Memorandum submitted by The Association
of Colleges (OAR 3)
SUMMARY
1. We are pleased to see recognition by
the Chief Inspector of the important role of colleges in their
local areas and of the contribution they make to the educational
chances of learners.
2. However, we are concerned that in some
important respects, colleges are judged more harshly than other
providers.
3. The report and inspections in general
fail to refer to the severe under-funding of colleges compared
to schools.
4. We are pleased to see that the proposals
for the new inspection process take account of a number of issues
on which AoC has campaigned for some time.
5. We still have concerns about several
important aspects of the inspection process.
SUBMISSION
6. AoC (the Association of Colleges) is
the representative body for colleges of further education, including
general FE colleges, sixth form colleges and specialist colleges
in England, Wales (through our association with fforum) and Northern
Ireland (through our association with ANIC). AoC was established
in 1996 by the colleges themselves to provide a voice for further
education at national and regional levels. Some 98% of the 400-plus
general FE colleges, sixth form colleges and specialist colleges
in the three countries are in membership. These colleges are the
largest providers of post-16 general and vocational education
and training in the UK. They serve over four million of the six
million learners participating in post-statutory education and
training, offering lifelong learning opportunities for school
leavers and adults over a vast range of academic and vocational
qualifications. Levels of study range from the basic skills needed
to remedy disadvantage, through to professional qualifications
and higher education degrees.
7. AoC is pleased to have the opportunity
to submit a response to the Select Committee on the Chief Inspector's
Annual Report for 2003-04. Our response will also highlight some
of the current areas of concern felt by the further education
sector on the current proposals for reform of the inspection process
in the second cycle.
8. We are pleased to see recognition by
the Chief Inspector of the important role of colleges in their
local areas and of the contribution they make to the educational
chances of learners. Amongst the issues to which the report pays
tribute to colleges are the following:
— The "critical importance"
of colleges within their local areas. They draw strongly upon
and make a vital contribution to local partnerships and have strong
links with employers and the local communities that they serve.
— The overall improvement in the performance
of the college sector and the fact that more colleges are well
managed than in 2002-03, including some outstanding general further
education colleges. Sixth form colleges continue to do well.
— The challenges faced by the majority
of further education colleges in making provision for their learners.
We are pleased that finally some acknowledgement has been made
of the considerable difficulties faced by many colleges, which
continue to cater for the most disadvantaged people in society,
including those who have failed to thrive in the school system.
These difficulties include attracting and retaining appropriate
staff, especially in the light of the funding gap between colleges
and school sixth forms; strong competition from local schools
in some areas and the current unsatisfactory state of the vocational
curriculum.
— Recognition that almost all unsatisfactory
provision had improved by the time of re-inspection.
— The fact that nine out of 10 colleges
judged inadequate were judged satisfactory on subsequent re-inspection.
— The improved flexibility in the curriculum
for 14 to 16 year olds. Currently, hundreds of thousands of 14
to 16 year olds study in colleges for part of the week. The role
of colleges in re-motivating and engaging these young people is
an important development.
— The extensive range of courses to
meet employers' needs. Colleges have been shown in an HMI survey
to be responsive to employers' needs, often tailoring provision
to meet the needs of individual employers.
— Their role in widening participation
amongst under-represented groups. The report acknowledges the
emphasis which colleges place on this role and the fact that they
carry it out well.
9. We are concerned that the report fails
in several respects to portray colleges in as generous a light
as school sixth forms. The Chief Inspector recently made some
very public and damaging observations about unsuccessful colleges
being a "national disgrace". However, nowhere in this
report does he say that 1,000 schools are making insufficient
progress in improving. Nor does he say that the many learners
in further education colleges who are given a fresh start and
who go on to gain qualifications have been failed before this
by the school system.
10. In his report on education in prisons,
he concludes that although the education received by girls is
of a very poor quality, nevertheless, it is perceived by the girls
themselves as superior to and more useful than that they received
in school. This is a severe indictment of schools and their failure
to cater for these harder to teach students but one on which the
Chief Inspector makes no explicitly critical comment.
11. We are disappointed that the report
makes no reference to the under-funding of college provision and
the effect that this has on the college's ability to meet all
the needs of all their learners or potential learners. The separation
of the funding arm from the inspection arm with the dissolution
of the FEFC conferred on the inspectorate the obligation to make
this kind of observation. The funding gap between schools and
colleges is running at between 10% and 12%, with schools not only
funded more per student but also with the additional benefit of
an extensive Government-funded capital programme. The current
funding position is preventing colleges meeting the needs of many
of their potential adult learners and they are having to cut provision,
for example, for adults wanting to study on courses that are not
Government priorities.
12. The report makes no mention of the huge
bureaucratic burden placed on colleges, which hinders their ability
to deliver their services to the frontline as effectively as they
could. According to the first annual report of the Bureaucracy
Review Group, chaired by Sir Andrew Foster, the sector has "a
burdensome regime which diverts and consumes significant resources,
limits the time and effort dedicated to learners and damages initiative
and creativity" (2004 Annual Report of the Bureaucracy Review
Group).
13. We are most disappointed that the proposals
contained in the Tomlinson Report on 14-19 education have not
been adopted by the Government. We note the Chief Inspector's
high expectations, expressed in the report and elsewhere, for
the outcomes of the Tomlinson report and the review of 14-19 provision
in alleviating the problems of vocational provision and its low
status relative to academic provision. He clearly felt that the
proposals were a helpful way forward for the majority of learners
in colleges on vocational courses and as a means of engaging those
who currently see nothing to attract them to which to progress
in education or training at 16.
THE INSPECTION
PROCESS
14. We are pleased to see that the proposals
for the next cycle of inspection contain the following elements,
for all of which AoC has campaigned for some time:
— differentiating the volume of inspection
according to risk;
— reducing the notice period; and
— simplifying the Common Inspection
Framework while maintaining its learner focus.
15. However, we still have concerns about
the following:
— The number of organisations and agencies
still carrying out inspection and the consequent number of inspections
taking place in many colleges.
— The over-reliance on particular indicators,
particularly that of total achievement and a lack of recognition
of partial achievement.
— An over-emphasis on particular cohorts
of students and aspects of the curriculum, notably 16 to 19 and
increasingly 14 to 19 year-old students, to the exclusion of others
such as adults on short courses and lower level work.
— The inexperience or inappropriate
behaviour of some inspectors.
— The lack of consistency of the decisions
made on leadership and management.
— Inappropriate comparisons made between
widely different types of colleges.
— The perception of inspection by some
colleges as a negative and damaging experience (even where the
outcomes are agreed).
— The funding levels and overall resources
of the college not being taken into account by inspectors.
— The existence of policy differences
between the operation of Ofsted and ALI.
16. It remains our belief that despite the
proposals to lighten the inspection burden, colleges will still
be subject to an excessive amount of inspection and other scrutiny.
Apart from the college inspection, they will receive scrutiny
from Ofsted for initial teacher training, nursery provision and
surveys on specific areas, during 14-19 area inspection, from
QAA, from auditors, examination board verifiers and others.
17. Many colleges report in excess of 200
inspector (or equivalent) days taking place between the visits
for their four-yearly inspection. This takes away hundreds of
hours from learning. In addition, many colleges report other anomalies
such as many inspector days being spent in re-inspecting areas
of learning involving very small numbers of learners. So despite
the inclusion in the principles of inspection in the Framework
of an assurance that inspection will be proportionate to risk
and tailored to circumstances and need, it appears that even low-risk
colleges will still find themselves subject to many days of assorted
scrutiny.
18. There are advantages and disadvantages
in the reduction to three weeks of the notice period for inspection.
On the one hand, it would ensure that the stressful waiting time
in the lead-up to an inspection was cut to a minimum and that
the inevitable collection of additional evidence and documentation
was minimised. Colleges are confident that their own continuous
efforts to improve quality will ensure that inspectors see the
same quality of provision whether the notice period is three weeks
or six months.
19. On the other hand, however, there are
difficulties in making practical arrangements within such a short
timescale. Colleges are large and complex organisations with thousands
of learners on different types of programme with varying modes
of attendance, hundreds of staff, many sites and many stakeholders.
20. We are pleased to note that the proposed
changes to the Common Inspection Framework are not radical in
nature and that the focus remains firmly on the needs of the learner.
Feedback from our members on the proposed changes has shown that
it has been a useful and well respected document and one that
colleges have found helpful in supporting their drive to improve
quality.
21. We support the introduction of a four-point
scale as we believe it has a helpful simplicity and the end of
the confusing combination of five-point and seven-point scales.
22. There is a general widening of the differences
between the approaches of the Ofsted and the Adult Learning Inspectorate.
For example, work-based learning providers and adult and community
learning providers will be given several months notice of an inspection
instead of the three weeks given to colleges. We would argue strongly
that differences such as this in the approach taken to different
types of provider are unhelpful and potentially unfair.
23. Colleges report no improvement in the
process of inspection in several areas on which AoC has been campaigning
for some time. Feedback to AoC indicates that colleges still do
not always perceive the inspection process to be a fair one or
one which brings about as many improvements as the time and cost
would seem to warrant. There still seems to be a difficulty in
finding appropriately experienced inspectors in some areas—often
the areas in which a college may have particularly good provision,
such as hairdressing or leisure and tourism. Colleges still feel
there is a lack of consistency between inspection judgements,
both within and between colleges, particularly of leadership and
management, and that the judgements underpinning the grades for
lessons lack moderation by Ofsted and therefore are unlikely to
be adequately consistent.
24. The feeling persists that inspection
is akin to a battle with the inspectorates, with colleges having
to fight to dissuade the inspectors from an assumption that the
provision is poor. This is not a helpful starting point.
25. The lack of a developmental focus is
a factor that many colleges feel is most unhelpful in bringing
about improvement and which represents a missed opportunity for
Ofsted to work with a college rather than merely to impose a judgement
on it. It has been made clear by the Chief Inspector at a previous
Select Committee meeting that the annual monitoring visit to be
conducted by a college inspector will not be for the purposes
of giving helpful feedback or advice. We continue to be of the
opinion that this refusal to offer constructive comment to providers
on areas that inspectors judge as weak is most unhelpful. Clearly,
in order to judge an area as weak, inspectors must have a model
in mind of what constitutes good provision. Not to share this
and work with the provider appears perverse.
26. We are pleased that new measures of
success are currently being developed to enable more accurate
comparisons to be made across and within the sectors. We expect
to see for value for money measure being applied equally across
the different sectors.
March 2005
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