believe that pupil behaviour has deteriorated during their time in teaching. From the NUT's own evidence, there are relatively small groups of pupils who nevertheless have the capacity to operate maliciously in schools.

  22.  Pupils' views in the context of focused school self-evaluation exercises, conducted with the consent of teachers and other staff, provide valuable information. As the NUT's own work on school self-evaluation has revealed, collection of such data through school self-evaluation necessarily should be confidential. In the context of "high stakes inspection", the incentive for either malicious intervention from some pupils or for pupils to misrepresent themselves in the context of pupils' own views of what inspections might consist of, is greatly increased.

  23.  It is in this context that OFSTED needs to consider very carefully any proposal to use evidence from pupil questionnaires to inform inspections. As indicated above, the internal use of pupil questionnaires as part of school self-evaluation is not at issue. The issue is whether pupils involved in filling in questionnaires will move from being involved in providing valuable information to the school corporately or whether such information can be used to undermine individual teachers.

  24.  There are also other issues arising from this proposal. Some pupils may not be able to express themselves as well as others. There may also be the complicating factor of whether some pupils can fill in questionnaires without teacher intervention and support. If teachers are expected to supervise the completion of questionnaires in these circumstances, issues of confidentiality could be raised.

  25.  In sixth form colleges, student questionnaires have been used to inform the inspections on an optional basis. Post-16 education is based on a different premise to that of statutory education; students attend voluntarily. If, as a result of the outcome of OFSTED's pilot project, it is proposed that pupil questionnaires are to be used as part of the inspection process, at the very least the use of questionnaires should be optional, with a decision taken by teachers on their use.

  26.  The NUT is concerned, however, that it is proposed that such a requirement is introduced for all pupils, regardless of their age, before the results of OFSTED's pilot projects on this development are known. Would the Chief Inspector expand on the proposed use of pupil questionnaires as part of school inspection? If, for example, it was found that the gathering of pupils' views was particularly problematic or unhelpful, would he withdraw this requirement from the inspection framework? Will OFSTED ensure parity between schools and colleges in implementing pupil questionnaires on an optional basis only?

  27.  The NUT has noted the previous HMCI's comments regarding attendance in his 2000-01 Annual Report:

    "Some schools have particular difficulty improving attendance levels when so many children have their absence condoned by parents."

  The NUT would echo these sentiments. Would the Chief Inspector agree the emphasis of school inspection reports in the future should be on what the school has done to improve attendance, making it clear when weaknesses in attendance levels are due more to a lack of parental support than to schools' attendance procedures?

Professional Development

  28.  The inclusion in the consultation version of the revised school inspection framework of the requirement for inspectors to evaluate the effectiveness of the school's leadership in creating a learning community" is welcome. The NUT has held the long-standing belief that, because the promotion of learning is its highest priority, teaching should provide the best example of a learning profession. It has expressed consistently a view that school leaders should primarily focus their energy and activity on being the lead professional within the school.

  29.  The effective development of staff through induction and professional development should be inspected, however, with due regard for the practical constraints facing schools. For example, last year headteachers were advised by Government that they should not let staff out during the school day for professional development activities because of the difficulty of securing high quality supply cover. Would the Chief Inspector expand on how inspectors' findings would record instances where staff are denied CPD opportunities for such reasons?

The Engagement of Teachers in the Inspection Process

  30.  The NUT would suggest that the references in the consultation version of the inspection framework to discussions with staff in the preliminary stages of inspection should be strengthened and become an integral part of the "Framework for Inspecting Schools", rather than being left to the discretion of inspectors. Such a development would reinforce the greater emphasis given to both schools' self-evaluation and the involvement of staff in the management of schools in the revised version. In addition, if the process is seen as a dialogue between professionals from the very outset, such a requirement might also go some way towards improving teachers' attitudes towards OFSTED inspection.

  31.  The arrangements relating to inspectors' feedback to teachers could also be strengthened to include the specific requirement that time for oral feedback is built into the "Framework for Inspecting Schools" and that all teachers who wish to access such feedback should be provided with adequate time to enable this to take place. Would the Chief Inspector acknowledge the need for OFSTED to do more to engage teachers in the inspection process? In what ways does he believe this might be achieved?

OFSTED'S EARLY YEARS DIRECTORATE

  32.  The creation of the Early Years Directorate has incorporated the OFSTED inspection of the Foundation Stage in schools (Section 10) with inspection of maintained nursery provision for three and four year olds with funded places in private and voluntary sector settings (Section 122). It also involves the registration, regulation, compliance and enforcement required by The Children Act inspections of the quality of day care provided for young children.

  33.  The NUT believes that children and parents are entitled to comparable quality of provision for their education and care. Under the present arrangements, however, Section 122 inspections are carried out by a single Registered Nursery Inspector rather than teams of inspectors and usually only last for a day. It has also been reported by the Early Years Curriculum Group that there may be discrepancies between the key issues set out in the two forms of inspection. For example, recommendations to put a system of planning or assessment in place for a private nursery setting bear on comparison to the rigorous and detailed refinements that may be demanded of staff working with under fives in schools. (Early Years Curriculum Group, "Action Paper3", 2001).

  34.  The NUT believes that the inspection of all early years education provision should be based on the following common principles:

    —  All forms of provision for young children should be subject to the same rigorous system of regulation and inspection;

    —  The main focus of the external inspection should be on whether or not an institution has effective systems and procedures for self-evaluation and improvement;

    —  There should be common standards for staffing, premises (indoor and outdoor), the curriculum, health and safety etc against which all providers of education are inspected;

    —  Making judgements about provision should be a corporate activity and, therefore, one inspector acting alone is not satisfactory; and

    —  All inspectors should be appropriately qualified and have significant early years' experience.

  35.  The current discrepancies between Section 10 and Section 122 inspections are unacceptable. The NUT believes that consistency of approach to the provision in all sectors is essential, but not at the expense of quality. All settings should have visits from more than one inspector lasting longer than one day, so that there is time to gather valid and reliable evidence of continuity and progression. It should also build on internal procedures for self-evaluation, providing validation and also encouragement for practitioners to become increasingly reflective in their practice. Meetings with parents and managers should be built into the inspection, as they are for schools. How will the current inconsistencies between Section 10 and Section 122 inspections be addressed by OFSTED? Will the Chief Inspector acknowledge that reliable and consistent judgements are less likely to be achieved if inspections are undertaken by one person? What is the place of educational assessment in inspections of early years provision? Should this be the main focus of inspection, as is presently the case for Section 10 inspections, or should there be a more fundamental reassessment of what all early years provision, including nursery schools and classes, might offer and how it could be measured?

  36.  The recent expansion of OFSTED's remit has meant that nursery education inspectors are not needed because of the requirement for OFSTED to take on all of the staff previously employed as inspectors within the social services departments of local councils. The NUT is concerned that the training for early years and childcare inspectors is currently inadequate.

  37.  The most productive form of inspection is one where the inspector understands the learning and teaching processes at work and is able to draw on actual evidence. Those being inspected must respect the judgements being made. Where such understanding is not present the inspector's judgements may lack credibility, or the wool may be pulled over the inspector's eyes. The composition of inspection teams must, therefore, be suitable: the qualifications, training and experience of the inspectors themselves should be appropriate to the provision being inspected. What assurances can the Chief Inspector give that inspectors of early years provision—in maintained as well as private and voluntary settings—are up to the job?

OFSTED Post-16 inspection

  38.  Since September 2001, post-16 provision has received greater attention as a result of the extended remit given to OFSTED and the establishment of the Learning and Skills Council (LSC). Although the NUT has, to a certain extent, been reassured as to OFSTED's intentions about the way in which "The Common Inspection Framework for Inspecting Post-16 Non-Higher Education and Training" will be implemented, the outcomes of the inspection still remain "high stakes".

  39.  The NUT has serious concerns about the powers afforded to LSCs and the way in which inspection reports may be used by them, in particular, the ability of LSCs to put forward reorganisation proposals for the improvement of post-16 provision at local level, including the ability to make proposals relating to closure of school sixth forms where inadequate progress has been made in securing the necessary improvements. The range of provision in any school sixth form may be constrained by factors outside its control.

  40.  It is important that OFSTED liases with the local LSCs in terms of monitoring school sixth form provision. Although raising standards of post-16 provision is an important criteria in the inspection arrangements, this should not be judged in terms of economic viability. Inspection outcomes should not be driven by higher unit costs in post-16 education. When post-16 provision is being evaluated it is important that a fair consideration is given to all course programmes, even though some may prove more expensive than others. How would the Chief Inspector describe the relationship between OFSTED and LSCs? Does he think it would be appropriate for OFSTED inspection reports to be used as justification by LSCs for the closure of school sixth forms? Will OFSTED not be compromised, therefore, by the LSC's additional powers in post-16 reorganisation proposals? What transparent procedures will be in place to ensure that open and full accountability is seen to take place?

  41.  Whilst acknowledging that retention rates and high levels of completion and achievement are important indicators in the post-16 quality indicators, these should not dominate the accountability process. There should be sensitivity to the diversity that exists in post-16 provision. Local and community provision, in both rural and urban areas, must be taken into account.

  42.  In addition, evaluation of post-16 provision should take into account all the factors that relate to social and economic disadvantage. Whilst not intending to justify poor quality provision, the context in which post-16 learning takes place and the circumstances, previous educational and social contexts from which learners are drawn, will inevitably have a significant impact on the quality of their learning experience and the learners' achievements. Judgements on where the providers of learning programmes must be made with full knowledge of the learners' backgrounds.

  43.  A wider definition of achievement should also be incorporated into the accountability process that acknowledges the new post-16 curriculum developments, which are delivered increasingly in units and modules. The quality of post-16 provision should also focus on what a particular local provider is offering to meet the educational needs of learners in that locality.

  44.  Any inspection arrangements in post-16 education must not be biased towards narrowly defined outcomes. Obviously, the quality of provision is central to the success of post-16 education but it should be seen in the context of supportive measures rather than as a means of penalising institutions in terms of OFSTED recommendations. For example, there is a range of factors which can influence the quality of provision, including adequate funding.

  45.  Inspection arrangements in post-16 education should recognise and support the delivery of the education that is being offered to learners, rather than focus only on what specific courses are available. For example, the contribution that post-16 students make to the ethos of the school or college of which they are part are important quality indicators. Does the Chief Inspector believe that the current arrangements for post-16 inspection give a rounded picture of all of the work of institutions? What assurance can OFSTED give that post-16 inspections will give equal value to all courses and not just to those that lead to formal qualifications that attract higher levels of funding?

  46.  The quality of school sixth form provision is currently subject to both Section 10 and Post-16 inspections. OFSTED has said that it is in the interests of all that the inspection of school sixth forms and colleges are comparable. Yet many issues relating to the dovetailing of Section 10 inspections and Post-16 inspections remain unresolved. One key principle is that school sixth forms should not be over-inspected. If, for example, a school sixth form has been recently subject to an OFSTED Section 10 inspection as part of the regular cycle, it should not then be inspected under the new arrangements within four years. Equally, teachers in school sixth forms may view it unfair if the rest of the school was subject to a "short" Section 10 inspection while they had a full Post-16 inspection.

  47.  There is also potential for the over-duplication of documentation and bureaucratic overload arising from the requirements of post-16 institutions to provide evidence of quality improvement. OFSTED needs to issue supplementary guidance, which should be subject to written consultation, on maximum levels of documentation needed for post-16 inspections. It should be a key principle of any such guidance that OFSTED would not require of school sixth forms any information which has previously been provided in connection with a Section 10 inspection.

  48.  The NUT believes that school sixth forms should be included within Section 10 inspections only and not subject to duplicate inspections. Post-16 area inspections should focus on provision which was previously the responsibility of the FEFC. Would the Chief Inspector agree that issues of overlap relating to school sixth forms still need to be resolved? What steps will OFSTED take to ensure that inspection arrangements do not duplicate the bureaucratic and administrative demands on school sixth forms?

SUMMARY

  This submission from the National Union of Teachers (NUT) focuses on the new school inspection framework as set out in recent OFSTED consultation documents. It also addresses issues of concern relating to the work of OFSTED's Early Years Directorate and OFSTED's inspection responsibilities for post-16 education.

  There are a number of questions which arise from the submission which members of the Select Committee may wish to consider in their interview with Her Majesty's Chief Inspector. These questions are as follows:

    —  Would the Chief Inspector agree that any future development of the school inspection framework should include appropriate support and guidance to schools in addition to the identification of weaknesses?

    —  Will OFSTED agree to put in place annual review arrangements which maintain a "running check" on the effectiveness of the proposed changes, following its usual consultation mechanisms?

    —  How would the Chief Inspector define the relationship between internal and external evaluation? Does he envisage any changes in that relationship in the future?

    —  Would the Chief Inspector expand on the format, role and purpose(s) of self-evaluation in the revised school inspection framework?

    —  How will OFSTED inspections take into account barriers to school self-evaluation, which are beyond the school's control?

    —  As teachers' planning will continue to be scrutinised by inspectors, will OFSTED provide detailed guidance on what is expected of teachers in terms of the documentation of planning and objective setting for pupils?

    —  Would the Chief Inspector expand on how the management of teachers' workload will be evaluated? How will OFSTED ensure that the judgements made about the management of workload take into account the external demands, which are beyond the control of the school's leadership and which would, indeed, have an impact on the workload of school leaders also?

    —  Would the Chief Inspector agree that OFSTED has responsibility in ensuring that its requirements are manageable for headteachers? What mechanisms are in place for monitoring and reviewing such demands on a regular basis?

    —  Would the Chief Inspector acknowledge the need for sensitivity in the use of such data?

    —  Would the Chief Inspector acknowledge the limitations of such data in making comparisons between schools?

    —  Would the Chief Inspector expand on the proposed use of pupil questionnaires as part of school inspection? If, for example, it was found that the gathering of pupils' views was particularly problematic or unhelpful, would he withdraw this requirement from the inspection framework? Will OFSTED ensure parity between schools and colleges in implementing pupil questionnaires on an optional basis only?

    —  Would the Chief Inspector agree the emphasis of school inspection reports in the future should be on what the school has done to improve attendance, making it clear when weaknesses in attendance levels are due more to a lack of parental support than to schools' attendance procedures?

    —  Would the Chief Inspector expand on how inspectors' findings would record instances where staff are denied CPD opportunities for such reasons?

    —  Would the Chief Inspector acknowledge the need for OFSTED to do more to engage teachers in the inspection process? In what ways does he believe this might be achieved?

    —  How will the current inconsistencies between Section 10 and Section 122 inspections be addressed by OFSTED? Will the Chief Inspector acknowledge that reliable and consistent judgements are less likely to be achieved if inspections are undertaken by one person?

    —  What is the place of educational assessment in inspections of early years provision? Should this be the main focus of inspection, as is presently the case for Section 10 inspections, or should there be a more fundamental reassessment of what all early years provision, including nursery schools and classes, might offer and how it could be measured?

    —  What assurances can the Chief Inspector give that inspectors of early years provision—in maintained as well as private and voluntary settings—are up to the job?

    —  How would the Chief Inspector describe the relationship between OFSTED and LSCs? Does he think it would be appropriate for OFSTED inspection reports to be used as justification by LSCs for the closure of school sixth forms? Will OFSTED not be compromised, therefore, by the LSC's additional powers in post-16 reorganisation proposals? What transparent procedures will be in place to ensure that open and full accountability is seen to take place?

    —  Does the Chief Inspector believe that the current arrangements for post-16 inspection give a rounded picture of all of the work of institutions? What assurance can OFSTED give that post-16 inspections will give equal value to all courses and not just to those that lead to formal qualifications that attract higher levels of funding?

    —  Would the Chief Inspector agree that issues of overlap relating to school sixth forms still need to be resolved? What steps will OFSTED take to ensure that inspection arrangements do not duplicate the bureaucratic and administrative demands on school sixth forms?

September 2002


 
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