Memorandum submitted by Association of
Directors of Children's Services (ADCS)
INTRODUCTION
1. The Association of Directors of Children's
Services represents leaders of children's services in local authorities
and children's trusts. This submission has been prepared on behalf
of the Association by John Freeman, DCS Dudley, Joint President
of ADCS, and David Hawker, Deputy Chief Executive, Westminster,
and Chair of the ADCS Standards, Performance and Inspection Committee.
2. The Association would be willing to give
oral evidence if asked to do so.
3. The Association welcomes the opportunity
to submit written evidence to the Select Committee on the work
of Ofsted. Our role in the leadership of children's services at
local level gives us important insights into the workings of Ofsted
on the ground. Our statutory remit as Directors gives us a concern
for quality management and improvement in the delivery of services,
in order to secure better outcomes for children and young people,
which complements that of Ofsted through the inspection process.
Our statutory roles under the Children Act 2004 and the Education
and Inspections Act 2006, in particular, give us both powers and
duties to manage the quality of local provision for children and
young people, in schools, early education and childcare settings,
social care and youth settings, using inspection evidence and
local intelligence. Ofsted's evidence base is therefore indispensable
to us in all our work. In addition, Ofsted has a remit to inspect
and report on the effectiveness of local authority provision.
4. As an Association we enjoy good working
relationships with HMCI and her team, and have worked closely
with Ofsted in recent years on improvements to the various inspection
frameworks which are relevant to our work. We have found Ofsted
to be generally willing to listen to our views and make changes
in the light of experience in the field, while at the same time
retaining its independence and impartiality. In particular the
open and consultative approach of the current Chief Inspector
has greatly aided the dialogue and helped to foster an atmosphere
of mutual respect. This is not to say that relationships are always
perfect, neither is it to ignore the concerns which colleagues
in the field raise from time to time about aspects of the inspection
process. However, our recent experience is that these issues,
when raised, are discussed honestly, and with a genuine desire
for improvement on both sides.
OFSTED'S
REMIT
5. We are aware that concerns have been
raised concerning the breadth of Ofsted's remit. We understand
these concerns, but we do not share them.
6. We believe that the footprint of the
organisation should mirror that of the new DCSF at national level,
and of Directors of Children's Services at local level. It is
important that Ofsted, as the inspection and regulation agency
for all children's services, is charged with developing a complete
rather than a partial view of services for children and young
people. It would be counter-productive for some services managed
and led by Directors of Children's Services to be inspected or
regulated by other agencies.
7. However, Ofsted still needs to become
more cohesive, and there are some challenges in terms of the knowledge
base and experience of some inspectors who have operated previously
under a narrower remit (eg in youth work or social care). However,
we believe these challenges are being overcome with a judicious
combination of training and support for existing inspectors, and
the recruitment of new inspectors from the field with broader
experience. Over the past year, we have collaborated with Ofsted
to try to achieve this. In our view, the benefits of bringing
together inspectors from a wide range of disciplines to be able
to see the whole picture of children's services outweigh any potential
problems of focus on individual areas. Just as in children's services
departments we rely on highly experienced specialist professionals
working together in multi-disciplinary teams to make a reality
of children's services, we believe Ofsted can only properly fulfil
its mission if it is also a multi-disciplinary organisation.
8. We would extend this point a little.
We would like to see Ofsted given lead responsibility, and acting
on behalf of other inspectorates, in areas which fall outside
its immediate terms of reference, but which nevertheless relate
to children and young people, such as children's community health
care, and youth justice. This could be achieved, for example,
by seconding inspectors from the relevant inspectorates to take
part in joint activities.
SCHOOL INSPECTIONS
9. The current school inspection framework,
with predominantly short notice two-day inspections, has, we believe,
resulted in an improvement in the system. The regional organisation
of Ofsted which was instituted at the same time as the new framework
has meant that local authorities and schools now have a single
key point of contact at regional level, who is able to build up
an in-depth knowledge of a local area and its schools. In many
places this has resulted in some very effective joint working
between Ofsted and the local authority in dealing with performance
issues in schools where improvements are needed. The existence
of this intelligence base at local and regional level has led
to sharper and prompter interventions from local authorities.
We believe that this is contributing positively to a general improvement
in school performance.
SOCIAL CARE
AND CHILDCARE
INSPECTIONS
10. Ofsted has inherited a regulatory function
from its predecessor bodies in these domains, in respect, for
example, of fostering and adoption agencies, and childcare providers.
We believe this regulatory function is necessary, and it rightly
focuses as much on quality as on compliance. However, we do believe
that there could be more consistency between the two, in terms
of proportionality. We would question, for example, whether it
is necessary to inspect high performing local authority fostering
services as frequently, and to the same depth, as poorer performing
services.
LOCAL AUTHORITY
INSPECTIONS
11. Experience at local level of the Joint
Area Review (JAR) system and the Annual Performance Assessment
(APA) has been mixed. Many authorities have been satisfied with
the process in 2007, and have felt that it has been an improvement
on the equivalent processes last year, but there remain significant
concerns about administrative burdens and consistency. ADCS has
discussed these issues with Ofsted, and is working with them on
a number of possible improvements for 2008, based on experiences
this year.
12. There is a general welcome from Directors
that the over-burdensome JAR system is to be abolished at the
end of 2008, to be replaced by a more risk-led and proportionate
approach as part of the new CAA arrangements.
THE FUTURE
COMPREHENSIVE AREA
ASSESSMENT
13. Ofsted will clearly have an important
role in the future CAA, and ADCS welcomes the opportunity to discuss
this with HMCI and her colleagues ahead of time. The Association
believes that Ofsted should be given the lead role for inspecting
and assessing all services for children and young people, working
with other inspectorates as needed.
14. It is important that, in the spirit
of Government's commitment to lift the bureaucratic burdens on
local authorities, the simplicity of the new CAA arrangements
are not undermined by alternative local authority performance
management systems. The new National Indicator Set will form the
basis for the CAA, and Ofsted should be supported in their desire
to stick to it when making their contribution to the CAA.
15. Discussions need to take place between
Ofsted, DCLG, DCSF, the Audit Commission, the LGA and ADCS, to
design the CAA processes for children and young people. One important
issue which will need to be resolved is the relationship between
the CAA process and the "Local Authority Interactive Tool"
which has been developed by DCSF and which draws on a wide range
of data on all local authorities, including the views of a variety
of field forces. It is important that this data is used in a carefully
managed way, to ensure that the Interactive Tool does not drive
what might become, in essence, a parallel inspection and accountability
regime, which would of course be contrary to the commitments to
reduce regulatory activities set out in the Local Government White
Paper in 2006.
December 2007
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