Memorandum submitted by the Secondary
Heads Association (SHA) (OFS 5)
1. The Secondary Heads Association represents
over 11,000 members of leadership teams in maintained and independent
schools and colleges throughout the UK. Our members are clearly
very directly affected by the work of Ofsted.
2. There were serious weaknesses in the
Ofsted framework that came into force 12 months ago, though SHA
members were somewhat reassured by the updates that have come
from Ofsted since.
3. SHA broadly welcomes the proposals for
the next set of changes in Ofsted's approach, but our members
remain suspicious of the organisation's capacity to implement
the principles set out in them.
COMPLAINTS PROCEDURES
4. We have significant concern with a solely
paper based system which promotes significant delays, added stress
and arguably miscarriages of justice. Justice delayed is justice
denied.
5. There is a real need for early intervention
along the lines of a hotline or panel manned by the most experienced
practitioners.
6. SHA would value the opportunity to work
with Ofsted on the development of a more responsive, user-friendly,
but still rigorous complaints procedure to accompany inspection
in the future.
THE IMPACT
OF INSPECTION
AND THE
ROLE OF
THE SCHOOL
7. The Future of Inspection consultation
paper makes a number of assertions about the conduct of inspection,
their impact on standards and the role of schools in the bureaucracy
of inspection with which SHA cannot wholly agree.
8. While it may be true that inspection
practice has recently become more consistent and effective, this
view was not borne out by the experience of many schools inspected
under the new framework introduced in 2003.
9. SHA disagrees strongly with the assertion
that schools are responsible for the bureaucracy associated with
inspection. Faced with an evidence-based inspection process and
the often painful public experience of its application, schools
have simply responded to the demands of Ofsted.
10. SHA knows of no secure research evidence
that reveals any direct correlation between Ofsted, examination
improvement and the raising of standards.
INTELLIGENT ACCOUNTABILITY
11. In its pursuit of intelligent accountability
SHA welcomes the intention of Ofsted to introduce an inspection
process that places minimal burdens on schools. SHA hopes that
funds saved as a consequence of this decision will be redirected
to schools to enable them to support school improvement and increased
achievement directly.
12. We are pleased with the intention to
move away from micro-management of schools as part of a new relationship
with schools.
13. An inspection system based on more frequent
light touch inspections may be genuinely capable of supporting
school improvement. But to do so it must:
— be supportive of Schools Self Evaluation
(SSE);
— gain the trust of school leaders
and governors as an appropriately challenging external validation
of SSE; and
— become incorporated into the school's
own cycle of planning and self-evaluation.
14. In this context both a three-year inspection
cycle and the concept of shorter notice of inspection appear to
be reasonable. SHA also approves of the decision to vary the depth
and frequency of inspection according to need.
15. Similarly, we welcome the reduction
in documentation required before the inspection, the commitment
to cease the practice of repeated lesson observation of teachers,
the reduction of the number of inspector days in an inspection
and the shortening of inspection reports. However, we are concerned
that reports provide a balanced view of the school especially
when they are public documents.
16. While we recognise that in addition
to school inspection there will still be a need for both thematic
or survey inspections, we are concerned that these should not
create an undue burden on schools. Consideration also needs to
be given to the publication of these inspections and the manner
in which schools will be publicly identified.
17. Although we support the introduction
of short inspection reports there will be a need for effective
training of inspectors and consistent moderation of report writing.
18. SHA welcomes the reduction in emphasis
on pre-inspection preparation. If SSEs are to be honest evaluations
it is imperative that they are not mis-used by inspection teams
to focus upon identified weaknesses. They should then examine
such weaknesses, but should just as significantly be opportunities
to celebrate success and achievement, a concept not included in
the consultation.
SCHOOL IMPROVEMENT
AND SCHOOL
SELF-EVALUATION
19. SHA welcomes the recognition that school
improvement is the central responsibility of the school and that
Ofsted should complement schools' planning and self-assessment.
We agree that schools have become more effective at self-assessment,
but there is a need for a dialogue about what might be the key
aspects of SSE. If schools' SSE processes are to be effective
they will need to be both robust enough to sustain the single
conversation and the new Ofsted while being sufficiently lean
and non-bureaucratic for schools to operate with ease.
20. We are also concerned with the status
within the public domain of the school SIF. While the SIF itself
is intended to be confidential to the school and its key partners,
a summary of the SIF will be published within the inspection report.
This will not encourage the honest evaluative approach that Ofsted
wishes to promote.
21. The expectation that an evidential base
of parental views should be embedded in self-evaluation may increase
the pressure for yet another bureaucracy of evidence collection.
Whilst SHA agrees with the principle of surveying the views of
parents it questions the need to create new systems just to provide
evidence to inspectors of that process.
22. The decision to bring together the various
inspection regimes and to work with other inspectorates is a logical
step so long as the key judgements regarding schools' performance
are made by educational professionals.
INSPECTION TEAMS
23. SHA is delighted with the reinstatement
of HMI within inspection and would welcome their engagement in
all secondary inspections. This in our view addresses the variability
of both the process of inspection and judgements made under the
current regime of solely independent inspection teams.
24. There is, however, very great concern
at the intention to have a "very much more substantial"
contribution from lay inspectors. This raises significant questions
about consistency, training and the nature of judgements made
by an inspection process allegedly still focusing on teaching
and learning. There is no need for a lay inspector on all inspections.
25. We also have some concerns over the
engagement of multi-disciplinary teams if this approach reduces
the core focus on teaching and learning.
26. SHA agrees that, ". . . the security
and reliability of inspection will depend on the training and
quality assurance of the work of highly expert inspectors."
Evidence would suggest that this aspiration has yet to be consistently
achieved with the use of independent Ofsted inspectors.
THE NEW
RELATIONSHIP
27. Some progress has been made regarding
data access and the ability to enter data once and then to use
it many times.
28. School development planning still raises
significant concerns regarding multiple accountabilities and the
impact on what is intended to be a single conversation.
29. SHA has concerns about the possible
effect of Every Child Matters and Children Bill in the creation
of children's services directorates potentially moving the central
agenda away from school improvement, teaching and learning towards
a focus on social inclusion and a small number of particularly
difficult and deserving cases.
30. SHA is pleased to note that early signs
suggest that the training for School Improvement Partners is to
be rigorous.
31. Headteachers taking on the SIP role
is critical to the success and credibility of the strategy. But
SHA naturally has concerns about heads' work life balance as well
as that of senior teams who must lead and manage in their absence.
32. We are pleased with the progress made
so far in simplification of funding streams but there is still
more to be done.
SCHOOLS AND
OFSTED IN
THE FUTURE
33. The future of inspection and its ability
to support and enhance school improvement will depend on the culture
of trust and therefore openness that any new framework promotes.
34. The damaging effect of the implementation
of the new framework in 2003 and the impact that it had on the
view of Ofsted within the profession did nothing to promote such
a culture. Much more significantly, the failure of Ofsted to end
the practice of identifying schools as being "in special
measures" will make confidence in the new framework much
more difficult to achieve. It is our view that this public deficit
model of inspection is antithetical to school improvement.
35. We are deeply concerned with the statement
in the consultation document, ". . . Ofsted inspections should
. . . be consistent wherever possible in terminology and judgement
grading scales." The implication that some judgements should
be allowed to be inconsistent undermines the whole basis of inspection
leading to grading on a numerical scale. Whilst such scales are
in use the idea is unacceptable.
36. Whether the current S4 and in future
the new SIFs will be interpreted as honest critiques of the current
health of the school and its future achievement or as a means
of publicly identifying its current shortcomings will be significant
in the levels of trust given. We are particularly concerned that
the new SIF will amount to schools publicly revealing their weaknesses
in a manner just about unknown in other walks of life, and which
most would regard as absurdly bad for business.
October 2004
| 
