- Children, Schools and Families Committee Contents

Memorandum submitted by City and Guilds


  1.  City & Guilds response to the inquiry is from a vocational qualifications standpoint.

2.  City & Guilds believe the proposals demonstrate the potential to maintain quality whilst providing a flexible and fit for purpose system.

3.  The shift from a deficit model of inspection to one of continuous improvement is imperative if the schools system is to compare favourably internationally and to gain the confidence of learners, parents and politicians that real value is being added.

  4.  Greater accountability, responsibility for and ownership of inspections results and all that they entail at school level is fundamental to embedding a continuous improvement agenda. This will, however, require access to accurate and robust data sets and the ability to work with such material for benchmarking purposes and to develop improvement strategies.

  5.  Inspections cycles should be based on risk.

  6.  Clarification of measurement criteria is essential.

  7.  A consistent approach to notice periods is essential.

  8.  The ability to implement unannounced visits should be retained, as long as such inspections are justified and applied consistently.

  9.  Health checks provide valuable intermediate feedback on performance and progress. The hiatus between inspection visit and health check submission needs to be tightly governed to ensure the system of trust that it is predicated on is sustainable.

  10.  All inspection related evidence (including reports and health checks) should be in the public domain, thereby supporting the sharing of key data and information. The shared use of information, data and intelligence, informing all relevant stakeholders, including awarding organisations, will better ensure collective responsibility to adding value.


  1.1  I am the Director of Assessment & Quality at City & Guilds. I have worked in the vocational education system for over 20 years. My career focus has been on the efficacy of assessment, how individuals learn, and strategies for retention and achievement; underpinning all of this has been the role of inspection in assuring quality delivery and outputs.

1.2  It must be made clear at the outset that City & Guilds is a vocational awarding organisation that has as its primary focus the assessment and certification of vocational knowledge and skills. Our market is generally 16+ and the average age of our candidature is around 30. We do, however have significant domain expertise in 14-19 arena and are fully engaged with Diplomas, strengthening our involvement with young people and the systems that support their development.

  1.3  We have over 500 qualifications on offer and deliver to around 7,000 centres in the UK. A centre can be anything from a FTSE 100 employer, to a College of Further Education, a Sixth Form college, a private training provider, small employers, youth offending institutions or, as indicated above, schools.

  1.4  We issue around 1.5 million certificates a year. We believe that about one in five adults within the UK hold a City & Guilds certificate.

  1.5  Throughout our 130 year history a primary driver has been ensuring the quality of the provision and the associated output. Inspection in myriad forms has played a central role in this. Equally it has provided clear evidence toward the continued maintenance of our approval to operate as an awarding organisation.

  1.6  The information provided to Ofsted for inspections purposes does not meet the requirements currently placed upon City & Guilds by the Regulator (Ofqual). This information is, however, valuable in providing us with performance data, details of financial health, graded judgements in each area of learning, performance information and feedback on its capacity to improve from its own perspective. Equipped with this information we are better able to agree an appropriate level of support and monitoring from City & Guilds.

  1.7  With regard to the interests of the Select Committee we seek to offer some general observations on the principles and purposes of accountability and inspection and would welcome the opportunity to provide oral evidence on the 22 April.


2.1  Accountability

  2.1.1  In response to calls for reduced bureaucracy, acknowledgement of the professionalism within the sector and the reliance of trust that the proposals outline, a reciprocal requirement on schools will be greater accountability, responsibility and ownership of inspection results, (retention and) achievement data, quality of provision and capability to improve. If communicated carefully, referencing and recognising the professionalism that exists within the system, this can, and should, be seen as a positive step forward. It is not, however, without impact and it should be anticipated that there will remain a certain level of nervousness as a result. One would expect that this tension would be less than is evident in the current inspection regime.

2.1.2  The proposals identifying greater accountability on senior management within schools are a natural and appropriate progression. There will be a need to help schools evolve in their practice so that they can manage the requirements this places on them. Although there is evidence of an increased confidence in using performance data it is necessary to see this evolve further still to the point where schools that are data rich continue to use that evidence to benchmark their own performance within and across schools and to set out their own improvement journey.

2.1.3  The management of a system thus defined, with regulators liaising with stakeholders to build an accurate picture based on local intelligence, demonstrates added value and generates both public confidence and value in the inspection service improvement agenda but also in school accountability. The next step in this agenda would be to not only share inspection results and health checks but to share improvement plans and most importantly outcomes that are generated by the schools themselves, thereby creating a virtuous circle of improvement by sharing best practice. In an attempt to manage any associated bureaucratic impact on schools, Ofsted could add value here by adopting a philosophy of sharing best practice and publishing this evidence, thereby minimising the demands placed on schools.

  2.1.4  Holding such data at a school level with the ability to drill down to specific areas of concern ensures that individual schools adopt accountability for their data and the performance it attests to. Of equal importance is that it ensures that learners and their parents are better informed and can take meaningful decisions about the schools they engage with. This in turn will give clear messages to and about the school, the resources on offer and service provided.

  2.1.5  In so doing it must be recognised that the general qualifications process remains a highly competitive one and a learner's success depends heavily upon the school they attend and the resources that school is able to secure. In this sense it is not a "fair" system. It will not be "fair" until all learners are able to access equivalent resources delivered to a common standard. While the same criticism can be made of vocational qualifications the system has embedded procedures to reduce the variability.

  2.1.6  National Vocational Qualifications (NVQs) are regulated by Ofqual. The NVQ is a performance-based qualification underpinned by specific occupational standards. The current NVQ Code of Practice details agreed principles and practice for the quality assurance of qualifications and units and clearly articulates the responsibilities of awarding organisations and centres. This provides the basis upon which the regulator monitors the performance of awarding organisations.

  2.1.7  Assessment within an NVQ is underpinned by strategies prepared by awarding organisations and Sector Skills Councils (SSCs) and accredited by Ofqual. These strategies clearly spell out the requirements for external quality control, where assessment should/should not take place and specific requirements for those assessing and quality assuring. Coursework is evidenced through a portfolio, a physical or electronic document that maps the learner's progress of performance/skills demonstration through the various units of the award. A locally based, occupationally competent assessor who has the opportunity to ask questions, challenge and reconfirm the performance carefully monitors and confirms the learner's achievements.

  2.1.8  All occupationally competent assessors must also hold a nationally approved assessors qualification to ensure consistency of practice. Every centre delivering an NVQ must meet regulated approval criteria. Each centre is regularly visited by a representative of the awarding organisation, who will also hold a nationally approved qualification, to ensure that the centre is maintaining the occupational competence standards in its assessment practices. The proposed inspection regime must aspire and work to support the same end point—greater confidence in the system and the results.

  2.1.9  The management of this system through regulation provides a reassuring degree of independence that we believe is valued by the consumer. Greater accountability is brought to bear as an awarding organisation's reputation depends upon their ability to deliver and market forces exert continued pressure on the system to ensure high levels of quality assurance.

  2.1.10  The benefit of this system is that ownership and accountability resides with the awarding organisation and the centre itself rather than with what could easily be perceived as a bureaucratic government department. Further, awarding organisations have the ability, expertise and relative freedom to refine their approach to maintaining quality standards so that they can respond to the varied needs of myriad customers (centres).

2.2  Inspection

  2.2.1  Inspection systems per se, the current school systems included, have a tendency toward a deficit model focusing on issues of non-compliance even when with regard to learners outcomes. As such, the shift toward an improvement agenda that places onus on the school to demonstrate their professionalism and ability to make improvements is a welcome departure. City & Guilds agrees that the inspection should take more account of continuous improvement and would like to see development plans to support this.

2.2.2  The inclusion of recommendations that focus on areas where improvements are needed are a fundamental part of any inspection agenda, particularly where that system seeks to bring about improvement. As such we would continue to support the call that improvement requirements as identified through inspection have a corresponding action/development plan which also gives due attention to capacity to improve.

  2.2.3  City & Guilds welcomes Ofsted's proposals that future inspection activity should be proportionate to risk, using the full range of indicators available to the school and the inspectorate and we made a formal response to the recent consultation which put forward these proposals. The ability to tailor indicators of risk to specific needs and criteria would bring in the required flexibility and go some way to recognising that all centres are not uniformed.

  2.2.4  The proposed inspection cycles, be they six (6) or three (3) years, supported by health checks enable "right touch" methodology to be applied and should be supported. Six (6) years is, however a long time in the life of a school/centre. Although a provider may have demonstrated to Ofsted that they have fulfilled the requirements to achieve the grade of outstanding or good, a change of key personnel with responsibility for quality assurance may have a dramatic impact on the provider's ability to continue to operate to the same standard.

  2.2.5  Anecdotal evidence suggests that although a provider has been awarded an outstanding or good grade, it does not make them immune to allegations of suspected malpractice, which through investigation may be substantiated. As such, further consideration must also be given to the remote nature of the health checks and their timeliness/frequency in juxtaposition to the system of trust that such an arms length relationship demands. This is particularly important when it ultimately influences the level of inspection that is to follow.

  2.2.6  Transparency is of utmost importance in any inspection regime; it enables data to be shared across stakeholders, for information to be submitted once and used many times and equally impacts on levels of accountability. It allows informed decisions to be taken based on local intelligence and helps engender the relationship of trust that any remote assessment relies.

  2.2.7  The information provided by centres is only as good as the centre's ability to produce it accurately. Some centres may seek to present evidence in a particular light, taking advantage of the trust the system imbues to them. In recognition of this, the publication of health checks would be a positive step providing performance and standards information to both current and prospective learners and their parents. Incumbent on the publication of the health checks is a reciprocal demand on the inspection system: it is imperative that health checks are rigorous and factually correct before entering the public domain.

  2.2.8  Clarification of the measurement criteria is essential. It will, however, have a direct impact on the associated inspection cycle. Discrimination across a particular grade (ie satisfactory) will require tight action planning and clear measures agreed. This in turn has the potential to lead to twin-banding within a single grade.

  2.2.9  A consistent approach to notice periods is essential. The ability to implement unannounced visits should be retained, as long as such inspections are justified and again applied consistently.

  2.2.10  By adopting the stance outlined in the proposals and enumerated above Ofsted have the opportunity to add real value to schools in support of their learner outcomes. As the system matures there should be a reciprocal expectation that comparisons internationally will see a significant improvement thereby generating greater learner, parental and political confidence in the system.

Dr Vikki Smith

Director of Assessment and Quality

April 2009

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