Memorandum submitted by City and Guilds
EXECUTIVE SUMMARY
OF THE
CITY & GUILDS
SUBMISSION
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. INTRODUCTION
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. FACTUAL INFORMATION
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 pointgreater 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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