Memorandum submitted by NASUWT
The NASUWT's submission sets out the Union's
views on the key issues identified by the Committee in the terms
of reference for the Inquiry and examines significant broader
implications in policy and practice in the education system for
the development of effective and constructive approaches to school
accountability.
The NASUWT is the largest union representing teachers
and headteachers in the UK, with over 270,000 serving teacher
and school leader members.
EXECUTIVE SUMMARY
— The NASUWT believes that an effective
school accountability system must be based on principles that
ensure that it can operate in an effective, development focused
way. — The current school accountability regime, based on
performance tables and Ofsted inspections is not only punitive,
divisive and demoralising but also undermines the ability of teachers
and headteachers to provide high quality personalised learning
experiences for pupils.
— The operation of performance tables and
Oftsed inspections has created a high-stakes environment in the
education system in England with a continual emphasis on improving
demonstrated pupil attainment and achievement while skewing the
curriculum offered by schools by encouraging an increasing focus
on core subjects.
— Inspections in particular continue to
undermine work to reduce teachers' and headteachers' workload
and organisational bureaucracy.
— A growing number of international studies
show that other comparable countries—including in other
UK nations—have reached and maintained higher educational
standards without the use of the crude systems of school accountability
that have become a negative feature of the system in England.
— Ofsted's ability to play a positive role
in raising standards is undermined by the inappropriate arrangements
in place by which it is held to public account.
— The current focus of inspection practice
that simply resorts to more frequent inspection of schools in
such circumstances will not support continued and further development
of the quality of provision in the schools.
— Current arrangements in respect of the
use of data in inspections, the training of inspectors and the
management of complaints are inadequate.
— The proposals by the Government to introduce
a School Report Card offer an important opportunity to re-examine
some of the principles and practices associated with the current
school accountability regime and to consider ways in which more
positive approaches to school accountability might be established
in future.
PRINCIPLES OF
AN EFFECTIVE
SYSTEM OF
SCHOOL ACCOUNTABILITY
1. The NASUWT believes that an effective
school accountability system must:
— place minimal burdens on schools;
— be consistent with and support the principles
underpinning the School Workforce Remodelling Agenda, which seeks
to tackle teachers' and headteachers' workload and raise standards
of educational achievement;
— not require schools to undertake any
special preparation;
— make use of the wealth of data that is
already available and not require schools to prepare or collate
data for the sole purpose of inspection;
— be supportive and focused on helping
schools to improve;
— focus on schools' management arrangements
and processes and their outcomes for pupils and staff in terms
of efficiency, equity and effectiveness;
— not duplicate other systems of monitoring,
performance management and support;
— operate coherently with other systems
of audit and performance management advice and support, including
that that is carried out by Her Majesty's Inspectors (HMIs) and
local authorities;
— provide judgements that are fair and
in which the profession and the public can have confidence;
— reflect appropriately the contribution
made by schools to pupils' broader development and wellbeing;
— not act in a way that impedes the ability
of teachers and headteachers to use their professional skills,
talents and expertise to meet the learning needs of the pupils
for whom they are responsible;
— not undermine policy priorities and strategies
established by democratically accountable governments; and
— reflect the changing nature of the responsibilities
of the school workforce, including teachers and headteachers,
in the context of a continually evolving policy environment.
2. There can be no objection in principle
to the establishment of appropriate mechanisms for holding schools
to public account for the work that they can reasonably be expected
to undertake with learners. However, the current school accountability
regime, based on performance tables and Ofsted inspections rather
than reflecting these critical principles, operates in a way that
is not only punitive, divisive and demoralising but also undermines
the ability of teachers and headteachers to provide high quality
learning experiences for pupils.
BASIS OF
THE CURRENT
SCHOOL ACCOUNTABILITY
REGIME IN
ENGLAND AND
ITS IMPLICATIONS
3. The operation of performance tables,
currently in the form of the Department for Children, Schools
and Families' (DCSF) Achievement and Attainment Tables, has created
a high-stakes environment in the education system in England with
a continual emphasis on improving demonstrated pupil attainment
and achievement. This high-stakes environment has had the effect
of skewing the delivery of the curriculum by encouraging an increasing
focus on core subjects and stifling creativity and the scope for
teachers to use their professional skills and expertise in the
development of innovative and personalised approaches to teaching
and learning. It has promoted a culture of teaching to the test
and has put staff in schools under pressure to target resources
at borderline achievers to push them into a higher grade.
4. The accountability regime continues to foster
competition between schools. In this way, the operation of inspection
and performance tables works against the direction of travel of
current Government policy which aims to enhance educational provision
by creating structures where schools work in collaboration rather
than competition with each other in the interests of all pupils
in the communities these schools serve regardless of the specific
school they happen to attend.
5. Ofsted inspections continue to undermine
efforts to reduce teacher and headteacher workload and organisational
bureaucracy. Pressure to generate and produce documentation to
justify schools' self-evaluation outcomes is leading to increased
bureaucratic burdens on schools and is generating a culture of
"self-inspection" involving inappropriate, intrusive
and unnecessary scrutiny of teachers' professional practice. This
impact was evidenced in the findings of the NASUWT's audit of
teachers' and headteachers' workload published in March 2008 which
set out the significant extent of inspection-related causes of
excessive workload.
6. The high-stakes context of school accountability
that performance tables and inspection generates also has wider
negative consequences for the development and implementation of
Government policy. For example, the New Relationship with Schools
(NRwS) agenda, which aims to streamline and modernise the institutional
relationships between schools and local and central agencies of
government, has been impacted upon negatively by unreformed systems
of school accountability.
7. Two key stands of the NRwS agenda, the
development of School Improvement Partners (SIPs) and the School
Profile illustrate these concerns. In the case of SIPs, development
of this role was intended to be the means by which a coherent
"single conversation" between schools and outside agencies
could be facilitated. However, feedback received by the NASUWT
from members suggests that, in practice, engagement between SIPs
and relevant staff in schools is focused to a disproportionate
extent on achievement of outcomes designed to satisfy the requirements
of the school accountability system.
8. Similarly, the School Profile, which
aimed to give parents relevant and meaningful information about
school performance and progress, has, as the Government itself
acknowledges in the context of its proposals to develop a school
report card, failed to secure its intended objectives. In many
respects, the lack of engagement by parents with the Profile has
been as a direct result of the continued publication of the Achievement
and Attainment Tables to which parents' attention is drawn by
their widespread use by the media in its publication of crude
"league tables" of school performance. As a result,
the information given to parents and other relevant stakeholders,
either directly by the Government or unofficially by the media,
on school performance, does not allow them to form balanced and
holistic views of school performance and adds to the difficulties
described above in respect of the impact on learners and staff
in schools of the current system of school accountability.
APPROACHES TO
SCHOOL ACCOUNTABILITY
IN OTHER
COMPARABLE EDUCATION
SYSTEMS
9. There is little evidence that performance
tables or school inspection have contributed to raising standards
of attainment in England. As the largest teachers' union in the
UK, the NASUWT has gained direct experience of approaches to school
accountability in Scotland, Wales and Northern Ireland and it
is instructive to consider the key distinctions between these
systems and that in place in England.
10. In respect of performance tables, it is notable
that the Department of Education Northern Ireland (DENI) has never
produced performance tables as part of its public accountability
measures, while the Welsh Assembly Government (WAG) and the Scottish
Government both abolished performance tables in 2001. In relation
to inspection, in Northern Ireland for example, the Education
and Training Inspectorate (ETI) takes a collegial, supportive
approach to the inspection of schools and colleges. There is no
grading system for inspections in Northern Ireland, although following
the inspection, schools are expected to produce an action plan
addressing areas for improvement. A comparable approach is identifiable
in the context of the inspection system in Scotland.
11. Beyond the UK, research also highlights
clear distinctions between the system in place in England and
that established in other countries. Extensive research by the
European Commission's Eurydice European Unit, undertaken in 2007,
provides extensive evidence of forms of school accountability
that are based on a range of different approaches that do not
rely on performance tables or punitive systems of school inspection
but that are associated with high levels of public confidence
and rising standards of educational achievement.[15]
THE STATUS
OF OFSTED
12. There can be no meaningful objection
in principle to the establishment of a dedicated school inspection
organisation within the context of a fit for purpose system of
school accountability. However, the problems identified above
in relation to the way that Ofsted operates in practice draws
attention to serious issues in respect of the basic constitution
of Ofsted and means by which it relates to its stakeholders, Government
and arrangements by which it is held to account for its activities.
13. The establishment of Ofsted was associated
with a significant alteration in the relationship between democratically
accountable ministers, the central Government departments for
which they are responsible and the organisational machinery of
school inspection. The creation of Ofsted gave executive responsibility
for the inspection of education to Her Majesty's Chief Inspector
(HMCI) as head of a non-ministerial public body (NMPB). To date,
Ofsted is the only official public body within the education system
in England with this status. The aim and consequence of this alteration
in arrangements for the inspection of education in England was
to end the ability of ministers to control the discharge of school
inspection within set legislative frameworks. The outcome of this
policy has been that the effective freedom of Ofsted to interpret
its remit within the legislative framework established by Parliament
is, to all intents and purposes, unfettered, notwithstanding its
formal accountability to Parliament required by its NMPB status.
While Parliament, through select committees and other structures,
may be able to undertake informed and appropriate analysis and,
where appropriate, criticism of Ofsted's work, there are no effective
means by which it can direct Ofsted to amend its policy and practice
where this is deemed necessary.
14. This has led to Ofsted being given the
scope to act in a profoundly undemocratic and unaccountable way.
As a key element in a high-stakes system of school accountability,
priorities that Ofsted establishes in relation to those areas
it is empowered to inspect have a considerable influence on practice
at school level, regardless of the extent to which these reflect
the policy of Government or the intentions of Parliament when
it enacts education-related legislation. Reform of the status
of the public agency charged with undertaking inspection of the
education system must therefore be a central element of future
policy in relation to school accountability.
FORM, CONTENT
AND QUALITY
OF SCHOOL
INSPECTIONS
15. Concerns have been identified at school
level that inspection judgements are increasingly data driven
and that conclusions about school performance are reached by inspectors
in advance of inspection. While a mix of sources of evidence about
school performance based on data, professional dialogue, the views
of staff on school performance and progress and evidence gained
directly from visiting schools may have an important role to play
in any fit for purpose system of school inspection, the purposes
to which this information is put within the context of the current
punitive and unconstructive school accountability regime simply
serve to undermine the ability of teachers and headteachers to
undertake their professional responsibilities and compromise public
confidence in the state education system. This calls into question
the mechanisms by which schools are identified as "failing"
or "underperforming" by Ofsted and publication of inspection
reports generated through this flawed system compound these problems.
16. The NASUWT notes the interest of the Committee
in the notice given to schools under the current inspection regime,
the extent of detail that should be included in inspection reports
and whether inspections should be tailored to the current performance
levels of individual schools. This latter point clearly relates
to the introduction of a light-touch inspection regime for schools
Ofsted identifies as "higher-performing".
17. Consideration of these points highlights
the extent to which the current inspection regime fails to reflect
the principles of effective approaches to school accountability.
In a fit for purpose system of accountability, with supportive
and development focused school inspection mechanisms, the provision
of detail in inspection reports, the extent or otherwise of notice
of inspection and the tailoring of inspection to the identified
needs of schools would all be based on an objective and informed
consideration of the circumstances of each individual school and
how schools can be helped to enhance further the quality of their
educational provision.
18. However, in the current high stakes
school accountability context, variations in the detail of inspection
reports, the introduction of short or no notice inspections and
the use of so-called proportionate inspection, simply represent
tinkering with a fundamentally flawed accountability system. A
number of the changes proposed to the inspection regime by Ofsted
for inspections conducted from September 2009 may have some
impact on the effect of inspection on staff and learners in schools
and the NASUWT would welcome the opportunity to consider these
complex issues with the Committee in more depth in oral evidence.
However, the key issue for the Committee to consider is that while
changing aspects of the operation of the current regime may lessen
or worsen to some extent the negative consequences for the education
system of the way in which inspection is undertaken currently,
establishing circumstances where inspection makes a positive contribution
to raising standards and sustaining improvement will require a
fundamental recasting of the purpose and form of inspection rather
than a series of additional amendments to the fundamentally flawed
inspection system in place at present.
19. Notwithstanding the significant flaws
in the current model of inspection, for all inspectors, both HMI
and Ofsted continue to contract externally, effective training
and development remain key concerns. For this reason, the fact
that the nature, scope and quality of Ofsted's training programmes
are not open to independent scrutiny remains an important area
of concern. Without any meaningful assessment of the fitness for
purpose of Ofsted's provision of training and development for
inspectors, confidence in the ability of inspectors to undertake
their wide-ranging and complex responsibilities will continue
to be compromised. The need for effective training is emphasised
by the increasingly complex range of issues that inspectors are
required to address including, as the Committee identifies, the
contribution of schools towards achievement of the Every Child
Matters outcomes and the promotion of pupil wellbeing, the effectiveness
of school-level policy and practice in respect of the workforce
and the duty on schools to promoting community cohesion.
20. The complaints procedure is heavily
weighted towards the judgement of the inspector and it is not
acceptable that there is no effective appeals process to challenge
an inspection judgement that relates to standards. The current
system makes it extremely difficult for individual members of
staff to pursue complaints about an inspection and the timescale
for making complaints is too rigid and excludes cases where it
has taken time for the full evidence to become available.
SCHOOL REPORT
CARD
21. In light of the limitations and negative
features of the current system of school accountability, the proposals
by the Government to introduce a School Report Card offer an important
opportunity to re-examine some of the principles and practices
associated with the current school accountability regime and to
consider ways in which more positive approaches to school accountability
might be established in future.
22. In considering the School Report Card proposals,
it should be noted that the consultation document issued by the
Government sets out broad and general principles that aim to support
more detailed subsequent work on the detail on the School Report
Card proposal. It is therefore premature at this stage to set
out details of the specific areas of school activity that should
be reflected in the Card and the relative weight that should be
ascribed to them in the formation of judgements about overall
school performance. However, the Government recognises that one
of the limitations of the current school accountability regime
is that it is not aligned closely enough with the Government's
broader vision for the 21st Century School. The Government also
makes clear its view that Ofsted inspection reports are subject
to limitations in terms of their usefulness as a means by which
a balanced view of school performance can be presented. Most significantly,
the Government recognises that the judgements derived from performance
tables and those generated through Ofsted inspections are frequently
contradictory and that additional pressure is placed on schools
by two distinct and, in important respects, non-complementary
accountability mechanisms.
23. It is clear that the Government intends
to undertake a detailed and thorough consideration of all the
key issues associated with approaches to school accountability
as part of its development of the School Report Card. In light,
however, of the Government's initial rationale for proposing the
development of a school report card, it is apparent that the continued
existence of a school accountability regime based on narrowly
focused performance tables and an outmoded and highly detrimental
system of school inspection has become a legitimate area for debate.
March 2009
15 Eurydice (2007) School Autonomy in Europe: Policies
and Measures. Brussels, Eurydice European Unit. Back
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