Memorandum from The National Union of
Teachers (OFS 09)
This submission from the National Union of Teachers
focuses on the OFSTED proposals for school inspections from 2003
as set out in the document "Improving inspections, improving
schools". The submission addresses also issues of concern
to OFSTED raised by the DfES White Paper "Schools Achieving
Success", the Education Bill and other recent Government
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:
Did the Secretary of State define
the boundaries of the OFSTED consultation document and, if so,
what aspect of inspection would the Chief Inspector have liked
to see reviewed?
Will OFSTED agree to put in place
annual review arrangements which maintain a running check on the
effectiveness of the proposed changes for school inspections?
Would the Chief Inspector expand
on the basis on which OFSTED will select schools for inspection
and what criteria will be used to decide whether or not a school
is selected for a `full' or a `short' inspection?
What assurances will the Chief Inspector
give that inspectors will be prohibited from "grading"
and identifying individual teachers on an informal basis?
In the light of the Government's
review of teacher workload and PricewaterhouseCoopers' proposal
that OFSTED should inspect the application of measures to reduce
workload does he think such a proposal will lead to a significant
reduction in workload? If he does, can he describe how he will
implement such a proposal?
Would the Chief Inspector agree to
work with the DfES to produce guidance to head teachers which
discourages unnecessary pressure and bureaucracy being placed
Would the Chief Inspector acknowledge
the need for sensitivity in the use of value-added and benchmark
data in relation to school evaluation?
Are all members of every inspection
team required to undergo a period of training annually? How long
is that training and in what form does it take?
What assurances can the Chief Inspector
give that inspectors of early years provision - in maintained
schools as well as in private and voluntary settings - are up
to the job?
Would the Chief Inspector commit
himself to a more fundamental review of the arrangements for inspection
of special schools sometime in the near future?
Will OFSTED ensure parity between
schools and colleges in implementing pupil questionnaires on an
optional basis only?
What plans, if any, are there to
review the current OFSTED Complaints Procedure?
Can the Chief Inspector report on
the ability of schools to protect pupils from offensive materials
on the Internet and from undesirable external contacts? Is he
satisfied that the Government has done enough to raise teacher
awareness, confidence and skills in the safe and effective use
of the Internet to support pupil's learning?
Would the Chief Inspector not agree
that if every teacher was provided with his or her own portable
or personal computer, as a `tool of the trade' then more significant
progress would be made?
Bearing in mind the additional challenges
faced by some secondary schools does the Chief Inspector think
that they should receive additional support rather than threats
What assurance can OFSTED give that
post-16 inspections will give equal value to all courses not just
those that lead to formal qualifications or specific qualifications
that acquire higher levels of funding?
1. This submission from the National Union
of Teachers focuses on the recent OFSTED proposals for school
inspections from 2003 as set out in the document "Improving
inspections, improving schools". It also addresses issues
of concern to OFSTED raised by the DfES White Paper "Schools
Achieving Success", the Education Bill and other recent Government
2. The recently published Demos report,
"Classroom Assistance", commissioned by the NUT, is
the latest in a long line of studies which emphasise 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 are based entirely
on securing accountability accompanied by punitive consequences
for those schools which have been deemed to require special measures.
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 secure their commitment to the evaluative process. The NUT
is concerned that OFSTED's proposals do not redress sufficiently
the balance between internal and external evaluations.
5. The NUT hopes, however, that the shift
in emphasis towards self-evaluation and other positive proposals
within the consultation document will, in fact, contribute more
constructively to school improvement and teacher morale. In this
context, the NUT notes the statement "we see no need at
this stage to alter the fundamental structure of the arrangements
put in place in 1993" within paragraph five of the recent
OFSTED consultation "Improving inspection, improving schools".
The history of school inspection arrangements in the past decade
is that they have been subject to evolutionary change rather than
6. Yet towards the end of 2000 and in the
first part of this year there were statements made by various
policy influencers, and even the HMCI himself, which led many
in education to believe that a more substantial review would be
undertaken. In February journalists were reporting a "radical
shake-up of the system" and an "inspection overhaul".
Did the Secretary of State define the boundaries of the OFSTED
consultation document and, if so, what aspect of inspection would
the Chief Inspector have liked to see reviewed? 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?
A MORE FLEXIBLE
7. OFSTED has proposed a "more flexible
inspection system". The NUT believes that the application
of a flexible inspection system to primary schools would be more
responsive to the relatively integrated nature of the primary
curriculum, compared to that of secondary schools. A common approach
is essential, however. Such an approach would require the further
development work identified for the flexible inspection system
for secondary schools. In addition, the suggestion that there
might be "a small proportion of longer inspections"
for primary schools undermines the common approach proposed by
OFSTED itself. Would the Chief Inspector expand on the basis
on which OFSTED will select schools for inspection and what criteria
will be used to decide whether or not a school is selected for
a "full" or a "short" inspection?
8. The proposal to stop providing profiles
of grades of teaching to individual teachers and head teachers
is welcome. The current arrangements confuse evaluation of teaching
with the evaluation of an individual teacher. The intention by
OFSTED to "promote a constructive dialogue between inspectors
and teachers on the quality of teaching observed, rather than
a potentially unproductive debate about grading" (paragraph
29) is a step in the right direction. The requirement to give
profiles on individual teachers to head teachers for management
purposes, albeit in confidence, has always provided de facto,
individual inspectors a key responsibility for the performance
appraisal of teachers.
9. There remains, however, a danger of inspectors
informally providing head teachers, or members of governing bodies,
information on teacher grades without individual teachers' knowledge.
What assurances will the Chief Inspector give that future advice
to inspectors will prohibit such activity?
10. Paragraph 10 of the OFSTED consultation
document refers to an increasing reliance by inspection teams
on value-added data.
11. 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 NUT also welcomes statements from the Chief Inspector
"Let us not value only that which we can measure. Education
is about a great deal more than that. If we ever lose sight of
that then I want an early bath".
On the other hand, absence of value-added progress 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 health
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?
12. The NUT is concerned also about inspectors
making comparisons between schools which are deemed to be similar
through information provided by 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 inadequacies of such data
in making such comparisons?
13. The consultation document recognises
that, "some school inspections do not yet meet all these
requirements [set out by OFSTED in paragraph 8] as well as they
might". This is important because, although most schools
do not have disputes with inspection teams which they would wish
to pursue, there is still a view amongst many head teachers and
teachers that they can be lucky or unlucky with the teams contracted
to inspect their schools.
14. The NUT notes that the number of companies
responsible for providing inspections has reduced but believes
that the contracting out arrangements, subject as they are to
the vagaries of the market, are prone to shortages and inconsistencies
in quality. The NUT would urge OFSTED to review fundamentally
the current arrangements with a view to bringing the existing
15. The consultation document talks about
investment in "quality control" and an "annual
training plan". Are all members of every inspection team
required to undergo a period of training annually? How long is
that training and in what form does it take?
16. The recent expansion of OFSTED's remit
has meant that the `nursery education' inspectors are not needed
because of the requirement on OFSTED to take on all 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.
17. 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 eyes of the
inspector. The composition of inspection teams must, therefore,
be suitable - i.e. 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 schools
as well as in private and voluntary settings - are up to the job?
18. For teachers in special schools and
pupil referral units, it is a matter of continuing frustration
and concern that a disproportionately high number of inspection
teams do not understand the specific needs of the pupils they
teach. These concerns are strongest amongst teachers of pupils
with emotional and behavioural difficulties. For those teaching
in special schools and pupil referral units, it is clear that
the main problem is that many inspectors simply do not understand
the need for teachers to respond flexibly to sharp and unpredicted
changes in medical conditions or behaviour. Many teachers, particularly
those in EBD schools and pupil referral units, believe that the
inspection framework should be changed and a requirement put in
place that the majority, if not all, inspectors inspecting their
schools should have had a practical and recent background in teaching
in their area.
19. The NUT would call for a separate review
of inspections of special schools and pupil referral units. The
current proposals, therefore, to "maintain a mix of short
and full inspections for special schools" (paragraph 30)
simply misses the point. Would the Chief Inspector acknowledge
that this is an issue and commit himself to a more fundamental
review of the arrangements for inspection of special schools sometime
in the near future? In the meantime, OFSTED must ensure that
via guidance and training, inspection teams involved in inspection
of special schools apply the inspection framework flexibly, according
to the particular characteristics of the individual school or
unit. What, if any, specific recruitment practices and training
opportunities will be put in place to ensure that OFSTED makes
"the most positive and effective contribution" to the
improvement of special schools?
20. The NUT welcomes any proposal that will
genuinely reduce the levels of bureaucratic burdens associated
with inspections. OFSTED's commitment to reducing the burden of
inspection for primary schools is particularly welcome. There
is little evidence, however, that teachers facing a short inspection
currently undertake less preparation than those undergoing a full
inspection. The consultation document fails to acknowledge the
pressure on schools generated by government. Although OFSTED provided
advice on the literacy and numeracy strategies at Key Stages 1
and 2, many head teachers still remained under the impression
that: (a) the strategies were compulsory; and (b) local education
authority target setting and proposals for lesson planning were
also compulsory. OFSTED needs to provide clear and specific guidance
on such issues, including on the implementation of the Key Stage
3 strategy which emphasises the voluntary nature of that strategy.
The purpose of planning and assessment should be to benefit children's
learning. Lengthy and beautifully presented lesson plans should
not be seen as necessary evidence for external monitoring purposes.
Would the Chief Inspector agree to work with the DfES to produce
guidance to head teachers to this effect?
21. Prior to the publication of a consultation
document, there were suggestions by OFSTED that, as a contribution
to reducing bureaucratic burdens on schools, OFSTED would include
in the framework a requirement on inspectors to inspect the contributions
of head teachers to achieving a reasonable work-life balance for
staff. That this proposal appears to have disappeared is regretful.
Recent OFSTED advice to inspectors states
"Inspectors must be alert to the fact that
head teachers are concerned about the weight of bureaucracy on
schools at the moment. Inspectors should report on the nature
and extent of the bureaucratic demands on schools and indicate
the most common sources of these demands. These must be explored
with the head teacher and reported in the relevant section of
the report. Inspectors need to take account of any other barriers
to efficient development.".
Will this issue remain a matter of guidance
or will there be a more explicit reference to reasonable levels
of workload within the OFSTED framework itself? In the light of
the Government's review of teacher workload and PricewaterhouseCoopers'
proposal that OFSTED should inspect the application of measures
to reduce workload does he think such a proposal will lead to
a significant reduction in workload? If he does, can he describe
how he will implement such a proposal?
22. 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's proposal to pilot questionnaires
for 11-16 year olds is, however, 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 per cent 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.
23. 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.
24. Parents and their children have more
rights and choices than they have had previously. Rights should
be accompanied by responsibilities and currently the perception
of teachers is that many parents do not understand their responsibilities
or carry them out.
25. 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.
26. 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.
27. 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 the pilot goes ahead,
at the very least the use of questionnaires should be optional,
with a decision taken by teachers on their use. Will OFSTED
ensure parity between schools and colleges in implementing pupil
questionnaires on an optional basis only?
28. In her speech to the LGA last week (22
November) the Secretary of State acknowledged the difficulties
faced by schools in `challenging circumstances'. She spoke about
how these schools were feeling "squeezed" and teachers
were under "great pressure" as a result of external
social pressures. She emphasised the number of barriers to learning
that exist for pupils from poorer and `lower class' families.
Yet on the same day the newspapers were full of headlines about
the seventy six schools facing closure for not meeting the government's
target of 15 per cent 5A* C GCSEs. The head teacher from
William Crane School in Nottingham summed up the frustration of
head teachers and teachers in these schools "If you put
pressure on schools like this, then staff who are working very,
very hard to turn the place round may decide that there are easier
ways of making a living". Bearing in mind the additional
challenges faced by some secondary schools does the Chief Inspector
think that they should receive additional support rather than
threats of closure?
POST -16 INSPECTIONS
29. From September 2001, post-16 provision
has received greater attention as a result of the extended remit
given to OFSTED and the establishment of Learning and Skills Councils.
The NUT is concerned about the impact of the changes in the ways
in which post-16 provision is monitored on the learning opportunities
for all pupils. What assurance can OFSTED give that post-16
inspections will give equal value to all courses not just those
that lead to formal qualifications or specific qualifications
that acquire higher levels of funding?
30. The efficiency and efficacy of the current
Complaints Procedures needs to be tightened up. There is little
redress currently for teachers where they consider that inspection
judgements of their teaching to be unfair. OFSTED advises that:
"OFSTED cannot second-guess judgements made during the week
of the inspection" (Making Complaints to OFSTED 1998), is
too restricted. It should be made abundantly clear by OFSTED that
all aspects of inspections are subject to independent scrutiny
and accountability through a fair and open complaints procedure.
The current arrangements suit OFSTED in that the exercise is drawn
out over such a long period of time that schools are often discouraged
from continuing with the compliant, however, justified it is.
The consultation document does not make any reference to OFSTED's
complaints procedures or the role of the adjudicator. What
plans, if any, are there to review the current Complaints Procedure?
ICT IN SCHOOLS
31. In terms of lottery funded ICT training
OFSTED recently advised inspectors that "a number of problems
with the implementation of some of the NOF training. Inspectors
should be sensitive to the fact that schools may not have benefited
sufficiently, even though they have participated."
32. In the same guidance OFSTED advises
inspectors to "make sure that schools take reasonable
steps to ensure that their pupils are protected from offensive
materials on the Internet and from undesirable external contacts,
for example through e-mail or non-educational chat rooms".
Can the Chief Inspector report on the ability of schools to
protect pupils from such dangers? Is he satisfied that the Government
has done enough to raise teacher awareness, confidence and skills
in the safe and effective use of the Internet to support pupil's
33. In the Chief Inspector's latest Annual
Report he reported that the provision of ICT varied enormously
and that in too many schools the quality of ICT teaching and learning
was found by inspectors to be unsatisfactory. He has acknowledged
that the effectiveness of teachers' use of ICT is dependent on
levels of resourcing, the availability of technical support and
the quality of any training received. Would the Chief Inspector
not agree that if every teacher was provided with his or her own
portable or personal computer, as a "tool of the trade"
then more significant progress would be made?
National Union of Teachers
1 TES 16 February 2001. Back
Pages 11 and 12, Update 36: OFSTED advice to inspectors 2001. Back
Pages 16-18, Update 36: OFSTED advice to inspectors 2001. Back