APPENDIX 5
Memorandum submitted by NASUWT (National
Association of Schoolmasters Union of Women Teachers) (OFS 05)
SUMMARY
1. The submission by NASUWT relates to all
aspects of the work of OFSTED. In particular, the Association's
evidence to the Select Committee recommends that:—
— a fundamental review of the school
inspection framework is needed to ensure OFSTED's relevance within
a changing educational context and to engender a level of professional
confidence in the inspection process;
— a detailed cost-benefit assessment
of OFSTED's work should be undertaken with a view to supporting
the future development of an efficient inspection process which
is coherent and takes account of other existing mechanisms for
school improvement;
— the inspection system should contribute
to reducing the problems of excessive workload and unnecessary
bureaucracy in schools which operate to the detriment of effective
teaching and learning.
2. The Association's submission addresses
a number of themes relevant to OFSTED's work:
— the future work of OFSTED
— OFSTED's accountability
— establishing work/life balance for
teachers
3. NASUWT would be pleased to provide further
information or commentary to the Select Committee upon request.
OFSTED'S CURRENT
WORK
4. NASUWT has previously indicated its view
that a fundamental review of the school inspection framework is
needed. Such a review was previously offered by the previous Chief
Inspector of Schools, Mike Tomlinson. However, a review of the
purpose, principles and future of inspection has not transpired;
instead, OFSTED has remained committed to making relatively minor
adjustments to the Inspection Framework, rather than engaging
in a much needed and open dialogue about the purpose and contribution
of inspection.
5. There remains a need to address a most
fundamental question: namely, the future purpose of, or rationale
for, school inspection. This must be addressed in a manner which
takes account of the prevailing context where a number of mechanisms
exist within schools, as well as locally and nationally to support
school improvement.
6. NASUWT finds that OFSTED has made a contribution
to the development of a national comparative database of school
performance based on the process of a nationally driven system
of school inspections. Indeed, the broad outcome of an inspection
may be anticipated in advance of a visit to a school. The existence
of such comparative information makes it possible for the conduct
of detailed school by school comparisons to be undertaken, without
the need for further expensive and time-consuming visits to be
made to individual schools.
7. A review of the arrangements for school
inspection must take account of the need for public accountability,
but within a context in which a thorough assessment is made of
the financial and professional costs arising from inspection.
Research undertaken by NASUWT has demonstrated that the inspection
arrangements have delivered poor value for money. It is also clear
that the impact upon teachers' lives, morale and retention has
been significant and adverse.
8. Critical accounts of the OFSTED approach
indicate that it is over-extended in its ambitions for supporting
the work of schools. The inspection framework confuses the separate
tasks of quality assurance, quality control, audit, assessment
and support for institutional and individual learning/development.
This has led to inconsistency of practice which has undermined
confidence in the school inspection regime.
9. Moreover, the inspection process has
failed to:
— respond adequately to the specific
and changing circumstances within individual schools;
— take account of the qualitative or
process issues that underpin effective teaching and learning;
— take into account the specific contexts
and circumstances in which individual schools operate; and
— gain the support and confidence of
the majority of teachers.
10. Furthermore, the conduct of inspection
is:
— overly dependent on the use of unreliable
and subjective perceptions sourced from the practice of classroom
observation;
— unduly stressful for school staff
and pupils;
— widely perceived as punitive, demoralising
and demotivating;
— unpopular with education professionals;
— variable between different inspection
teams; and
— undermined by the failure to ensure
that inspectors have adequate expertise and recent experience
in the subjects and phases they are observing.
11. Despite some recent improvements, the
majority of teachers continue to approach the OFSTED inspection
process with less than a positive attitude. There is little doubt
that responsibility for this lies with OFSTED and the Government
and their contribution to the promotion of a crude and simplistic
discourse on educational standards in this country, which has
not hesitated to castigate the efforts of schools and teachers
alike.
12. NASUWT undertakes regular surveys of
teacher workload. Consistently, these surveys have identified
that for headteachers and classroom teachers one of the greatest
sources of additional workload is the OFSTED inspection process.
There is no doubt that the stress and diversion of effort into
the preparation for inspection, the "performance" expected
during the inspection period itself, and the conduct of the post-inspection
review has had a major impact upon both the professional and personal
lives of teachers.
13. As well as the cycle of school inspections,
OFSTED carries out inspections into other areas which can, and
frequently does, result in additional visits from inspectors.
The problem of inspection overload must be addressed as a matter
of urgency.
14. Furthermore, the Government Circular
2/98, "Reducing the Bureaucratic Burden upon Teachers"
highlighted the need for schools and OFSTED to reduce the workload
of teachers relating to inspections. In spite of the Circular
there is little evidence of a reduction in workload.
15. NASUWT has received many complaints
from teachers about the lack of professionalism, expertise and
qualifications of some inspectors. Many of these complaints focus
upon the mismatch of expertise and experience within the sector
and/or the subject being inspected. Examples cited include inadequate
knowledge and experience within inspection teams of primary teaching,
special educational needs, and teaching English as an additional
language.
16. In addition, NASUWT has received a constant
stream of reports regarding:
— the lack of transparency in the work
of the inspection teams;
— the lack of consistency in the oral
feedback given to classroom teachers about their performance;
— the lack of consistency in inspection
judgements;
— the lack of consistency in the time
spent in classroom observation;
— the failure of some inspectors to
observe the guidelines regarding the confidentiality of feedback;
and
— the failure of some inspection teams
to follow the Code of Practice.
17. Teachers have also reported a disparity
between the judgements of OFSTED, HMI and LEAs, which has led
to confusion, frustration and disillusion with the system. This
lack of consistency must be addressed by establishing a unified
system of inspection and support.
18. Moreover, with as many as 14,000, mostly
part-time, inspectors working for over 240 separate contractors,
it is inevitable that procedures and judgements vary significantly.
19. One of the most frustrating and unfair
aspects of the OFSTED inspection process for teachers is the inability
of schools or individual teachers to have redress against damaging
and inaccurate judgements. Although there is a complaints procedure,
the integrity of it must be questioned. The redress offered to
schools where an appeal is upheld is the threat of another inspection.
It is hardly surprising that teachers have such little confidence
in the system.
20. The cost associated with the OFSTED
inspection regime is a major area of concern. The money invested
annually in OFSTED far outstrips the investment made to comparable
areas of public sector audit, such as the work undertaken by the
Audit Commission.
THE FUTURE
WORK OF
OFSTED
21. NASUWT asserts that there are undoubted
advantages in a system of rigorous quality management of education
services. The case for some sort of independent audit to make
schools accountable and to facilitate educational and organisational
improvement is not at issue. NASUWT is not opposed to an inspection
process. However, the process should be supportive as well as
inspectorial. It remains to be demonstrated that the most appropriate
system is in place.
22. There has been a massive increase in
inspection activity within the pre- and post-16 system which has
engendered confusion, complexity, duplication and overload.
23. There are substantial direct and hidden
costs associated with the current inspection regimes which are
not matched by the benefits of inspection. A full cost benefit
analysis of the OFSTED inspection system must be undertaken as
a matter of priority and as a basis for securing the requisite
levels of professional confidence.
24. There is a considerable body of independent
research that is broadly critical of the design, operation and
effectiveness of OFSTED. In spite of recent reforms to the inspection
framework, significant concerns remain about the scope of OFSTED's
role and the conduct of inspection teams on the ground.
25. The Association proposes a number of
changes to the inspection system, as follows:
— Rationalise the various inspections
frameworks in a way which delivers real benefits for schools and
colleges and which minimises the burdens on institutions;
— Replace the current private contracting
system with a smaller, permanent group of professional, qualified
and trained inspectors who have recent and relevant experience
of teaching;
— Introduce agreed criteria for identifying
those schools with problems and where an inspection is appropriate,
working within a newly agreed framework;
— Provide specialist advisers to work
closely with LEA inspectors to support school improvement;
— Ensure that non-statutory elements
are removed from the inspection schedule;
— Ensure that a comprehensive and appropriate
range of equalities indicators is used to inform the inspection
process;
— Abandon the use of surveys of student
opinion;
— Introduce an independent body to
which OFSTED would be accountable; and
— Introduce a fully independent appeals
body with powers of redress.
26. There are further critical issues to
be addressed in respect of:
— the relationship between school inspection,
self-evaluation and performance management;
— the role of OFSTED in assuring social
inclusion and anti-discrimination;
— the quality of the school inspections
process and its implementation; and
— the standard and consistency of inspection
reports.
OFSTED'S ACCOUNTABILITY
27. NASUWT remains unconvinced by claims
made about the merits of the school inspection arrangements in
England as the basis for raising educational standards. Many teachers
and parents would recognise that educational standards are not
improved simply by measuring what takes place within schools.
NASUWT asserts that it is due to the hard work and professionalism
of teachers that improvements in teaching and learning have been
secured.
28. Nevertheless, it is essential that OFSTED
is held accountable for its work, and that it operates on the
basis of a sound evidence base gained from its work in the field.
In particular, it is essential that OFSTED report annually on
the extent to which its work adds value to the existing arrangements
for accountability, performance management and raising standards
in schools.
29. The real costs of inspection must be
balanced against the benefits derived to each school. This relationship
is far from clear. Research undertaken by NASUWT has demonstrated
that inspection arrangements have delivered poor value for money,
whilst the impact upon teachers' lives, morale and retention has
been significant and adverse. NASUWT calls for a review of the
financial, professional and educational costs of the burgeoning
inspection system to be undertaken, the findings of which should
be subject to public scrutiny.
INSPECTION BURDENS
30. There now exists a mass of school performance
information, targets, annual reporting arrangements and awards
to schools and individual teachers which deliver a more than adequate
level of public scrutiny and accountability, and which also assists
the process of continuous improvement in teaching and learning
within institutions. Nevertheless, and within this context, there
has been an increase in the inspection burden on schools and teachers.
NASUWT strongly asserts that the Government and OFSTED must act
with courage to better exploit the high quality data that is available
in relation to individual schools and by the improved use of value-added
school performance data.
31. NASUWT asserts that the current inspection
burdens have engendered confusion, complexity, duplication and
overload. The Association would prefer a radical alternative model
to be established which would substantially reduce these burdens.
Such a model should:
— significantly reduce the amount of
inspection time in individual schools;
— focus on assessing compliance with
statutory requirements;
— review the efficiency and effectiveness
of administrative and bureaucratic systems within individual schools;
— review the impact of national requirements
and statutory guidance on teacher workload and on teaching and
learning outcomes;
— make improved use of existing absolute
and value-added school performance data sets as a substitute for
school inspection visits;
— be supportive of the work of teachers
and help foster a culture of learning within schools;
— be accountable in public and professional
terms; and
— operate within a low bureaucracy
framework.
ESTABLISHING WORK/LIFE
BALANCE FOR
TEACHERS
32. NASUWT calls upon the Government to
introduce a new set of requirements which will ensure the issue
of establishing an appropriate work/life balance for teachers
as a crucial aspect in tackling the important problem of teacher
workload. This was a key recommendation of the STRB supplementary
report on teacher workload which NASUWT endorses fully.
33. NASUWT asserts that OFSTED must be expected
to recognise and address the concerns set out by the Government
and the teaching profession on the importance of reducing workload
and excessive working hours of teachers. This highlights the importance
of an inspection process that focuses on the effectiveness of
leadership and management in schools. Leadership and management
play an important role in terms of staff motivation and retention
which are critical to raising educational standards. NASUWT believes
that the Inspection Framework should set explicit expectations
for headteachers and governors in ensuring work/life balance through
arrangements to transfer from teachers tasks which are not appropriate
to their role, reduce and limit bureaucracy, limit working hours,
and any additional strategies agreed nationally with the teacher
unions as part of the workload reduction/remodelling agenda.
34. The Association believes that OFSTED
should be required to consult with the trade unions once a national
package has been agreed in respect of teacher workload and working
hours.
SELF-EVALUATION
35. NASUWT finds deeply unhelpful OFSTED's
continued promotion of school self-evaluation as a means to reviewing
school effectiveness. Moreover, OFSTED has adopted a position
on this issue which is at best ethically dubious, given its attempts
to market its own self-evaluation model and commercial products
to schools.
36. NASUWT maintains that OFSTED, as the
inspectorate body, should be concerned to evaluate the effectiveness
of arrangements for self-evaluation which have been adopted by
schools; and, in particular, to test the impact of the same on
educational standards and teacher workload.
37. Schools are neck-deep in the administration
of internal systems of planning, target setting, benchmarking,
analysis and reviews of individual and institutional performance.
The continued promotion of self-evaluation is becoming increasingly
superfluous and, evidence suggests that this strategy has served
to increase the bureaucratic burdens on schools.
38. Moreover, existing models of self-evaluation
are overly bureaucratic, workload intensive and require a range
of skills which is not immediately available to schools. Feedback
to NASUWT demonstrates that the hidden costs associated with the
conduct of self-evaluation are considerable and neither does the
mechanism deliver rigorous public accountability.
39. NASUWT wishes to reiterate its deep
concern that OFSTED has chosen not to review the effectiveness
and impact of its own self-evaluation models. The Association
believes that the continued promotion of self-evaluation will
serve to add a further and unnecessary layer of bureaucratic administration
within schools.
EQUALITY AND
DIVERSITY
40. NASUWT has argued consistently that
the current model of inspection fails to recognise the different
challenges that schools face with regard to pupil intake (particularly
the range of learning abilities), poverty and differing levels
of parental and community support. It is unclear that the operation
of the inspection process gives adequate recognition to the contextual
differences between schools which is so critical to determining
the outcomes that can be achieved by schools. It is welcome that
OFSTED now acknowledges the importance of socio-economic factors
as a determinant of school performance. It is essential that the
Chief Inspector makes clear how such a recognition will in future
impact on the conduct of school inspections and on the judgements
reached by inspection teams.
41. OFSTED has a critical role to play as
a public body listed under the Race Relations (Amendment) Act
2000. Importantly, OFSTED has invested in providing guidance and
training for inspection teams on educational inclusion/racial
equality matters. This follows serious criticisms by the Commission
for Racial Equality and other bodies regarding OFSTED's apparent
failure to address effectively issues of racial equality within
school inspection reports. Given the new duties that apply to
OFSTED under the amended Race Relations legislation, it is essential
that OFSTED:
— consult openly on the development
of its racial equality plan;
— identify and report on the arrangements
it will put in place to assure racial equality in all aspects
of its work;
— indicate how it will consult with
teachers and the wider community in the ongoing development of
its racial equality scheme; and
— report annually on its racial equality
practice and the outcomes of its work in addressing racial inequality
within its own structures and within those bodies subject to inspection.
42. The new requirements imposed under the
Race Relations (Amendment) Act 2000 should not overshadow other
equalities considerations; namely, the promotion of gender equality,
tackling homophobia and religious intolerance, and the need for
schools to meet their statutory duties under the Special Educational
Needs and Disability Act. OFSTED must report on its work in these
other areas of equality, and take full account of the wider equalities
agenda in the preparation of inspection reports.
43. NASUWT believes that the arrangements
for the conduct of Section 10 inspections must be adjusted to
take proper account of the needs of special schools and pupil
referral units. These provisions are disproportionately subject
to negative inspection judgements, despite the perceived quality
of the service they offer to young people. There remains a danger
that the standards used in respect of mainstream provisions are
applied inappropriately in the case of these specialist provisions.
PERFORMANCE MANAGEMENT
44. The introduction of performance management
in schools has a number of implications for the operation of the
school inspection system. At its most rudimentary, it requires
that OFSTED consider the operation of performance management in
schools and comment on its effectiveness. However, and more significantly,
performance management, where it is operating effectively, should
reduce the requirement for school inspection visits. NASUWT believes
that a detailed consultation is required on the criteria to be
used in the evaluation of performance management in schools and
the implications of performance management for the future scope
and focus of school inspections.
TRANSPARENCY
45. NASUWT welcomes the commitment made
by OFSTED that inspectors should brief school staff on the inspection
process and their involvement in it. This is particularly important
in helping to demystify the process of inspection, allaying the
fears of staff and should serve to enhance the transparency and
professional ownership. It is important that a meeting with school
staff takes place prior to the conduct of the inspection and on
completion of the draft inspection report.
46. NASUWT asserts that improved dialogue
is needed at all stages within the inspection process. This extends,
in particular, to the feedback afforded to teachers after their
practice has been subject to observation by an inspector. All
too often, teachers receive little by way of constructive feedback
on how the quality of their teaching could be improved. The abolition
of the grading process should constitute an important development;
however, and in order to engender professional confidence, it
must be the case that individual teacher profiles/grades should
be used strictly for the purpose of informing overall judgements
on the quality of teaching across the school/subject/phase, and
should not be disclosed to any party within the school.
POST-16 INSPECTION
47. Further clarification is needed on the
operation of the 14-19 inspection framework and its potential
impact on schools and on the workload of teachers. The 14-19 Green
Paper and the Education Act 2002 signal an important move towards
a 14-19 education framework for young people. The changes proposed
are highly significant; however, NASUWT is concerned that the
implementation of many of these changes will result in increased
inspection burdens on schools. It is essential that this does
not extend the burdens on schools.
48. NASUWT has recognised that the inspection
burden has increased rapidly. There is a serious problem of duplication
for those schools unfortunate enough to be subject to multiple
school, LEA, area based, and other focused inspections. This has
generated unnecessary levels of stress for teachers and students
alike. The problem of inspection overload must be addressed urgently
as a central part of the Government's strategy for sectoral coherence.
49. The relationship between inspection
judgements/reports and proposals for the reorganisation of 16-19
provision within an area must be made clear. This is a matter
for OFSTED to address in conjunction with the Learning and Skills
Council, the DfES and LEAs and in consultation with trade unions.
50. There is a need for clarity on the operation
of the 14-19 inspection framework and its potential impact on
schools and on the workload of teachers. It is essential that
OFSTED/ALI develop and consult on a strategy to rationalise the
various inspection frameworks in a way which delivers real workload
gains for teachers.
LEA INSPECTION
51. NASUWT recognises the statutory basis
for the inspection of LEAs and the contribution of an external
inspections process in helping to raise standards of educational
provision. LEAs should play a key role in guiding and supporting
the work of schools and in helping to raise standards of teaching
and learning. However, in recent years, many LEAs have been less
equipped to fulfil this function as a result of increased financial
delegation to schools, the impact of out-sourcing of functions,
and as a result of a plethora of legislative measures which have
been taken by Government to reduce the extent of LEA powers for
intervention. Indeed, the provisions regarding earned autonomy
as set out in the Education Act 2002 will further weaken the control
of individual LEAs in the running of schools. Moreover, in many
areas, LEAs capacity for strategic intervention to support schools
in need has been compromised as a result of a number of recent
policy changes.
52. Given this context, the Association
believes that it is essential to extend the debate about the purpose
and value of a comprehensive programme of LEA inspection which
continues to test the performance of LEAs against an outdated
set of performance criteria. Moreover, the activity and contribution
of other bodies involved in running LEA services and those companies
to be established/engaged in the provision of goods and services
to schools should also be subject to a more rigorous quality assurance
scrutiny, undertaken by OFSTED or other suitable body.
September 2002
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