Memorandum submitted by The Independent
Schools Inspectorate (ISI)
1. The Independent Schools Inspectorate (ISI) is
a body approved by the Secretary of State for the inspection of
schools in membership of the Associations of the Independent Schools
Council (ISC). As a body independent of government, ISI aims to
provide an informed commentary on education issues as well as
providing a high-quality inspection service. It regularly responds
to consultations and inquiries, as well as working with all of
the main political parties on education issues.
2. We responded to the Select Committee's previous
inquiry into school accountability, and would reiterate our comments
to that inquiry. We add the following comments in line with the
topics under current consideration.
What the purposes of inspection should be (relating
not only to schools but to all organisations, settings and services
under Ofsted's remit)
3. We believe that inspection should have two purposes:
(1) to secure conformity with minimum standards, for the benefit
of those that organisations are designed to serve and (2) to promote
improvement.
4. Improvement that is secured by dictating the processes
or procedures that organisations should follow has only limited
success because it stifles creativity and restricts the possible
routes to excellence. Inspection should instead focus on identifying
areas for improvement within an organisation and recognise the
strengths that can be further utilised to secure the desired outcomes.
The impact of the inspection process on school
improvement
5. The impact of inspection varies according to the
type of school and other support systems in place. The previous
incarnation of the Select Committee, in its report on School Accountability,
raised concerns that "the Government's 21st Century School
White Paper signals even greater complexity in an already overly
complex system of school accountability and improvement initiatives".
ISI had already responded in similar terms to Government consultations
on the report card proposals, and pupil wellbeing indicators.
Inspection to date has led to significant improvements in the
education, care and welfare of pupils and the public reporting
it provides enables parents and others to make informed choices,
enabling a much stronger partnership between schools and parents
than existed previously. Inspection is especially effective when
inspectors can spend time on direct observation of lessons and
other activities, scrutinising work, and in direct discussion
with pupils and staff. It is on this first hand evidence that
secure judgements can most readily be made. However, the increase
in complexity of regulation in recent years has placed increasing
demands on inspector time to a level that is now disproportionate
to the time spent on helping schools to improve the care and education
that they provide.
The performance of Ofsted in carrying out its
work
6. The size of Ofsted, coupled with its budgetary
constraints in recent years, has in our view led to a loss of
flexibility within its operations which has made joint working
more difficult for all involved. We would cite two examples. Firstly,
the quality assurance of the inspection of British schools overseas.
Ofsted have required in-depth on site monitoring overseas, equivalent
to that carried out for its statutory remit. This increases costs
to all concerned in a voluntary and non-statutory process. Secondly,
the inspection of Association boarding schools which transferred
to Ofsted from CSCI in April 2007. This represents a very small
piece of work for Ofsted and did not appear to readily fit into
its existing processes. Consequently, from the point of view of
those being inspected and ourselves working with Ofsted on inspection
of the same schools, the work has suffered from organisational
difficulties. Certainly, the system works better now than at the
start, but that has taken many hours of time and effort by Ofsted
staff, schools and ourselves. Even after three years schools receive
inconsistent experiences of these inspections. We would stress
that Ofsted staff, including HMCI, have sought to resolve difficulties
whenever they have been raised but because of interdependence
between systems and processes designed for a range of different
functions change can be slow to achieve.
The consistency and quality of inspection teams
in the Ofsted inspection process
7. We do not have direct experience of inspection
teams but many Ofsted Additional Inspectors (AIs) apply to ISI
to work as Reporting Inspectors. Our intensive training includes
a number of assessed tasks and we have found that some AIs do
not have a secure grasp of the full range of regulatory requirements.
The weight given to different factors within the
inspection process
8. We welcome the Government's recent announcements
regarding refocusing inspection on the key features of education.
Removing ancillary elements, such as community cohesion, prevents
schools being penalised for issues which may be beyond their direct
control. The regulatory context is crucial because of its impact
on inspector time. We strongly support the need for a clear set
of minimum regulatory standards for schools but for these to be
effective the requirements should be clear and concise, based
on outcomes required rather than processes involved. In particular,
all duplication of requirements should be removed. We would reiterate
our suggestion that independent schools should be subject to a
central core of regulations that apply to all settings and that
take account where necessary of any additional requirements for
early years and boarding welfare. This should remove the overlapping
of different sets of regulations that make it extremely difficult
for schools to know precisely what is required of them. Regulations
should be easy for all to understand what is needed, not just
those who are specialist in the field of regulation. We would
also suggest that inspection judgements should be left to the
professional discretion of the lead inspector, and not subject
to limitation by the inspection framework.
Whether inspection of all organisations, settings
and services to support children's learning and welfare is best
conducted by a single inspectorate
9. We recognise that the current practice of collaborative
working has advantages but continue to question whether one organisation
can deliver excellence across such a wide remit and develop the
strength in depth to meet the needs of multiple inspection frameworks
applicable to a wide range of very different settings.
The role of Ofsted in providing an accountability
mechanism for schools operating with greater autonomy
10. For maintained schools and similar provision
within Ofsted's remit, it is reasonable for the government to
insist on accountability through inspection to confirm that public
funds are being spent wisely and to good effect. However, for
wholly private provision, inspection to safeguard the education
and welfare of children against minimum standards should be organised
separately through a government approved inspectorate to take
account of their different context.
October 2010
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