Memorandum submitted by the NSPCC
A. SUMMARY
A.1 The NSPCC welcomes the opportunity to
contribute to the House of Commons Education and Skills Select
Committee evidence session on the "Work of Ofsted".
A.2 Although the session will primarily
focus on Ofsted's Annual Report, the NSPCC would like to set out
our very serious concerns about the proposal to create a single
inspectorate for children and learners, as part of a wider rationalisation
of public service inspectorates.
A.3 Inspection services play an important
role in improving experiences and outcomes for children and focusing
on their needs. NSPCC believes that inspection and regulation
is an important and powerful lever in driving up service standards
and providing the assurance and confidence that is needed on service
standards and quality. Inspection can also provide an assurance
that the necessary safeguards are in place to protect the most
vulnerable children and young people.
A.4 The proposal for the creation of a single
inspectorate as set out in the consultation document published
in July reaffirms the Government's commitment to merge the children's
services work of the Commission for Social Care Inspection (CSCI)
into Ofsted, together with the Children and Families Court Advisory
and Support Service (CAFCASS) Inspection remit of Her Majesty's
Inspectorate of Court Administration (HMICA). We believe that
in their present form, the proposals will fail to strengthen the
focus on outcomes for and safeguarding of children across the
board and particularly for vulnerable children and young people
and those considered to be at risk.
A.5 Under the proposals set out in the consultation
document, the creation of a single inspectorate for children and
learners is focused on inspection of services for this group which
are provided by local government or within the remit of the Minister
for Children. We do not believe that this would produce the end
result of a "single" inspectorate for children.
A.6 The NSPCC recognises that the Government
is clearly set on enlarging Ofsted's responsibilities. However,
we would recommend that more consideration should be given to
include all children's services, such as health and criminal justice
services within the single inspectorates remit and to focus inspection
activity on improving outcomes for and safeguarding children as
set out in the Every Child Matters Programme for Change.
B. THE NSPCC
B.1 The NSPCC is the UK's leading charity
specialising in child protection and the prevention of cruelty
to children.
B.2 The NSPCC exists to end cruelty to children
through a range of activities designed:
— To help children who have suffered
abuse overcome the effects of such harm;
— To prevent children from suffering
abuse;
— To prevent children from suffering
significant harm as a result of ill-treatment;
— To help protect children who are
at risk of such harm; and
— To work to protect children from
further harm.
B.3 We have more than 180 teams and projects
throughout England, Wales and Northern Ireland and the Channel
Islands. Their work includes:
— Family support, assessment, counselling
and therapy to children and families experiencing abuse;
— Investigations into allegations of
child abuse; and
— Work within schools and other youth
organisations to provide a voice for children and advocate their
rights.
B.4 The aim of our FULLSTOP Campaign is
to end cruelty to children. We believe that, given the will, most
abuse can be prevented. In order to achieve this, it is vital
that all children, whatever their needs, have a range of services
that are flexible and offer them support and protection.
B.5 Inspection was introduced in to the NSPCC
in 1991. The role of the Inspection Unit is to contribute to the
achievement of the highest professional standards and the continual
improvement of the quality of services delivered. It does this
by involving children and young people and providing an independent
inspection service to the Chief Executive and to the Board of
Trustees. In addition to undertaking an annual inspection programme
the unit also undertakes special investigations and enquiries
when requested by the Chief Executive.
B.6 In preparing this submission we have drawn
on the extensive experience of members of the NSPCC's Inspection
Unit as well as staff who have worked with inspection teams in
roles prior to their employment at the NSPCC.
B.7 In this submission we have chosen to focus
on issues in the consultation document relating to the establishment
of the new inspectorate for children and learners, the role of
user involvement, its governance and the role of the Children's
Rights Director. We have chosen not to comment on the incorporation
of Adult Learners Inspectorate in to Ofsted which we believe will
be more appropriately addressed by providers of these services.
C. SPECIFIC CONCERNS
We have a number of specific concerns about
the proposals for a single inspectorate including:
C.1 USER FOCUS
AND INVOLVEMENT
C.1A We do not believe that the case has
been made for the abolition of CSCI and transferring its functions
elsewhere. The work undertaken by CSCI, particularly in its commitment
to users of children's social care, their involvement in inspections
and focus on outcomes for children and young people rather than
processes has been exemplary. For example, the recent report published
by CSCI entitled "Making Every Child Matter—messages
from inspections of children's social services" demonstrates
the organisation's commitment to consulting children and young
people using services and progress being made in securing better
outcomes as set out in the Every Child Matters programme. [1]
C.1B We are particularly concerned that
the scope of the single inspectorate will be very wide and dilute
the focus on children and young people and in particular some
of the most vulnerable children and young people, for whom inspection
plays an even greater role.
C.1C It is difficult to see how this approach
to the involvement of vulnerable children in an area of work which
can yield significant changes in the quality of services could
be integrated into the Ofsted methodology, which has a very prescriptive,
standards-based approach and lacks user focused outcomes.
C.2 CHILDREN'S
HEALTH SERVICES
AND YOUTH
JUSTICE
C.2A We are also concerned that the single
inspectorate in its current proposed format will not focus on
youth justice and children's health services despite its remit
covering children and learners.
C.2B Recent figures state that 31,220[2]
children in the UK are listed on the child protection register
and many of these children are less than four-years-old. Health
care services are especially important for this vulnerable group,
particularly Children and Adult Mental Health Services and provision
of therapeutic services for children and young people who have
been abused. The report by Lord Laming into the death of Victoria
Climbie highlighted the essential role that health care services
perform in protecting children from abuse, neglect and maltreatment.
C.2C Achieving and improving outcomes for
children and young people also rely on an efficient and robust
criminal justice system. The same standards of safeguarding for
children and young people should apply in and out of the criminal
justice system. The links between social services and youth justice
are clear: local authority children's social care funding accounts
for the vast majority of Youth Offending Teams according the Annual
Review of the Youth Justice Board in 2003-04.
C.2D We fully endorse the duty placed upon
providers of services for children and young people to cooperate
as set out in Part 2 of the Children Act. Improvement in outcomes
for children and young people will depend on the effectiveness
with which a number of services work together. Therefore the ethos
and duty of partnership should also be reflected in inspection
of services for children and learners.
C.3 INSPECTION
OF LOCAL
AUTHORITY SERVICES
C.3A We are concerned that the consultation
document suggests that the single inspectorate will eventually
discontinue CSCI's practice of meeting regularly with each local
authority. This current strand of CSCI's work takes place to monitor
each local authority's plans and progress with a frequency proportionate
to its performance rating.
C.3B Instead, the consultation proposes
establishing a cadre of Children's Services Advisers, based in
Government Offices who will have a single discussion of priorities
and plans with each council's Director of Children's Services,
thereby reducing demands on the single inspectorate.
C.3C We believe that this proposal weakens
the single inspectorates capacity to both undertake work with
and encourage improvements in services provided by local authorities.
C.3D In particular, we are concerned that
a single annual assessment by advisers in Government Offices will
reduce the scope for scrutiny, especially where there are concerns
about the standard and quality of services and the council's capability
to improve them. This would be detrimental to improving outcomes
for children as well as the accountability of the single inspectorate.
C.3E It is unclear how the inspectorate
will be answerable for its findings if it cannot monitor developments
and is reliant on Children's Services Advisers for this role.
Although this is not explicitly discussed in the consultation
document, we would suggest that this work, which is the statutory
responsibility of CSCI should be strengthened to ensure continuous
improvement in services and continue as a role of the single inspectorate.
C.4 CHILDREN'S
RIGHTS DIRECTOR
C.4A The NSPCC strongly believes that the
statutory function of the Children's Rights Director should be
retained under the new arrangements. The role carried out by Dr
Roger Morgan has served the interests of children living away
from home, children looked after by local authorities and care
leavers, by promoting their rights, welfare and safeguarding and
securing the involvement of children in the work of CSCI. Abolishing
this function would lose the important work initiated in this
area and remove a champion for some of the most vulnerable children
and young people in society.
C.4B Therefore we believe that the role
should be incorporated in to the single inspectorate to ensure
children and young people to whom relevant services are provided
and to the views of the parents of such children and young people
are placed at the heart of the organisation.
C.5 GOVERNANCE
C.5A The current proposals state that the
single inspectorate will have the same organisational status as
Ofsted, remaining a non-Ministerial Government Department held
accountable through the Education and Skills Select Committee.
C.5B We do not support the suggested governance
arrangements as we don't believe this system is sufficiently robust
in accountability and ministerial responsibility. We believe that
the single inspectorate should be established as an independent
statutory body, directly accountable to the Secretary of State.
We recommend that the inspectorate publishes an annual report
on progress made in improving outcomes for children and on the
major issues emerging from its work.
C.5C We also recommend that to ensure a
fully robust and impartial inspectorate, the inspectorate should
be governed by a board of Commissioners. The Secretary of State
should be invested with power to appoint the Chair and board of
Commissioners.
October 2005
1 Every Child Matters-messages from inspections
of children's social services', 19 October 2005. Back
2
Number of children's names on Child Protection Registers,
United Kingdom, 31 March 2002. Back
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