Memorandum from the Association of Colleges
The Association of Colleges is the representative
body for further education colleges in England and Wales established
by the colleges themselves to provide a voice for further education
at a national level. Some 98 per cent of the 420 colleges in England
and Wales are members.
The Association has been analysing with much
interest the emerging outcomes of the inspections that took place
during the summer term and the first half of the autumn term.
It has held meetings and conducted interviews with the majority
of these colleges and it has mounted two conferences to brief
the sector on the new regime. In addition it has prepared several
information packs explaining the ethos and details of the processes
of the OFSTED/ALI inspection framework and these have been greatly
welcomed by colleges.
In this submission, we will comment specifically
on OFSTED's new inspection responsibilities for post-16 education
and raise issues about the separate but apparently duplicatory
approach related to performance provider review, conducted under
the auspices of the LSC.
colleges are finding the new inspection
regime rigorous and searching but the judgements do not always
reflect the overall picture of the college;
the emphasis of the Common Inspection
Framework on the experience of the individual learner is welcomed
the size of the inspection teams
causes a great deal of disruption to colleges;
the findings of the first five inspections
give cause for concern about inspectors' consistency of judgment;
the short notice period gives colleges
inadequate time to collect information in the required format.
Information demands are still excessive;
the short timescale for the inspection
is inadequate to ensure judgements are sound;
lesson observations have focused
on the 16-18 cohort;
lesson observations have focused
on level 3 provision;
inspection reports seen so far make
very little mention of adult provision and of work at entry level
and levels one and two in colleges, even where this forms the
majority of college provision;
colleges with a high widening participation
factor do not always feel the inspection process encourages them
to provide for the most disadvantaged;
the role of the nominee is almost
impossible to do and it is most unsatisfactory that the nominee
is not allowed to be present at grading meetings.
there is a lack of clarity about
how judgements about attainment can be reached in the case of
certain types of provision;
OFSTED do not provide CVs of individual
inspectors as did FEFC. These are important for colleges;
it is important that a system of
"lighter touch" inspection is developed for those colleges
which have been shown to have good provision overall;
there is no right of reply for colleges
to challenge judgements;
colleges are given insufficient time
to read through the Pre-inspection Commentary and the draft report;
the inspection handbook provides
a helpful level of detail; and
the potential for overlap, duplication
and an unnecessary additional framework burden arising from performance
provider review should be examined.
1. Colleges are reporting that the inspection
process is being conducted in accordance with the handbook and
that the conduct of the inspection teams is professional and courteous.
Many colleges, however, especially large colleges and those with
a high widening participation factor, are concerned that the grades
and judgements do not reflect the nature of the provision as a
whole and concentrate on 16-18 provision at level three.
2. The Association and the colleges greatly
welcome the overriding focus on the experience of the individual
learner. We particularly welcome the emphasis on the experience
of the learner in the classroom or workshop, the quality of the
guidance and support received and the quality of the management
of the learning programme. We are pleased to see that judgements
on a range of cross-college aspects are now reached through assessing
their effects on the learner and that there is less emphasis on
the mere possession of policies and procedures judged in isolation
from the effect they have on the learning process.
3. Many inspection teams are very large,
with some teams having over 40 inspectors. This causes great disruption
to colleges in terms of servicing such a large number of inspectors'
individual requirements for data and providing appropriate accommodation.
In addition, there will inevitably be difficulties for the reporting
inspector in forming a coherent picture of a college from the
feedback of so many separate inspectors.
4. The findings of the first five inspections
would appear to be unrepresentative of subsequent inspections
and of the sector as a whole. We recognise that there will be
changes in emphasis while the new framework is bedding down but
feel it is vital that judgements are seen to be consistent. A
poor grade profile will have a very detrimental effect on a college
within its community and every effort must be made to ensure that
these judgements are made fairly and accurately.
5. Between six and 12 weeks' notice of an
inspection has been a very difficult timescale for colleges to
meet in the light of the data demands that have been made on them.
In some cases over 200 lever-arch files of data had to be collected.
The simultaneous audit with its own data demands has created additional
pressure and we would urge that these two processes are conducted
at separate times. There have been severe problems with the validation
of data by the local LSCs and this has created extra pressure
within the timescale.
6. The short timescale of a week for the
inspection is inadequate to allow inspectors to develop a thorough
and overall understanding of the mission of the college and the
nature of the provision of large, multi-sited colleges. Where
judgments have to be collated from large numbers of inspectors,
teams will have to begin this process fairly early in a week and
this will mean that conclusions concerning possibly 30,000 learners
or more will be reached after possibly only two days of inspection.
This is clearly not sufficient time in which to reach valid judgements
on the experience of many thousands of learners, often learning
in widely different contexts on different types of programme and
7. Lesson observations have focused disproportionately
in some colleges on the 16-18 cohort, and not reflected the amount
of post-19 work, even when the vast majority of students was aged
19+. This will clearly disadvantage some colleges whose chief
strength lies in their provision for adult students. Many general
further education colleges have in excess of 80 per cent 19+ students.
Often this provision takes place at a remote location or in the
evening or at weekends and thus will be less accessible to inspectors
because of their tight timescales.
8. Lesson observations have tended in most
colleges to focus on level three work and to give considerably
less attention to entry level work and work at levels one and
two. As with the work with adults, many colleges have particular
strengths in provision at the lower levels. As these levels are
key in meeting the government's widening participation agenda,
it is vital that colleges are given every encouragement to provide
learning at these levels.
9. As a consequence of the lack of scrutiny
of a proportionate amount of provision for adults and at entry
level and levels one and two, there are inadequate references
to these in the inspection reports. This will be unhelpful to
people making decisions about courses on the basis of reading
the inspection reports.
10. In some college inspections, it appears
that the inspection teams do not fully appreciate the colleges'
efforts to recruit those who have traditionally not participated
in education post-16. Inspectors have shown inadequate understanding
of the difficulties of retaining these students and ensuring they
succeed on their courses. It is a well documented fact that poor
previous educational achievement is a very high indicator of subsequent
lack of success. If colleges are not to be discouraged from widening
participation amongst these groups and thus playing a valuable
part in combating social exclusion, it is vital that it does not
appear that only those colleges that recruit students who are
most likely to succeed can gain good inspection reports and grades.
Inspectors need to be seen to be very well aware of the challenges
in working with disadvantaged young people and adults and ensure
that appropriate benchmarks are used.
11. The nominee has an almost impossible
task in managing the arrangements for a larger inspection team,
reading reports within a short timespan, hearing feedback from
inspectors, relaying emerging judgments to college staff and finding
additional evidence for inspectors. The nominee is not allowed
to be present at grading meetings and is thus not able to challenge
any inaccuracies or supply additional information to the team.
This may well lead to invalid judgments, especially when inspecting
a large college which the team may not have seen in its entirety.
Colleges would greatly welcome the opportunity to be represented
at these meetings as used to be permitted under the FEFC regime.
12. There is a lack of clarity about how
judgements about attainment are reached during lesson observations
in the case of certain types of provision. Each lesson is given
three grades: for teaching, learning and attainment. The attainment
grade purports to measure the standard of work of the group as
a whole against a national norm for students working at a particular
level at a particular stage of the year.
Neither inspectors nor teachers are clear about
the way the grade for attainment would be applied in the case
of classes where learners are not all working at the same level,
are not on courses lasting a year or where there is no commonly
accepted concept of what constitutes average levels of attainment
for students on that type of course. This would be true, for example,
of a basic skills class and many others where students are at
widely different stages of attainment and where it makes no sense
to grade the level of attainment of the group as a whole.
We understand that it is the intention of OFSTED
no longer to publish the attainment grades but we feel concern
that judgements will still be made about attainment, even though
their findings will not be in the public domain. We would recommend
that this information is no longer collected at all as a separate
grade and that effort is put into developing more sophisticated
value-added measures to ensure that meaningful information is
collected about the attainment of individual learners and the
progress they are making against their own goals, not against
a concept of a notional "norm" for students at a particular
13. Colleges were reassured in the past
about the experience of the inspectors by the provision of brief
CVs of each member of the inspection team. This no longer happens
in the new regime and colleges would welcome the provision once
again of these pen portraits. It is important that colleges are
reassured about the relevance of the experience of inspectors
making judgements about their provision.
14. In the light of the rigour of the first
round of the OFSTED inspection process, it is important that consideration
is given to developing a lighter inspection process in subsequent
rounds for those that have shown they are providing a high quality
learning experience within well led and managed colleges. The
inspection and audit burden in colleges is widely considered to
be excessive and it is important that colleges are allowed a greater
element of control over ensuring quality improvements once they
have proved that they are capable of managing this process for
15. Colleges cannot now challenge inspection
judgements as they could under the appeals procedure of the FEFC.
It is most important that there is such a system to allow for
transparency of judgements and the rights of the college to defend
its reputation against perceived unjust grading decisions.
16. Colleges are given very little time
to read through the Pre-Inspection Commentary which is a vital
pre-inspection report and contains inspectors' key findings based
on the data they have received prior to the inspection. It gives
an indication of areas in which they will be looking to find corroborative
evidence and will contain a hypothesis which the inspection process
will seek to evidence. In some cases colleges were given this
report on day one of the inspection when it was very difficult
for the nominee to find the time to give it appropriate scrutiny
to identify aspects which the college might want to challenge.
It is vital that the starting point of the inspection is an agreed
one and on the first day of an inspection the nominee is extremely
busy and does not have the time to give the commentary the attention
it needs. Some colleges were also only given a few hours to read
the draft report and to challenge any inaccuracies. This is clearly
17. The inspection handbook is helpful to
colleges who have reported that it provides a useful guide to
the process and to the criteria used by the inspectorates when
making their judgements.
18. Quality improvement is an essential
goal for all providers. The Provider Performance Review should
support this process. Provider Performance Review is the responsibility
of the LSC not Ofsted. It would be expected that the Provider
Review would complement, but not duplicate, the inspection process.
The Association is concerned that this does not always seem to
be the case. The AoC has expressed a number of concerns to the
LSC about the Provider Review process as it has been developed
Some of our concerns about the review include:
that it risks duplicating other review
processes such as inspection and audit;
that it is unnecessarily bureaucratic,
involving as it does three major reviews each year supplemented
by monitoring visits;
that it has been inconsistently conducted
by local LSCs, in some instances resulting in outcomes of questionable
validity, often because the necessary expertise in further education
that it relies on an inappropriate
grading system which mimics that used for inspection and implies
judgements being made about the quality of provision that are
properly the responsibility of the inspectorates; and
that it lacks effective mechanisms
for challenging review outcomes where these are believed to be
unfair or in error.
The Association believes that the role of the
Provider Performance Review should be reconsidered, and that duplication
should be avoided so that the proper role of the review, to support
providers in enhancing their overall level of quality provision,
can be developed.
The Association feels that, although the Common
Inspection Framework provides a sound basis on which to conduct
an inspection of colleges, the process as implemented in the inspections
of the first two terms requires modification if the efforts of
colleges to provide for very large numbers of adults, reach disadvantaged
groups and to attract non-traditional learners is not to be sabotaged.
The inspection findings must give a clear picture of the totality
of the college's work and the range and diversity of provision
which exist in most FE colleges and OFSTED must allocate inspection
time to all age groups and levels of work in proportion to their
existence in the college. The model adopted appears to cast the
school sixth form as an ideal and to judge colleges against how
well they conform to that model. The lack of recognition of adult
work and of work at entry and levels one and two will not encourage
colleges to attract these groups which are so vital to widening
participation and combating social exclusion. Indeed, if traditional
16-18 work continues to receive a disproportionate amount of inspectorate
attention, colleges may withdraw from these other more problematic
areas of work.