Memorandum submitted by the Association
of Colleges (AoC)
SUMMARY
1. In our evidence submitted to the Committee
in September 2002 AoC made a number of points about Ofsted procedures
which disadvantage sections of the Further Education community.
We repeat those below which remain unaddressed.
2. Of major concern are the relatively low
inspection grades achieved by the majority of colleges with a
high disadvantage factor. It is vital that ways of measuring the
"value added" to a learner by the college is introduced.
(see paragraph 32)
3. The criteria for judgements made on leadership
and management should be clarified. (paragraph 34)
4. The use of attainment as a criterion
for grading lessons continues to be a problem and should be discontinued.
(paragraph 30)
5. It remains a matter of concern that the
nominee is excluded from the grading meetings that take place
on a Thursday and Friday of inspection week. (paragraph 40)
6. There are shortages of inspectors in
certain curriculum areas, with the result that these areas are
not inspected in some colleges. (paragraph 28)
7. The inspection of school sixth forms
continues to be conducted using different criteria and by different
groups of inspectors, making true comparisons very difficult.
(paragraph 41)
In addition we would make the following points:
8. We would like to see consistency of practice
across all local Learning and Skills Councils in the descriptions
of colleges which are used by the Inspectorate to help with their
analysis. (paragraph 39)
9. Ofsted should take more notice of previous
inspections and colleges' own self-assessment procedures and use
them as a basis or their inspection. (paragraph 43)
10. Colleges report a generally high level
of satisfaction with the implementation of the Common Inspection
Framework and the conduct of the inspectorate. (paragraph 23)
11. The emphasis in the inspection process
on the experience of the learner continues to be welcomed by colleges.
(paragraph 24)
12. We welcome the recognition from inspection
findings that teaching and learning and success rates, continue
to improve. (paragraph 25)
13. It is vital that further work is done
on recognising a wider range of successful outcomes to measure
institutional and individual performance. (paragraph 38)
14. The misleading practice of using the
leadership and management grade as a surrogate grade for the overall
judgement of a college as "good" or "poor"
etc should be discontinued. (paragraph 35)
15. Colleges would welcome further guidance
on the pre-planned meetings with staff, students and employers,
in view of their importance in relation to the Key Questions.
(paragraph 29)
16. Further guidance on a desirable format
for the Self-Assessment Report would be welcomed. (paragraph 43)
17. A protocol for Nominees to use in noting
concerns about the inspection process should be made available
for use during the inspection. (paragraph 40)
OFSTED MEDIA
RELEASES
18. AoC has serious concerns about the negative
emphasis in Ofsted media releases on further education college
provision. These media releases, although they create considerable
press coverage, are often not a fair reflection of Ofsted's own
reports.
19. For example on 30 April 2003 Ofsted
issued 12 press releases jointly with the Adult Learning Inspectorate
in relation to their report on post-16 education and training.
All of these media releases stated that "further education
should be more closely matched to the needs of local employers".
There was little evidence in the report to substantiate this comment.
The reason for any gap tends to relate to employers choosing qualifications
that attract public funding rather than any lack of responsiveness
from colleges. In fact we understand that Ofsted are only now
in the process of assessing the level of employer engagement and
this report is not due until autumn 2004.
INTRODUCTION
21. 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% of the 420 colleges in England and
Wales are members.
22. AoC has continued to monitor College's
perceptions of the Common Inspection Framework and while there
are still some concerns about the process, inspection is seen
by Further Education Colleges as the key to driving up quality
across the sector.
OFSTED'S
INSPECTION RESPONSIBILITIES
FOR POST-16
EDUCATION
23. Feedback received by the AoC from many
colleges continues to reveal a generally high level of satisfaction
with the implementation of the Common Inspection Framework, its
usefulness as a tool to improve quality and the validity of the
findings. Inspections have worked particularly well where the
team has consisted largely of experienced inspectors with a good
understanding of the diverse nature of FE provision and students.
In the most satisfactory inspections, the team has been prepared
to listen to and acknowledge the college when it has wished to
clarify issues or bring additional evidence to bear. Inspectors
have almost unfailingly been professional and courteous in their
dealings with colleges. There is still some variability between
part-time inspectors.
24. The continued focus on teaching and
learning and the evaluation of the impact on learning of all college
functions is still welcomed by colleges and is seen to be driving
up standards.
25. We are pleased to note that the number
of lessons observed as good or above is continuing to increase:
68% of the teaching of adult learners was good or better, and
63% for 16-18 learners. The number of unsatisfactory lessons has
reduced from 10% to 7%. In addition, we are pleased to note that
recent LSC data confirm substantial increases yet again in learner
success rates, from 59% to 65%.
26. The AoC noted at the last Select Committee
meeting the sector's appreciation for the changes that the AoC
had highlighted and that had been implemented, namely: the smaller
teams, the increased length of inspections where appropriate,
the longer notice of inspection, the increased reporting on adult
work, the availability to colleges of Inspectors' CVs and the
implementation of the appeals system against grading decisions
and a complaints system for procedural issues. It might be helpful
to add a protocol for nominee's to report concerns about the practice
of any of the inspectors while inspection is taking place.
27. Colleges have welcomed the implementation
of further changes that the AoC had suggested/supported and that
have now been implemented. These include:
— The use of contributory grades when
grading a programme area. This enables the college to identify
strengths and weaknesses more clearly and overall judgments for
discrete areas inside whole programme areas to be made.
— The revised process for re-inspection
is seen to be more helpful to colleges and is more likely to result
in the improvement of quality that is required.
— Now that there is a history of robust
data colleges welcome not having to devote time to data checking
prior to inspection.
— The recognition of the need to look
at 14-16 provision within colleges and the importance of the relationship
with the 14-19 area reviews.
28. There is still a problem in recruiting
inspectors with expertise in particular subjects, especially some
vocational areas. This sometimes results in specialist areas such
as Hairdressing and Sport not being inspected. This disadvantages
general further education colleges which in many cases will have
excellent provision in these areas. It is important that every
effort is made to recruit sufficient appropriately experienced
inspectors for all curriculum areas.
29. Overall, colleges welcome the pre-planning
process but, now that the process is well established, there could
be some extra guidance to make the process more streamlined. The
purpose of this would be to save time and ensure that the college
is presenting information in the most helpful way. For example:
the planning of meetings with staff and students during inspection
week takes up considerable time within the college because they
are considered as very important in helping inspectors judge how
well the college responds to the key questions. However there
is a feeling in the sector that inspectors by now do know what
they are looking for in these meetings and that there could be
extra guidance to help the planning process. Likewise, extra guidance
on what inspectors want to see in the work place would be most
helpful. Inspection teams tend to arrive in with a plan of what
they want to see in these areas but then have to change the schedule
to meet the demands of the work place. A section in the hand book
of inspectors' expectations regarding what they wish to observe
in work based learning would be helpful together with a recognition
that inspectors will then be guided by the college in these areas.
30. The application of the criterion "attainment"
is still causing confusion in its use as applied to many courses
found in colleges. This requires inspectors to make judgements
on the standard of work of the group as a whole against a national
norm for students working at that particular level at that stage
of the year. This is a model that makes sense in schools where
the student group is relatively homogeneous but only in certain
courses in colleges. First, the members of a group, for example,
of basic skills students, may be at widely different stages and
working to their own individual learning plans. Secondly, this
system penalises colleges that admit students with more modest
prior achievements. Because attainment grades are no longer published,
colleges can no longer even see the effect these grades are having
on final lesson gradings. We believe that this criterion should
be discontinued in colleges.
31. There is much good practice in the development
of self assessment documents as colleges are learning to self
assess more accurately. However, more guidance in the handbooks
on the process and desirable final format of the self assessment
document would be welcomed.
32. We welcome the increasing recognition
of the importance of developing appropriate value added measures
to measure achievement and we look forward to the findings of
the Measuring Success Steering Group. At present value-added measures
only exist to measure the distance travelled by learners on a
narrow range of courses. Developing a wider range of value-added
measures will be of particular importance as an inclusive 14-19
curriculum unfolds, and in measuring the success of current 14-16
initiatives which require colleges to work with many disaffected
young people who are at risk of dropping out of education or training.
Achievement of a qualification may not always be an appropriate
outcome. For some learners at risk of dropping out, for example,
merely attending regularly and acquiring employability and other
social skills will be an achievement in itself and this should
be recognised by the inspection process.
33. There is some concern that inspectors
seem to be inconsistent in their judgement about the significance
of different learning strategies. AoC would support an emphasis
on inclusive learning for all students but believes that this
needs to be consistently measured.
34. AoC wishes to reinforce again the importance
of transparent criteria when making judgements on leadership and
management. It is not always clear why a college receives an unsatisfactory
grade while another receives a satisfactory grade.
35. AoC would like to propose that the Inspectorate
reviews the practice of identifying a "good" or a "poor"
college on the basis of the leadership and management grade. Using
the leadership and management grade as a surrogate in this way
is misleading when taken up in subsequent public discussions of
the performance of the FE sector.
36. The role of the Learning and Skills
Councils in inspections needs to be reviewed. They are involved
in the planning meetings and they hear the feedback but otherwise
they are peripheral despite their key role in signing off the
post-inspection action plan. Consultants are often required to
help to do this.
37. Many colleges feel there is too long
a time lag between the end of inspection, the production of the
final report and the signing off of the post inspection action
plan. A suggestion would be to recognise the report as complete
when it is sent for publishing, this would reduce by a whole month
the gap between the report and the official beginning of post
inspection planning [many colleges start this process informally
immediately after inspection]. The whole area of post inspection
action planning needs tightening.
38. There continues to be concern about
the tension between widening participation and the importance
of retention and achievement of whole qualifications for certain
groups of students. Colleges with a large proportion of disadvantaged
students and those whose history of prior achievement when they
arrive at the college is poor, still tend to receive poorer grades
at inspection. There is still inadequate recognition of the quality
of the work of colleges with students who find it more difficult
to remain at college and achieve a qualification. There is an
over-reliance on achievement of a qualification as an indicator
of the success and quality of a college. Retention and achievement
of a qualification are sometimes dependent on factors outside
a college's control. Many adults, for example, are not interested
in a qualification and may leave when they have acquired the knowledge
or skill that they need. Many leave because they have obtained
employment. Some leave because their employer withdraws sponsorship
and others experience financial or personal pressures which make
it impossible for them to continue at college. Colleges providing
for these categories of students need to have their work acknowledged
and praised by inspectors if they are not to be feel pressurised
into discontinuing this type of work and restricting their recruitment
to those students who are most likely to succeed. Recognition
of the achievement of individual units will hopefully help to
mitigate these effects.
39. It is critical that the interface between
Ofsted and the LSC is clarified. AoC understands that local LSCs
set benchmarks for colleges which are then used in analysis by
the Inspectorate. It is of considerable significance for a college,
for example if it is considered by the local LSC to have widening
participation as a major component of its mission. The Inspectorate
would then use a different set of benchmarks to another college
where this description was not used. It does appear that different
judgements are made in different parts of the country. We would
urge the Inspectorate to encourage local LSCs to move to a more
equable approach.
40. We remain committed to the view that
nominees should be present at the final grading meetings. Although
inspectors do their best to ensure that no unexpected findings
emerge at a late stage in the week, if they do, the nominee can
challenge any inaccuracies with additional evidence. This process,
adhered to by FEFC, reinforced the partnership between the college
and the inspection team in a professional and objective manner.
41. We are concerned that colleges are still
subject to a different inspection process and a far more rigorous
and exhaustive inspection than school sixth forms. This is reflected
in the fact that the inspection report of a school sixth form
is only a few paragraphs long.
42. There is concern that in some colleges
a poor inspection has resulted in major changes in the senior
management. It is important that the findings of an inspection
are used as the basis for planning improvements and not seen necessarily
as a tool for restructuring.
42. AoC believes that it is critical that
Ofsted moves from a position of similar inspection of all institutions
to one that takes cognisance of successful prior inspections and
moves to a light touch where appropriate. AoC considers that it
is essential that Ofsted should take more notice of colleges'
own self-assessment process and procedures and use them as a basis
or their inspection.
October 2003
| 
