Further 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 the work of Ofsted generally, the NSPCC would like to
set out our very serious concerns about the inspection of children's
social services as part of the new Office for Standards in Education,
Children's Services and Skills (OFSECSS).
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 is also important for ensuring
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 OFSECSS
as set out in the Education and Inspections Bill reaffirms a commitment
made by the Chancellor of the Exchequer in his budget statement
in March 2005 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 are concerned that OFSECSS may fail to strengthen
the focus on safeguarding, and on all five outcomes for and particularly
for vulnerable children and young people and those considered
to be at risk.
A.5 We are especially concerned about the
lack of focus on user involvement and consultation in OFSECSS
as set out in provisions contained in the Education and Inspections
Bill. The NSPCC believes that this is important and relevant given
the recognised role service users have in improving quality and
the Government's commitment to involving children and young people
as part of 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 relating to the establishment of OFSECSS, the
role of user involvement, its governance and the role of the Children's
Rights Director.
C. SPECIFIC CONCERNS
We have a number of specific concerns about
OFSECSS including:
C.1 User focus and involvement:
C.1a As part of the Education and Inspections
Bill we would like to see a duty placed on the Chief Inspector
to consult children and young people. 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 simply on processes, has been exemplary.
For example, the report published last year by CSCI entitled "Making
Every Child Matter—messages from inspections of children's
social services" demonstrated 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.[15]
C.1b We are particularly concerned that
the scope of OFSECSS will be very wide and dilute the focus on
children and young people and in particular on some of the most
vulnerable children and young people, for whom inspection is arguably
of even greater importance.
C.1c It is difficult to see how CSCI's 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 Ofsted's current methodology, which has a very
prescriptive, standards-based approach and lacks user focused
outcomes.
C.2 Inspection of local authority services:
C.2a We are concerned that OFSECSS will
eventually be discontinuing CSCI's practice of meeting regularly
with each local authority, as set out in the consultation document.
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.2b Instead, the Government 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 OFSECSS.
C.2c We believe that this proposal will
weaken the capacity of OFSECSS to both undertake work with and
encourage improvements in services provided by local authorities.
C.2d 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 OFSECSS.
C.2e It is unclear how OFSECSS will be answerable
for its findings if it cannot monitor developments and is reliant
on Children's Services Advisers to fulfil this function. We suggest
that regular meetings to monitor each local authority's plans
and progress, which is currently a statutory responsibility of
CSCI should be required to ensure continuous improvement in services
and be maintained as a function of OFSECSS.
C.3 Children's Rights Director:
C.3a The NSPCC welcomes the Government's
decision to retain the statutory function of the Children's Rights
Director and move the role to OFSECSS. 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.
C.3b We recommend that the functions as
set out in the Education and Inspections Bill are widened, to
include pupils excluded from school, as suggested by several respondents
to the Government's consultation to the "Single Inspectorate
for Children and Learners" consultation. 16 Excluded
pupils tend to be one of the most vulnerable groups and we believe
that extending the remit of the Children's Rights Director to
include this group would fit well within his function of protecting
the interests of the most vulnerable children and help to ensure
their views are considered and represented at the heart of OFSECSS.
C.4a Under the Education and Inspections
Bill, OFSECSS will have the same organisational status as Ofsted,
remaining a non-Ministerial Government Department held accountable
through the Education and Skills Select Committee.
C.4b We do not support the suggested governance
arrangements as set out in the Education and Inspections Bill
as we do not believe this system to be sufficiently robust in
terms of 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.
C.4c We 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.
This would allow for the separation of roles between Chairman
and Chief Executive which is a feature of best practice in corporate
governance.
March 2006
16 A Single Inspectorate for Children and
Learners, The Government's Response to Consultation, DfES
2005.
15 Every Child Matters-messages from inspections of
children's social services', 19 October 2005. Back
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