Select Committee on Education and Skills Appendices to the Minutes of Evidence


APPENDIX 16

Memorandum from the Association of Colleges (OFS 14)

  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.

SUMMARY

    —  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 by all;

    —  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.

SUBMISSION

  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 site.

  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 level.

  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 themselves.

  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 inadequate.

  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 so far.

  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 is lacking;

    —  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.

CONCLUSION

  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.

November 2001


 
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