Memorandum submitted by Tony Lau-Walker,
Chief Executive of Eastleigh College and Chair of the Windsor
Group of Colleges
1. Executive Summary
1.1 In further education, especially where employers
and adult learners predominate, Ofsted represents poor value for
money with its slow and burdensome inspection regime ill-suited
to promote improvement and focussed too much on full time in-college
courses for 16-18 year old learners.
1.2 It makes no attempt to use other performance
monitoring frameworks currently developed and used for commissioning
or quality kitemarking, and does not attempt to recognise or enable
the movement to peer review within the sector.
1.3 There is a need for the reform of Ofsted's
over generalised framework which tries to be all things to all
providers as it tries to cope with a much expanded portfolio of
responsibility.
1.4 A regime of shorter curriculum specific visits
'little and often' would provide better information to guide consumers
in their take up of FE. This approach would provide energy to
the movement towards rigorous self development in the sector and
provide current benchmarking standards that are no longer available.
1.5 To mirror the practice in higher education
Ofsted should focus their judgements on curriculum provision rather
than the providers to better inform the public regarding the standards
they can expect when making their choices.
2. Introduction
2.1 The following commentary is provided specifically
on the role of Ofsted in inspecting General Further Education
colleges (GFEs). As chief executive of an established Beacon college
which serves its local community well and has an extensive employer
engagement provision, and with experience of work as an additional
inspector the observations contained in the following paragraphs
is a personal observation based on work with a large number of
other GFEs in quality development and peer review.
2.2 Ofsted is one of several inspection regimes
experienced by the author in the past thirty years. Prior to incorporation
colleges were subject to irregular inspections, producing private
reports shared between college and local authority, and were not
very successful in either raising standards or identifying ineffective
institutions. FEFC introduced a regime which was regular and effective
at identifying major thematic issues for the sector to address
- such as Governance & Management, Quality of Outcomes and
Learner Support. This regime saw itself as having a responsibility
to assist colleges with improvement through the identification
of college inspectors to oversee ongoing improvements between
inspections.
3. What the purposes of inspection should
be (relating not only to schools but to all organisations, settings
and services under Ofsted's remit)
3.1 Introduced in 2001 Ofsted refocused the inspection
priorities to the quality of teaching and learning - what happened
in the classroom or workshop - and undertook a tight four year
cycle of visits, but did not see itself as having a direct relationship
with colleges in terms of improvement. After one cycle of inspections
the focus shifted back to the more generic cross college themes
that had dominated the FEFC regime, and spent less time inspecting
the learners' experience. The final iteration of the Ofsted inspection,
based on a six year cycle, introduced increased bureaucratic complexities
with 274 areas to question as it tried to merge the generic inspection
of the institution with the curriculum inspections it had started
with in the first cycle.
3.2 The final round of changes introduced such
complexity that the impact of the inspections has become devalued,
overly bureaucratic, apparently politically motivated and unresponsive
to the key aspects of the further education agenda such as employer
engagement and local responsiveness. General further education
colleges strongly committed to employer engagement have had their
inspections more focused on safeguarding, while sixth form colleges
have had their adult provision discounted or ignored during inspections
and reporting. Hence the growth of additional inspection frameworks
applying to the sector - Framework for Excellence instigated by
the funding agency to enable better performance monitoring, and
Training Quality Standards to address employer engagement directly.
If the Government want colleges to show responsiveness to local
needs as part of a single line adult funding stream there is likely
to be a further quality mark or regulatory body. Despite Ofsted's
existence the sector has been seen to need a multiple system of
regulation/quality kitemarks.
3.3 The capacity of the funding agency has grown
substantially to effectively monitor performance through the system
of Minimum Levels of Performance (MLP) to commission and decommission
provision, and to comparatively grade through the Framework for
Excellence using direct student and employer inputs, and following
up outcomes with progression checks. In addition the Training
Quality Standard assessments examine directly the effectiveness
of colleges to engage with employers and the Sector Skills Councils.
If these mechanisms are to survive then Ofsted needs to develop
a low cost approach to the inspection of delivered curriculum,
going back to their original sampling of the learner experience,
grading provision instead of institutions.
4. The impact of the inspection process on
school improvement
4.1 College improvement under the current Ofsted
scheme is an indirect and imprecise outcome. The Common Inspection
Framework (CIF) is an unwieldy and generic tool which covers all
types of further education provider. As such the CIF is not suited
to effective diagnosis of improvement needs other than in a most
general sense. Without a specific framework designed to be fit
for purpose to differentiate between types of FE providers and
suit their mission it is inevitable that general recommendations
for improvement are the outcomes of a very expensive process.
4.2 In fear of adverse publicity from the published
inspection report General Further Education colleges (GFEs) need
to work carefully to interpret the generic framework to focus
on inspectors' priorities rather than the priorities of the learners
and their employers. Improvement comes from direct and relevant
performance monitoring rather than a general review and the CIF
suffers from this lack of specificity to the local need and employer
engagement mission of the GFE. Ofsted has not reduced poor performance
in the sector as comprehensively as the annual monitoring of MLP
and commissioning through contract variation based on results.
4.3 If Ofsted is to contribute directly and cost
effectively to the improvement agenda it needs to adopt a more
flexible approach that addresses curriculum delivery in the context
of the specific learners rather than generalizing a framework
from a 16-18 college-based learner context across all providers.
It needs to become part of a system of performance management
and quality control by recognizing and making use of other quality
frameworks and performance monitoring, and most importantly, it
needs to recognize the mission focus of the provider being inspected.
5. The performance of Ofsted in carrying out
its work
5.1 In carrying out its work Ofsted tends to
focus on full time 16-18 learners almost exclusively - in a college
of 18,000 learners the 1,800 which are 16-18s tend to get the
vast majority of inspection time and the bulk of the inspection
report. This prejudice has been evident since the adsorption of
the Adult Inspectorate, and is a product of seeking to use a single
framework approach to all those sectors for which it is responsible.
In trying to create a simplified response to all its increased
responsible areas it has lessened its impact and relevance for
GFEs. While individual inspectors can make an effort to give the
proportionate weighting to reflect the individual provider this
rarely happens and the prejudice towards full time college-based
courses predominates. This bias or tendency is also reflected
in the text of reports.
6. The weight given to different factors within
the inspection process
6.1 Ofsted produces a single grade for overall
performance for the provider. This would be relevant if each provider
- as nurseries or schools are expected to do - provides the same
service to the community it serves. This assumption is not accurate
or relevant for the FE sector where diversity rather than homogeneity
is the distinct characteristic. The mission of a sixth form college
is not the same as that of a GFE. Moreover, the range and diversity
of a GFE differs from one to another. The requirement to reduce
to a single grade is, therefore, misleading - because it suggests
or rather insists that one can be compared to another - and unhelpful.
In fact there is no need to adopt or continue this approach, an
alternative already works perfectly well post- sixteen and that
operates in Higher Education.
6.2 The system operating in Higher Education
monitors and grades the provision and not the provider. Hence
there is no inspection regime that grades Oxford or Imperial College
as 'outstanding' because it is their provision which is assessed
not the institution as a whole. In the FE sector the obsession
of treating colleges like schools has lead to the single grade
concept and in the context of creating better consumer information
to aid choice this is dysfunctional. Consumers' choice of provision
should be informed by inspection at the moment it is not. As long
as the provider is graded then the information is partial and
imprecise. An 'Outstanding' college does not have all their provision
at that standard, some of it will be 'outstanding' but some will
be only 'good' and some may even be only 'satisfactory'. In the
same way, a 'Good' provider likewise may have some 'outstanding'
provision, some 'good' and some 'satisfactory'. For example, last
year Ofsted inspected 54 GFEs, of which two were graded 'outstanding'
overall and two were graded 'inadequate'. This is a simple picture
but a misleading one for the potential consumer as there were
17 outstanding curriculum grades awarded - and neither outstanding
college gained outstanding in each of the curriculum areas inspected.
The Government's desire to provide smarter information about performance
is not aided by Ofsted's current approach. Indeed, Ofsted, by
giving overwhelming prominence to generic grades like 'overall
performance', 'capacity to improve' and 'leadership and management'
at the expense of shorter more frequent curriculum judgments is
being unhelpful and poor value for money for the consumer.
7. Whether inspection of all organisations,
settings and services to support children's learning and welfare
is best conducted by a single inspectorate
7.1 The conclusion of the arguments expressed
above lead to the conclusion that GFEs focused on serving local
needs and meeting the needs of employers and economic prosperity
are poorly served by a single framework bureaucracy. The generalised
framework of assessment is only partially relevant to these colleges
and judgements are made without full and proper consideration
of the whole mission of the provider. The loss of the Adult Inspectorate
is unfortunate for the providers commissioned by the SFA and a
reform of Ofsted should reflect the diversity of needs from the
two commissioning bodies - YPLA and SFA.
7.2 Without creating a new body a simplified
inspection framework could be created that provides short sharp
inspections of provision - not providers - as the good practice
visits have done in the past, while working in partnership with
the commissioning bodies who use MLP information to shape provision
on an annual basis. Such an approach would cost less yet it would
serve the improvement agenda better. Inspections that are 'Little
and Often' and part of a network of monitoring are going to have
more impact in stimulating an improvement culture in the sector
than 'big and infrequent'. Different parts of the college will
be inspected frequently replacing the great upheaval every six
years. Such an approach will enable colleges to drive their own
improvement providing them with relevant and current benchmarks
of good practice.
8. The role of Ofsted in providing an accountability
mechanism for schools operating with greater autonomy
8.1 The funding agencies - especially the SFA
- have developed their commissioning role so that naturally available
data is used annually to monitor and manage performance. Hence
accountability is embedded in this process and is exercised annually.
Ofsted's long cycle of visits cannot be argued to assist or enhance
this process. Indeed, the commissioning practice can be seen to
diminish the need for the heavily bureaucratic approach of Ofsted.
Likewise, colleges have 'grown up' and now take a more rigorous
and active responsibility for their own improvement. The role
of Ofsted should be transformed to reflect these parallel developments
and, for the vast majority of colleges there should be more focus
on enabling self improvement and peer review.
October 2010
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