Memorandum submitted by the Association
of Colleges (AoC)
BACKGROUND
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 fforwm) and Northern Ireland (through
our association with ANIC). These colleges are the largest providers
of post-16 general and vocational education and training in the
UK. 737,000 16 to 18 year olds study in colleges (compared with
460,000 in schools). In addition there are 120,000 14-16 year
olds who choose to study a vocational course in college.
THE WORK
OF OFSTED—CONTEXT
This submission addresses the work of Ofsted
in the context of recent major developments:
— The implementation of proportionate
inspection;
— Learning and Skills Council (LSC)
intervention policy;
— The transfer of 16-19 responsibility
to local authorities;
— The Children's Plan and the revision
of the Common Inspection Framework in 2009;
— Consortia delivery of Diplomas;
— The roll out of the Framework for
Excellence; and
— The creation of the Single Voice
to take forward college self-regulation.
SUMMARY
Proportionate inspection
AoC welcomes lighter touch, proportionate inspection,
which acknowledges the improvements in the further education sector
and its capacity to self improve, and supports colleges' goal
of self -regulation.
Ofsted's professional judgement
Colleges value the contribution that Ofsted
has made to college demonstrable self improvement. Over the last
two cycles, colleges have become confident with the decisions
that Inspectors make. Their professional judgements are for the
most part recognised as being fair and accurate.
Satisfactory but not improving Colleges
This Ofsted judgment has been accepted as fair
and necessary by colleges. Colleges are committed to challenging
benchmarks and accept that "coasting" is not good enough.
They realise that the bar must be raised year on year. However,
concerns have been expressed by some colleges over the new minimum
standard of 75% success rate for A Levels.
LSC's notices to improve and intervention policy
One of the triggers for the Notice to Improve
(LSC Dec 2007) is an Ofsted judgement that a college is "Satisfactory
but not Improving". AoC wishes to be assured that the arrangements
for support of these colleges are truly effective and fit for
purpose. It is vital that Ofsted should be able to make a contribution
to improvement strategies funded by the Improvement Agency.
Framework for Excellence
Framework for Excellence has been developed
by the LSC as "a single, unified framework that will help
increase both the quality of FE provision and the way in which
that provision meets the needs of all users" (see www.lsc.gov.uk).
AoC is pleased to see the greater alignment of the Framework for
Excellence with the Ofsted's Common Inspection Framework, and
the commitment to a single quality framework announced which reflects
the responses to the original Framework consultation.
Self assessment and self regulation
AoC welcomes the key role of self assessment
and peer review envisaged in the new arrangements for Framework
for Excellence, and particularly welcomes the suggestion that
Ofsted could have a role in validating self assessment reports,
or the rigour and consistency of the process. This external role
in quality assurance should be retained and strengthened as colleges
move towards self-regulation.
Ofsted's remit
Responsible evaluation must take into account
fitness for purpose in the learning and skills sector. We have
emphasised in our previous submissions to the Committee in October
2005, March 2006 and December 2006, the necessity for each division
within the merged organisation to retain the specialist expertise
that it needs to inspect different parts of the sector. We wish
to repeat that concern here, with a more specific concern that
the revised CIF (Common Inspection Framework), which Ofsted is
currently working on, should not become so broad and inclusive
as to become unfit for the purpose of evaluating colleges. AoC
has identified features of schools' remit which appear to provide
different and inappropriate drivers for evaluating provision in
the learning and skills sector. Whilst there may be some merit
in a single overarching approach, nevertheless the FE sector is
distinctive and as such may require a differentiated approach
in some areas.
Meeting the needs of 14-19 year olds
It is accepted that Ofsted can be one Inspectorate
with a common unified framework. However, we feel very strongly
that the different contexts need to be considered. We are particularly
concerned that the needs of 14-19 learners are given due importance
within Ofsted, in view of the complex quality issues that arise
as a result of the 14-19 Diploma developments and the consortia
partnership arrangements between colleges, schools and other institutions.
QUALITY OF
OFSTED'S
WORK
Proportionate Inspection
1. The inspection arrangements are now risk-based:
the lower performing colleges receive the most intensive inspection.
Some colleges are now exempt from inspection, and we welcome this
incremental and proportionate approach from Ofsted, which is appropriate
for a more mature sector.
2. Risk-based assessment means that colleges
that have proved themselves as enabled to get on with minimal
inspection to ensure inspection resources are devolved where they
are most needed. This is consistent with colleges' goal of self-regulation.
Ofsted's professional judgement
3. While welcoming these proportionate developments,
AoC would also wish to see the continuation of the annual visit
from Ofsted, as even outstanding colleges value the professional
judgement that they have to come to expect of Ofsted. Many colleges
are unhappy that the inspection cycle for high performing colleges
may in future be six years. There may need to be the building
in of safeguards or triggers (for example significant changes
in senior staffing, or a falling of performance trajectory) that
would signal an earlier inspection is warranted
4. AoC would like to emphasise that over
the last two cycles colleges have become confident with the decisions
that Inspectors make. Their professional judgements are for the
most part recognised as being fair and accurate. In a recent AoC
survey of colleges, 84% of colleges thought Ofsted was well regarded,
and enjoyed national recognition and respect with many of the
sector's key stakeholders. There is a strong view that Ofsted's
judgements are authoritative, and have credibility with teachers,
parents and other stakeholders because of its focus on teaching
and quality of education. While 92% of colleges approved the risk
based, light touch approach to inspection, most colleges wish
to retain a dialogue with Ofsted in the Annual Assessment visit
and welcome the validation of the Self Assessment Report that
a visit gives. AoC does not wish to see the expertise and vast
body of experience which is the basis for sound professional judgement
being lost with the introduction of Framework for Excellence.
Satisfactory but not improving Colleges
5. This Ofsted judgement has been accepted
as fair and necessary by colleges. Colleges are committed to challenging
benchmarks and accept that coasting is not good enough. They realise
that the bar must be raised year on year.
LSC's notices to improve and intervention policy
6. One of the triggers for the Notice to
Improve (LSC Dec 2007) is an Ofsted judgement that a college is
"satisfactory but not improving". A college receiving
a "Notice to Improve" is required to produce an action
plan to deliver improvement within a year, alongside a package
of support from the FE Improvement agency (formed through a merger
of the Quality Improvement Agency and the Centre for Excellence
in Leadership). If the improvement is not demonstrated, an LSC
Intervention could result in the withdrawal of LSC funding.
7. AoC wishes to be assured that the arrangements
for support of these colleges are truly effective and fit for
purpose. AoC is concerned that Ofsted should be able to make a
contribution to improvement strategies funded by the Improvement
Agency.
8. The most effective way to ensure improvement
is by sharing the good practice that already exists with the sector.
Ofsted currently holds the information about best practice. Ofsted
will shortly publish a set of case studies showing features of
most improved colleges. It is vital that the expertise and developmental
role of Ofsted is not lost at this stage, as "Satisfactory
but not Improving" colleges are the last substantial area
for improvement in the college sector (about 30 colleges are expected
to be identified within this category in September 2008).
9. This approach to improvement is central
to the commitment of the FE sector to self regulation. We would
wish to see Ofsted retain its professional role in identifying
and sharing key characteristics of the capacity to improve.
Framework for excellence and a single quality
system
10. We would like to see the growing alignment
between the LSC and the Common Inspection Framework continuing
and strengthening. It is important that the quality standards
and systems that are being developed by LSC map across to the
Common Inspection Framework, rather than impose new standards
and criteria for self assessment measures to substitute or add
to these existing standards.
11. The AoC college survey found that 94%
felt that a single performance and assessment framework is essential
or desirable, but 70% saw barriers to this. A key message is that
it is absolutely critical that the barriers are resolved and the
two frameworks are aligned. In particular, colleges felt that
it was vital that the LSC Overall Performance Rating (OPR) and
Ofsted Overall Effectiveness (OE) grade align.
12. In relation to the Framework for Excellence,
there are new indicators that are more problematic to quantify,
namely employer responsiveness and learner responsiveness. It
may well be that the judgement approach, that takes into account
a variety of quantitative and qualitative local evidence and weighs
it, may be a far better indicator than reliance on a survey or
other hard data.
13. AoC would like to go further in having
greater simplicity in terms of quality assurance, which would
align all standards within a single quality framework, so that
one set of judgements could be used many times.
14. We have major concerns about the proliferation
of different organisations, including the Sector Skills Councils,
setting standards and making judgements about colleges. This is
unhelpful in that it diverts efforts away from what should be
their priority—providing quality education and training
for learners.
Self assessment and self regulation
15. The college Self Assessment Report (SAR)
is the centre of the current inspection arrangements. Ofsted is
essentially making judgments about the accuracy of this report.
In particular, the new and critical judgement, "capacity
to improve", is largely made on the basis of how well a college
is able to self-assess its own performance and implement effective
action plans to improve.
16. We would like to emphasise that AoC
sees Ofsted's role as the external assessor of colleges' performance
as essential and critical. This is something that AoC would wish
to remain even within a self-regulating system. The credibility
and rigour would be important to retain, especially when colleges
are working with peers to regulate themselves.
17. The self-assessment reports in the sector
have received greater importance in inspection than ever before,
as this is the main plank along which the self regulation agenda
is built into the Framework for Excellence.
18. The "Single Voice" (an alliance
of FE organisations which represents the sector in discussion
with Government on regulatory matters) is currently considering
how it may wish to intervene in the case of provider underperformance.
We believe this will be an incremental process, that will rely
on existing benchmarks and standards which will be developed over
time. Ofsted would be one critical partner in this process, ensuring
that college performance measurements are up to date and fit for
purpose
Remit of Ofsted
19. AoC wishes to identify here features
of the schools remit which appear to provide different and inappropriate
drivers for evaluating provision in the learning and skills sector.
"Every Child Matters" is a key driver for schools (expanded
and developed in the Children's Plan). The ECM agenda is however
not a headline category for colleges, but a subset. AoC suggests
that Ofsted may need to employ some new headings to take account
of the differentiated purposes of schools and colleges. Colleges
have to be increasingly responsive to their users (learners, employers
and the community), and will be scored for Responsiveness in the
Framework for Excellence, and this requirement will presumably
be incorporated into the revised CIF. We suggest therefore a new
separate heading in the CIF applicable to colleges but not to
schools, would be Meeting the Needs of the User.
20. The Priority in the DCSF's Children's
Directorate is "meeting the needs of the individual child",
with achievement as a subheading. However in the learning and
skills Sector, achievement is one of the main priorities for the
user. That is why people go to college, and why employers send
trainees. Therefore a second, separate heading for colleges in
the Common Inspection Framework we suggest should be Outcome for
Learners. Progression and Destinations are the two other priorities
for colleges. For the purpose of evaluating colleges, we suggest
Ofsted also separate these out as subheadings under Outcomes.
Responsible evaluation must take into account fitness for purpose
in the learning and skills sector.
Meeting the needs of 14-19 learners
21. It is accepted that Ofsted can be one
Inspectorate with a common unified framework. However, we feel
very strongly that the different contexts need to be considered.
We are particularly concerned that the needs of 14-19 learners
are given due importance within Ofsted, in view of the complex
quality issues that arise as a result of the 14-19 Diploma developments
and the consortia partnership arrangements between colleges, schools,
and other institutions. In evaluating colleges Ofsted needs analysis
to show how the curriculum of the various providers in an area
are meeting the needs of 14-19 learners. As curriculum for 14-19
needs to be agreed in an area, collaboration and meeting need
should be identified as a category within the revised CIF and
rewarded.
May 2008
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