Memorandum submitted by the Independent
Schools Inspectorate (ISI)
EXECUTIVE SUMMARY
1. The Independent Schools Inspectorate
welcomes the opportunity to submit written evidence to this inquiry.
ISI believes that a strong accountability structure supports schools
improvement. Robust inspections based on objective measures and
direct observations which result in published reports are essential
in helping schools to provide high quality education and care
and in securing public confidence.
INDEPENDENT SCHOOLS
INSPECTORATE
2. The Independent Schools Inspectorate
(ISI) is a body approved by the Secretary of State for Children,
Schools and Families for the inspection of independent schools
in membership of the Independent Schools Council (ISC). ISI inspections
report on the extent to which regulatory requirements are met,
support school development and improvement and provide independent
and frank reports to inform parents, schools and other interested
parties. ISI inspects over 1,200 schools, educating over
500,000 pupils80% of the independent sector in England.
ISI also inspects a number of schools overseas each year.
ACCOUNTABILITY
3. ISI agrees with the principle that schools
should be held publicly accountable for their performance. This
accountability arises from two sources. Firstly, schools are,
in addition to parents and carers, significant contributors to
a child's development. This care for children at a crucial stage
of their lives requires full accountability for key outcomes.
Secondly, maintained schools are in receipt of public funds and
therefore should be accountable for the way in which this money
is spent and the outcomes achieved.
4. Schools are, and should be, accountable to
pupils, parents and funding sources. They should be accountable
for what they claim to provide, for example academic education,
pastoral care and welfare etc., and for their compliance with
legal obligations. The outcomes should be effectively assessed
through objective external review with full public reporting.
Where such external review indicates failings then a range of
measures, proportionate to risk but including closure, should
be available to an appropriate body.
5. Internationally the range of accountability
structures for schools varies greatly from undeveloped and superficial
to detailed and specific, with requirements backed by external
review (as in the UK). It is notable that many countries are investing
considerable resources in developing UK type inspection systems.
6. In general terms, the current accountability
system of inspection and reporting is fit for purpose. Parents
and the public hold published reports in high regard. However,
many associated areas on which inspection rests are complex and
burdensome. In particular the variety of organisations and requirements
both statutory and non-statutory involved in school accountability
(eg SIPs, Ofsted, LAs, National Strategies), leads to duplication
of effort and cost, and confusion for schools, parents and other
stakeholders. Changes in the maintained school inspection framework
in recent years have led to greater reliance on self evaluation
and test and examination results. We would question whether the
current inspection tariff for maintained schools provides sufficient
opportunity for inspectors to directly observe practice in schools
in order to test the validity of self-evaluation and to make a
reliable assessment of the outcomes for pupils beyond test and
examination results. The sheer number of regulatory requirements
that should be checked for compliance cannot be reliably covered
in the time available, relying instead on focusing on specific
areas or where concerns may be evident.
7. Where education provision is increasingly
collaborative with partner organisations, it becomes progressively
more difficult to hold individual schools accountable for their
performance. Clear reporting on the effectiveness of joint projects,
including the management arrangements, should inform stakeholders
appropriately.
INSPECTION
8. The inspection of maintained schools
by Ofsted and its contractors has been effective in increasing
accountability of schools through public reporting. In particular
Ofsted indicate that the measures for "failing schools"
have raised standards and increased the rate of improvement. Independent
inspection is the appropriate way of holding schools accountable,
and of assessing the impact of government policy as well practice.
To do this effectively the inspectorate must be well funded and
resourced. Where funding is limited, inspection models may by
foreshortened to the detriment of all.
9. The inspection process should drive improvement,
and give schools confidence that pupils are achieving standards
consistent with reliable external benchmarks. However, where inspection
prescribes methods or practices rather than focusing on outcomes,
creativity can be stifled and innovation detered. This can slow
improvement or even reduce standards. Parallels can be drawn with
the practice of "teaching to the test."
10. Inspectors, as with any workforce, have
a wide range of qualifications and experience. We would suggest
that it is important that inspectors are well "matched"
to the schools they are inspecting in terms of prior experience.
Where care of pupils in residential settings is being inspected,
inspectors from both education and care backgrounds should be
included in the team so as to ensure that both areas of expertise
are appropriately covered.
11. Inspections should be scheduled at an
interval so as to ensure that typically a child cannot complete
their time at the school without an inspection having taken place.
Inspections must be sufficiently detailed so that they can provide
a secure evidence base as to the outcomes for pupils and should
result in a published report which is useful to parents and the
public. The appropriate notice period for inspections depends
on what is viewed as the purpose of the visit. If schools are
to be "caught out" then there should be little or no
notice. If schools are trusted, then some notice can be given
for meetings to be scheduled (especially with governors, who are
often not available at very short notice) and documents collated.
An increased notice period also allows for a greater number of
parents and pupils to confidentially express their views through
questionnaires or other means.
12. Self assessment/self evaluation provides
a useful indication of a school's ability to be self critical
in identifying strengths and weaknesses. It can also be a helpful
starting point for the inspection process particularly in terms
of influencing judgements on leadership and management. However,
self evaluation should be a starting point for rigorous inspection
and not accepted without challenge. The results of national tests
act as one of many sources for inspectors. Contextual Value Added
scores act as a framework for schools performance but must be
treated with some caution. In particular, CVA must not exclude
the setting of high expectations for individuals or groups of
pupils, nor mask differential attainment of different groups of
pupils within the school.
13. We believe that attainment and ECM outcomes
should not be viewed as in competition. However, attainment is
objective and measurable, whereas qualitative "soft"
evidence on wellbeing is less amenable to quantitative objective
measures. Inspectors must balance these different types of indicators
using their professional judgement.
14. Performance based inspections should
be based on reliable and measurable indicators, and transparent
guidelines should be available. The current "light touch"
regime for some schools relies heavily on self evaluation and
does not, we feel, sufficiently probe the judgements of the school,
particularly in relation to care and welfare.
15. Indicators of underperforming schools
include attainment, regulatory compliance and inspection outcomes.
These are appropriate indicators but may conflict, for example,
pupil attainment may be below target levels, but, in an improving
school, the quality of teaching and pupil welfare much higher.
Different indicators are "enforced" by different agencies,
for example schools falling below the key government target of
30% of pupils achieving five good GCSE grades, may still be judged
satisfactory or good on inspection because of positive indicators
in other areas.
16. We feel that the current procedure for
complaints about inspection is adequate, including the arrangements
for review by an independent adjudicator. It is not clear though
what influence data from the complaints process has on the development
of future inspection models
PERFORMANCE REPORTING
17. Performance can only be usefully measured
on objective indicators, including attainment. Qualitative indicators
are best expressed in the context of an inspection report or similar
document.
18. The publication of league tables is unhelpful
in many respects and evidence suggests that it has led to increased
"teaching to the test" and narrowing of the curriculum.
These tables create the illusion of reliability and comprehensiveness,
especially to parents, that is not warranted.
SCHOOL REPORT
CARD
19. The DCSF proposals for a school report
card causes us some concern. In particular, there is significant
potential for duplication and conflict with other published information.
The proposed inclusion of qualitative judgements in numeric form
is alarming as it could have a significant negative impact on
a school yet be based on relatively "thin" evidence.
In particular, it is not clear how the views of parents and pupils
will be appropriately reported.
20. If an inspection report is thorough and sufficiently
detailed, with inspections occurring at suitable intervals, we
see little need for this additional level of reporting.
February 2009
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