Supplementary memorandum submitted by
NASUWT
This supplementary evidence responds to the
questions posed by members of the Select Committee at the oral
evidence session held on 16 March 2009.
SPECIFIC COMMENTS
What should schools be held accountable for?
1. The NASUWT shares the Government's view
that the principle emphasis of the work undertaken by teachers
and headteachers is to focus on teaching and learning. Therefore,
an effective system of school accountability would rightly place
significant emphasis on this aspect of a school's work. However,
it is also apparent that schools make a broader contribution to
the wellbeing and development of pupils and society more generally.
This is reflected, for example in the duty on schools to promote
community cohesion and pupils' wellbeing. Therefore, it is appropriate
that these aspects of schools' work with pupils should also form
part of school accountability. This is reflected in the Government's
initial proposals for the form and content of the School Report
Card.
To what extent should schools be accountable to
Government and Ofsted?
2. As a publicly-funded universal state service,
the education system is held and managed in the public interest
and must therefore, be accountable at national and local level
to those democratically elected by the public. The education system
should not be accountable to Ofsted. The body responsible for
inspection should provide the means by which the system is held
to account and not be an entity to which the system itself is
accountable.
What effect does the manner in which results are
reported have on schools?
3. The public has a right to information about
the education system and therefore it needs to be made publicly
available in an appropriate way. However, the current publication
of inspection reports and performance tables, which do not reflect
accurately the full range of work that staff in schools undertake
with children and young people, serves only to intensify the high-stakes
nature of school accountability with its significant negative
consequences for perceived failure.
4. The implications at school-level of this are
increased pressure and stress on staff and learners and a skewing
of the curriculum offer made to pupils because the focus is to
meet the requirements of the school accountability regime rather
than the needs of pupils being paramount.
5. This approach to accountability has promoted
a culture of teaching to the test, led to curriculum inflexibility
and narrowing and has put staff in schools under pressure to target
resources at borderline achievers to push them into a higher grade
to meet performance league table targets. In practice, the use
of performance tables has worked to undermine teachers' professionalism
and autonomy by breeding competition between schools rather than
supporting collaboration and the sharing of good practice.
How can it be ensured that parents are involved
in the assessment process?
6. The NASUWT has no objection in principle
to the use of appropriate means by which the perspectives of parents
and pupils should be able to make a contribution to an appropriate
system of school accountability. Clearly this is dependent to
a significant extent on ensuring that parents have effective,
timely and proportionate access to information about their child's
progress at school in a variety of ways.
7. However, the widely advocated approach of
relying heavily on opinion surveys of parents and pupils is problematic
in many respects, particularly in relation to the fact that views
of pupils and parents on the quality of provision in schools may
differ significantly depending on individual circumstances, such
as whether a parent's child has SEN or accesses some other form
of specialist service and that not all parents are inclined to
or well placed to provide feedback in this way. This highlights
the point that while information gathered in this way may be useful,
a degree of caution has to be exercised over its use.
Would school standards plummet if Ofsted disappeared?
8. There is little evidence that performance
tables or school inspection have contributed to raising standards
of attainment in England. Comparison with systems in other countries
and elsewhere in the UK indicates that it is possible to achieve
and sustain high educational standards and retain public confidence
in the education system without the flawed system of school accountability
in place in England. Consequently, the NASUWT does not believe
that school standards would plummet if Ofsted in its current form
disappeared.
What would make the system of inspection more
effective?
9. This is a critical and wide-ranging question
that goes to the heart of the issues that the Committee is investigating.
The NASUWT's initial written evidence sets out in detail the reforms
that the Union believes need to be put in place in order to establish
a more effective system of inspection in particular and school
accountability. However, it is clear that the principles upon
which inspection frameworks are established, the purpose of inspection
and the role and function of the public body charged with inspecting
schools in a more constructive system of inspection would require
fundamental change to the way in which Ofsted currently undertakes
its responsibilities. The Union believes that these principles
should ensure that systems of inspection:
— 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;
— not duplicate other systems of monitoring,
performance management and support;
— provide judgements that are fair and
in which the profession and the public can have confidence;
— 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.
What could be done to address variability in the
inspection process?
10. The Committee is right to highlight
the issues of variability in the inspection framework. The NASUWT
is clear that a number of issues drive the unacceptable degree
of variability in the system.
11. First, Ofsted training of its inspectors
is not open to rigorous external scrutiny. For this reason, serious
questions about the capacity of individual inspectors are raised
on a consistent basis by teachers and headteachers. This is reflected
in feedback from members, particularly in relation to the frequent
failure of inspection teams to take account of the policy context
within which inspections are being undertaken.
12. Second, Ofsted has no effective system
for quality assuring its inspections. It is, therefore, unable
to learn lessons from incidents of poor practice and thereby put
in place reforms designed to secure greater consistency.
13. Finally, the definitions used by Ofsted
for judging performance are not clear or consistent and have been
subjected to significant changes in meaning since Ofsted was established,
the effect of which is to continually "raise the bar"
in relation to judgements of acceptable school performance. This
is a particular issue in respect of the way in which Ofsted judges
and views performance it assesses as "satisfactory".
It is therefore not surprising that the way in which descriptions
of performance levels set out in the inspection framework are
applied in practice can vary to a significant extent. As part
of a package of wider reforms to the inspection system, these
issues would need to be addressed if issues of variability are
to be tackled successfully.
Do teachers have sufficient redress to respond
to critical remarks from Ofsted?
14. See 15 below.
Should there be an appeal process in response
to Ofsted judgments, and if so, what form should it take?
15. An effective system of complaints and appeals
is an essential feature of an effective and equitable system of
school accountability. However, this is clearly not the case in
respect of the current system. In its work representing teachers
and headteachers, the NASUWT has gained significant experience
of supporting members involved in complaints against Ofsted. The
Union is particularly concerned that 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 Union is also concerned that the current system makes it extremely
difficult for individual members of staff to pursue complaints
about an inspection. This relates, to a significant extent, to
the lack of transparency in the complaints process. Complainants
may be told that there is evidence to back up the inspection findings
but are not told what that evidence is. These aspects of the system
are in urgent need of reform.
16. The timescale for making complaints is too
rigid and excludes cases where it has taken time for the full
evidence to become available. Timescales for making complaints
should be amended so that complainants have the time necessary
to gather evidence. Ofsted should also consider introducing an
independent advice line to enable schools to raise issues and
concerns immediately following an inspection.
17. There are significant concerns about
the process used to deal with complaints to Ofsted directly from
the public and parents. These can remain on file and be used to
inform inspection even if they are not valid complaints in the
terms of Ofsted's remit.
What would be the appropriate length of notice
for Ofsted inspections?
18. In the current high stakes school accountability
context, variations to the degree of notice given to schools simply
represent tinkering with a fundamentally flawed system. In some
respects, current proposals to introduce no notice inspections
could compound the problems associated with the current inspection
system as staff in schools are under pressure to be prepared to
respond to an inspection at all times in effect schools are on
a permanent "war-footing". In a fit for purpose system
of accountability the extent of notice of inspection would be
based on an objective and informed consideration of the circumstances
of each individual school and how schools can be helped to enhance
and develop further the quality of their educational provision.
Is the manner of inspection Ofsted carries out
in relation to child welfare as apt as the manner of its inspections
in schools in assessing quality assurance?
19. The NASUWT does not accept that any aspect
of the current system overseen by Ofsted represents an effective
system of assessing the quality of educational provision. Given
the trend for Ofsted to seek to bring greater degrees of similarity
between its inspection frameworks across all its areas of responsibility,
there is certainly a risk that the problems associated with the
school inspection system, with which the NASUWT has direct experience,
could translate into its inspection of child protection. Oftsed's
remit has increased significantly since it was first established.
In the NASUWT's view, there are legitimate questions to be considered
in respect of the extent to which this remit has now become so
broad, that Ofsted is now not capable of discharging any of the
specific functions effectively.
Does the value of self-assessment have a weighting
in the assessment process?
20. See 22-23 below.
Do external operators give the self-evaluation
process more credibility and is this worth the cost?
21. See 22-23 below.
What role should self-evaluation play in school
accountability and the inspection process?
22. The views of staff in schools on levels of
performance and areas of strength and weakness based on informed
professional reflection have the potential to provide an important
source of information by which a fit for purpose system of school
accountability may form judgements about the education system.
This would depend critically on this system being based on the
clear understanding that self-evaluation in any form is only valuable
if professional judgements are trusted and respected. However,
the use of self-evaluation as part of the inspection process continues
to undermine work to reduce teachers' and headteachers' workload
and organisational bureaucracy.
23. Evidence from NASUWT members suggests strongly
that the need to collect evidence and produce documentation to
justify schools' self-evaluations is leading to increased bureaucratic
burdens on schools and is generating a culture of "self-inspection"
involving inappropriate, intrusive and unnecessary managerial
scrutiny of teachers' professional practice. However, previous
systems of school inspection which were less reliant on self-evaluation
and made greater use of external inspectors, because it was based
on the same flawed principles of inspection as the current system,
did not represent a more effective or equitable approach. Before
questions of the use or otherwise of external inspectors can be
considered meaningfully, more fundamental reforms to the purpose
and nature of inspection must be pursued so that judgement of
the appropriate balance to be stuck between internal and external
assessment of performance can be made within a recast school accountability
context.
Is too much money spent on the inspection process?
24. It is clear that the costs of holding
public services to account must be proportionate. This principle
was reflected clearly in the Government's Office of Public Sector
Reform's 2003 document "Inspection for Improvement."
However, it is also clear that such systems must be resourced
to an extent that allows them to undertake their responsibilities
effectively. The NASUWT believes, therefore, that public money
directed towards a constructive and equitable system of school
accountability would represent an appropriate use of these finite
resources. However, given the negative impact of the current system,
it is clear that the money spent on funding Ofsted is not being
deployed as effectively as it would be if the system were to be
reformed on the basis set out in the NASUWT's initial written
evidence. Ofsted's budget, as with all public sector inspectorates
has been reduced in real terms within the current public spending
settlement from previous levels. However, it is clear that the
fundamental solution to the problem of school accountability in
the system in England does not lie in either increasing or reducing
further Ofsted's budget but by reforming the basis upon which
school inspection is undertaken. An inspection system reconstituted
on these terms would then allow an objective assessment to be
made on the costs that would be associated with establishing and
maintaining the accountability system.
Can school report cards provide greater accountability
to the community?
25. See 26-27 below.
Do school report cards have a valuable and legitimate
place in terms of having accountability for schools?
26. As made clear in the NASUWT's initial written
evidence, the proposal by the Government to introduce a School
Report Card offers an important opportunity to re-examine some
of the problems associated with the current school accountability
regime and to consider ways in which more positive approaches
to school accountability might be established in future. The basis
upon which the current system attempts to measure and report school
performance is extremely narrow, as the Government has acknowledged
and is inconsistent with its proposals for 21st Century Schools.
The judgements reached by Ofsted and those reflected in performance
tables are also often contradictory.
27. In the NASUWT's view, successful implementation
of a useful, purposeful and constructive system of school accountability
through the School Report Card cannot be undertaken satisfactorily
without detailed and considered analysis of the extent to which
such a system could replace a school accountability regime based
on narrowly focused performance tables and an outmoded and highly
detrimental system of school inspection. If the aim of the Card
is to provide a streamlined, consistent and holistic view of the
work of staff in schools, then it has ability to do so.
March 2009
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