Memorandum submitted by the Association
of Inspection and Training Providers (AOITP)
1. STRATEGIC
PLAN 2004-07
1.1 We welcome the publication of this corporate
plan for its general clarity and ease of use as well as for its
content.
2. INTRODUCTION
BY HMCI
2.1 We note with interest the four principles
on which the work of Ofsted is based and:
— We support unreservedly the continued
constitutional independence of Ofsted.
— In focusing on its "extensive
statutory duties" we believe that Ofsted has lost an opportunity
to develop the non-statutory side by more extensively using the
educational expertise available to it from the education market
in a judicious mix of private and/or public sector providers.
— We believe that Ofsted has not rigorously
pursued the principles of "Best Value" in determining
whether to undertake work in-house or to seek to utilise the market.
At a time of ever increasing market capacity and capability we
are concerned at the extensive growth in the numbers of in-house
HMI.
— We support "open reporting"
to the public but believe that Ofsted should make even greater
efforts than it has to understand what it is that parents and
carers want to contribute to the inspection system and what information
they want back from that system and the format and content of
that information. In particular, there may be a conflict in this
area of presentation between the "professionalism of the
statutory role" and the more relaxed approach that disseminating
information to parents and carers might call for.
— While we continue to support the
Ofsted approach of "rooting advice and guidance" in
robust evidence we feel that there is a role for Ofsted and the
market to develop educational policy and strategy that requires
an element of speculation or "blue skies thinking".
We believe that this is currently an underdeveloped area of work
and that it represents a lost opportunity for both Ofsted and
the Government.
2.2 We support the concept of the "evolving
inspection system" and we are pleased that a higher priority
is to be given to the "improvement of inspection". Our
concerns in these areas are as follows:
— "Active review" has historically
meant that much of the developmental thinking has taken place
within Ofsted and has been largely uninfluenced by the expertise
available within the market. Consultation with the market has
been mostly at too late a stage to affect the key principles or
underlying philosophy and, in the main has been tinkering with
decisions already made.
— Review has not been a partnership
activity and the market has been frustrated at its inability to
contribute in any meaningful way to the system which it is then
operating within. On such limited occasions as we have had for
input into the current "New Framework", for example,
it has been clear that many of the issues we have raised had not
been considered by Ofsted or, where they had been considered,
there was not a consensus on the way forward internally and our
contribution was clearly not welcomed in that context. A concrete
example is that of the debate over whether the New Framework would
be "issues" or "curriculum" driven.
— We support the view that we should
continue to make the inspection process less burdensome to schools
but this process should be undertaken in partnership review with
the market as we have to live with the consequences of decisions
made which impact on our operational processes and sometimes have
financial implications not reflected in our tender prices.
— We strongly support accountability
and public reporting.
— Inspection should, of course, reflect
the nature and circumstances of the provision being inspected.
Performance is not independent of the operating context. What
is important, however, is not to allow "context" to
become an "excuse" or "reason" for poor performance.
The system should contextualise performance but then identify
what it is the provider has done to adapt to its context and respond
to and overcome what are perceived as being the barriers to effective
service delivery and improvement of standards.
— We are especially concerned that
the effectiveness or otherwise of the LEA in supporting and challenging
schools is not a focus of the inspection system given the impact
this can be perceived to have had for good or ill on its schools.
— We welcome the focus on things that
will make "a real difference to the quality of education
and care" and look forward to a constructive dialogue with
Ofsted on what these might be and how they might be measured and
reported on.
2.3 Like Ofsted, we welcome the possibility
of an integrated approach to the inspection of children's services
in an area, of which education would be one part.
2.4 Our view is that the "statutory
independence" of Ofsted is best supported by inspection teams
sourced from the open market that are free from the pressures
of being "within the system" and are themselves seen
as being independent. We are very aware of the pressures that
are brought to bear on in-house teams and the distortions this
can produce.
2.5 Given historical precedent, we would
have little faith that Ofsted will involve the market in the development
of an integrated approach despite a recognition in discussion
with them that things usually turn out better in a partnership
approach than when done alone. From our perspective, we believe
there to be internal barriers within Ofsted that prevent them
from operating in an effective partnership with the market. The
oft-repeated line that this or that contractor may gain a commercial
advantage by its involvement is not one that in our view either
holds water or is insurmountable. Its effect, however, is to exclude
rather than include.
2.6 We welcome Ofsted's plan to evaluate
in greater depth the impact of major government policies to which
we would add "initiatives". We would, however, wish
Ofsted to use Best Value Principles and engage with the market
in a dialogue as to how and where the market can help in this
evaluation rather than, as we suspect will otherwise be the case,
Ofsted undertakes all of that work in-house.
2.7 While we welcome Ofsted's initiative
". . . to disseminate inspection findings more effectively"
we believe this largely misses the point. All statutory agencies
involved in education together with LEAs and schools subscribe
to the principle of effective dissemination of good practice etc—that
many do it badly is also beside the point. The education system
is awash with good practice and dissemination—what Ofsted
needs as a precursor to this initiative is to understand what
the barriers are within LEAs and providers, including FE and HE,
that prevent good practice etc from being implemented.
2.8 Putting out more and better information
is not going to be effective if we do not first understand why
information already in the public domain is not effectively transferred
into current operational delivery and strategic thinking.
2.9 We would like to see the first of the
bullet points under this second strand redrafted as follows:
— Making the best use of the considerable
expertise of HMI and childcare inspectors and of the resources
available to us from the market.
2.10 We have stated before, and we firmly
believe it to be true, that there is more and greater expertise
in the areas of school improvement and effectiveness in the market
than there is within Ofsted. It is a concern for us that partnership
with Ofsted over the last five or six years has not led in any
significant way to the market to being involved in anything other
than inspections, inspector training and some ad hoc materials
development.
2.11 We support the third strand in this
report but again, repeat our request for earlier involvement in
the developmental process and effective consultation at the appropriate
stages. We have little confidence that this will be achieved without
a firm steer to Ofsted from the Select Committee.
2.12 In terms of Ofsted's objective ".
. . we set ourselves the goal of being a well-run organisation
. . ." we believe that it has some way to go before it can
claim to have met that goal. It is a source of concern to the
market that Ofsted sets high standards for its contractors and,
if it sets the same high standards for itself, regularly fails
to meet them.
3. Section II: Schools and Colleges
3.1 We broadly welcome the thrust of this
section and look forward to a formal opportunity of contributing
to the "appraisal of current strengths, weaknesses and challenges".
3.2 We already work closely with Ofsted
to maintain and improve the quality of all aspects of the inspection
system for which we are responsible. We are not aware that there
is any difference in outcomes between HMI led and market led inspections.
3.3 There are now no registered inspectors
operating on a freelance basis—all work through inspection
contractors and it is through and with those contractors that
we would wish to see Ofsted working to further improve quality
and rigour. We do not accept, and no-one has made the case, that
". . . there is a vital place for HMI, working alongside
registered inspectors, in assuring the quality of inspections
and accuracy of judgements."
3.4 Ofsted is again making the mistake of
not understanding the difference between quality control and quality
assurance and in the above statement it appears to be refocusing
on the process and not, as we have maintained it should, on the
outcomes of that process.
3.5 If there are perceived shortcomings
that approach is intended to address we should state firmly that
those shortcomings have not been raised with us as contractors
nor have we been engaged in any dialogue with Ofsted around this
issue.
3.6 HMI working alongside registered inspectors
has the effect of blurring lines of responsibility and accountability
and may throw the complaints process open to accusations of partiality
if HMI are part of a team against which a complaint is made and
that complaint is not upheld.
3.7 We would wish to be fully involved and
consulted on any changes along the lines suggested above.
3.8 Having said that, however, we have on
many occasions said that we are prepared to have HMI as part of
contractor teams on an occasional, planned basis for professional
development as we are very aware of the different cultural and
operational contexts between HMI teams and those of contractors.
That invitation has never been taken up and we repeat it again
here:
Ofsted report sub-paragraphs in bold
2.1 Regular inspection of maintained schools.
We note Ofsted's commitment to consultation and working with its
inspectors and contractors on reviewing the New Framework. To
date that commitment has not been fulfilled as effectively as
it might and we welcome the focus this issue will have at the
contractors' conference with Ofsted on 24 October. We are not
optimistic, however, based on historical trends, that Ofsted will
show itself amenable to a meaningful, on-going dialogue. Our current
dialogue with Ofsted on training needs and recruitment issues
has been in fits and starts over the last three to four years,
has been less than effective, unproductive in many ways and even
now is the subject of considerable criticism from our members,
especially on the focus given to numbers of recruits rather than
on their inspection capacity.
2.2 Quality assurance. Language is important
in conveying cultural values. We note that Ofsted will review
and develop quality assurance arrangements and that it will work
with us to improve quality further. We take that to mean that
we will not be involved in the analysis but we will be involved
in the subsequent delivery. We feel that we have important views
to contribute here and that in a partnership approach to the continuous
improvement of quality we would not detect the dislocation that
this paragraph implies.
2.3 Monitoring schools causing concern.
We have briefly touched earlier on the lack of any focus on the
LEA within the S10 inspection system. Given the current belief
that LEAs "make a difference" then schools that cause
concern might be regarded as a failure of the LEA's own quality
assurance and intervention processes. It seems appropriate to
us that the S10 inspection process should have a view on the adequacy
and effectiveness of the impact of an LEA on any given school
in its area, more so when that school is underachieving, with
serious weaknesses or special measures.
2.4 Inspection of independent schools.
We have no comment.
2.5 Effects of national policy aimed at raising
standards in schools. We would again suggest that the principles
of Best Value be applied here. We collectively have more people
on a daily basis in schools and LEAs and other provider institutions
including FE and HE than Ofsted or any other government agency.
Many of our consultants are recognised nationally and internationally
for the work that they do in all facets of education. Many subcontract
their services to the big national consultancies and are involved
in major DfES initiatives. A good number of our members are education
consultancies in their own right and have made a major impact
in various ways at local, regional and national level. We hope,
and expect, that Ofsted will begin to make more use of that resource
in this area of work.
2.6 Strategic review of inspection. We
note the commitment to consultation in 2004. We would hope that
a pre-cursor to that might be a diagnostic meeting/s between the
client and its contractors who feel that they have a contribution
to make in the early iterative stages of the developmental and
review process and not just in consultation on a series of options
or alternatives further down the road.
We have already given our support to better information
for parents and integrating inspection of services for children
and young people and do so again here.
We have some concerns over the quality of school
evaluation, especially in the "reality gap" between
the perception of some schools and what we find on the ground.
We support close targeting of inspections and more
intensive monitoring of schools causing concern. We would like
the option of being able to report on a school that does not fit
into the current categories of "cause for concern" and
where it is doing just enough to scrape by. For those schools
we would like the option of inspecting them again 12-18 months
later. This would not be a full inspection but a diagnostic check
that might result in a request for HMI corroboration visits where
performance has declined or not picked up as first thought possible
on the original inspection.
4. FURTHER EDUCATION
AND RELATED
PROVISION
4.1 Given the changes to 14-19 education
we believe there is a strong argument that this should form a
seamless part of the inspection process that should be market
led.
4.2 This is not the time or place to develop
that argument but we would welcome the opportunity of commencing
the dialogue with Ofsted and the Adult Learning Inspectorate.
5. TEACHER TRAINING
5.1 We are aware of many of the developments
in the last few years that the TTA has initiated and broadly welcome
them. As we have said earlier, we have more people in school for
more days in a week than any other agency. We believe that we
have considerable knowledge of teaching and teaching practices
that would be valuable to both Ofsted and the TTA, especially
in helping the latter inform the redevelopment and reshaping of
ITT courses and content.
6. SECTION III:
LOCAL EDUCATION
AUTHORITIES, CHILDREN'S
SERVICES AND
AREA WIDE
PROVISION
6.1 We have some concerns that the current
LEA inspection regime is less effective than it might be. While
we understand that government policy has moved away from direct
forms of intervention and outsourcing there is, nevertheless,
a need for LEA inspection to have the same rigour as the current
S10 process. We do not believe that to be the case and would welcome
the opportunity of developing this further with Ofsted.
6.2 We would, in particular, like to discuss
a greater involvement for the market in the process over and above
providing individual members for HMI led teams.
6.3 While we respect Ofsted's statutory
autonomy and welcome its discussions with other inspectorates
to develop an integrated framework and methodology for the inspection
of children's services in local authority areas we are conscious
that, for many of our members, S10 inspection work forms the mainstay
of their business.
6.4 At present, we tender on an annual basis
for our work and, at the point of the award, usually late-March
no contractor has much more than 12 weeks worth of work left.
This creates an annual instability within the market that has
declined from around 100 contractors three years ago to around
26 now. That instability hinders long-term planning and investment
decisions whether in infrastructure, hardware or people.
6.5 Ofsted consulting with other organisations
on future systems of inspection will add further instability and
hinder our ability to recruit and retain good quality staff and
inspectors unless we are also regarded as a partner in the developmental
process and offered meaningful consultation.
7. SECTION IV:
IMPROVEMENT THROUGH
INSPECTION
7.1 We would like to see an amendment to
the final sentence of the preamble to this section to read: "This
approach will draw on the resources and expertise of all directorates
within Ofsted and from the market" believing this to be both
within the spirit of partnership and that Ofsted is not the only
source of knowledge in these areas. While we do not really expect
an amendment to the document we hope that HMCI will give a commitment
to make that proposed amendment a practical reality.
October 2003
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