Memorandum submitted by Wandsworth Council
Executive Summary
(a) Local authorities can support this role more
effectively with stronger powers of earlier intervention.
(b) The majority of Ofsted inspection teams are
fair, consistent and professional. However, variability can lead
to inconsistent judgements
(c) The annual assessment process introduced
in 2009 has not been successful.
(d) Having sufficient, skilled, knowledgeable
and well-trained inspectors is more important than the question
of whether the scope of Ofsted's remit is too broad.
Submission
1. Wandsworth Council is an Inner London local
authority with an estimated population of around 288,000, of which
nearly 60,000 are under 19. Local children's services have been
judged by Ofsted to be Outstanding in each of their last five
annual assessments.
2. The local authority supports 537 settings,
schools or services which are subject to Ofsted inspection. In
addition to this Ofsted also undertakes:
— an
annual assessment of the effectiveness of Wandsworth children's
services as a whole;
— an
annual unannounced inspection of referral and assessment;
— a three
yearly announced inspection of safeguarding and looked after children
services;
— inspection
of private fostering arrangements; and
— a review
of the effectiveness of any serious case reviews conducted in
the borough.
The Purpose of Inspection
3. The main purpose of inspections should be
to provide a mirror to organisations which supports them in the
process of self-identification of strengths and weaknesses. They
should provide the opportunity to set minimum expectations and
to communicate best practice to the professional community.
4. Organisations which fail to meet minimum standards
often lack the necessary resources for self-improvement. In such
circumstances, inspections should serve as a tool for directed
improvement with clear expectations of what needs to change and
how quickly.
The Impact of the Inspection Process on School
Improvement
5. Ofsted inspections, when focused on the improving
outcomes for children and young people, provide a valuable tool
for Headteachers, school Governors and local authorities in assessing
progress in individual schools. Where an inspection provides
a school with clear recommendations for improvements this can
help to focus the efforts of school staff. This is particularly,
useful for schools which are "inadequate" or "satisfactory"
and may lack the strong critical evaluation skills needed to drive
self-improvement. For stronger schools the inspection process
acts as a useful validation exercise. The difference in value
to schools of inspection supports the logic that "outstanding"
schools should face less frequent inspection than schools with
poorer judgements - an argument which also holds true for other
settings and organisations
6. Ofsted inspection is not the only mechanism
to provide this support. Assisting schools in self-improvement
is a role which Local Authorities fulfil outside of the Ofsted
cycle of inspections. Strengthening the powers of early intervention
in under-performing schools for Local Authorities would help to
increase the numbers of schools which are seen to be Good or Outstanding.
This would reduce the number of schools which Ofsted would need
to inspect on a more regular basis and thereby reduce the overall
workload of the organisation.
7. The Government is right to propose that local
authorities should act as champions of local parents and children
and that to give meaning to this role the relationship between
local authorities and Ofsted should be firmed up in a number of
important respects. First, when this local authority has a concern
about a school it undertakes a joint review; at present there
is no statutory power underpinning this approach. Yet it is effective
as it nips problems in the bud before they escalate. This is
a cost-effective, non-bureaucratic and relatively light touch
way of promoting school improvement without the need for Ofsted
intervention. On the rare occasions when this approach is insufficient
local authorities can use formal warnings as a proportionate response.
Again such an escalation generally works without the need for
Ofsted intervention. Second, given the finite resources available
to Ofsted and the importance of targeting them where needed, based
on good local intelligence, it would be useful if there was an
expectation that Ofsted would act on local authorities' requests
to inspect a particular setting. Such requests would be used
only sparingly, but should ensure alignment between the regulatory
functions of local authorities and Ofsted. In this context it
would also be particularly helpful if Ofsted were more responsive
to requests to de-register Inadequate child care providers.
8. Inspection of any kind, whether focused on
schools or other settings, inevitably leads to disruption and
can have a negative impact on morale.
The Performance of Ofsted in Carrying Out its
Work
9. The work of individual Ofsted teams is more
often than not exemplary (see below). However, recent changes
to the inspection framework and management of the annual assessment
process have not been positive.
10. Ofsted's inspections of schools have become
too driven by raw data. Inspectors arrive at a school with pre-conceptions
which are hard to shift. Even with a strong self evaluation some
schools can feel that they are pre-judged and forced to fight
that judgment. It would be preferably if inspectors arrived at
schools with a hypothesis test rather than an opinion to select
evidence to substantiate.
11. The mechanism which was put in place in 2009
to conduct the annual assessment, alongside the now defunct Comprehensive
Area Assessment, is ineffective. It takes an overly formulaic
approach to the judgement of the effectiveness of widely differing
local authorities. The 2009 assessment process involved large
amounts of ultimately fruitless work in preparing submissions
for "green flags". Ofsted's request for a self-assessment
document without clear guidance on how it would be used in reaching
the final judgement added additional unnecessary work. The draft
of the judgement letter was poorly constructed and the final letter
to local authorities lacked the kind of recommendations which
make a meaningful contribution to local improvement. Ofsted's
published evaluation of the 2009 assessment process highlighted
some of the unease amongst local authorities, but the changes
made to process were limited. The guidance document for 2010
was published late and included a poorly defined request for information
on commissioned places. The Performance Profile used in both
years has caused concern as it has relied on out-of-date information.
The Consistency and Quality of Inspection Teams
in the Ofsted Inspection Process
12. For the most part inspection teams are fair,
consistent and professional. The majority of inspectors are specialists
in their area and committed to supporting organisational development
rather than just carrying out an assessment. However, variation
naturally occurs between inspectors and inspection teams. This
can lead to settings or organisations receiving different judgments
despite ostensibly similar performance.
13. This inconsistency often surrounds interpretation
of required documentation. Some inspectors seem more willing
than others to take a sensible balance between evidence of improving
outcomes and strict compliance with bureaucratic standards. There
have been recent examples of inspectors revising judgments or
raising areas for improvement which they have based on perceived
recording errors as opposed to outcome measures.
The Weight Given to Different Factors Within the
Inspection Process
14. The annual assessment of children's services
relies heavily on the application of a number of tests. These
tests are primarily based on the results of Ofsted inspections
rather than outcomes for children. In placing process ahead of
outcomes Ofsted have moved away from the national policy trend.
Weighting in such assessments should be clearly in favour of
quantitative outcome measures.
15. Wandsworth Council strongly supports the
objective use of outcome data to assess the effectiveness organisations.
This is particularly true of inspections conducted through desk
based exercise which do not allow inspectors the opportunity to
learn first-hand about a local authority. Ofsted argue that self-assessment
provides local authorities with the opportunity to provide context.
However, without clear parameters or guidance on how self-assessment
will be taken into account it is difficult to see how it can be
effectively used in objective assessment.
16. School inspections rightly focus on pupil
attainment as the key measure of school success. However, this
approach needs to be more subtly applied. The attitude towards
some pupils in schools, particularly those with special education
needs, can be detrimentally affected by this focus on raw attainment
data as many of these pupils are unlikely to reach the expected
level of their peers in key stage assessments. A more nuanced
approach to the weighting of attainment would also support a more
accurate targeting of inspections. For schools which are judged
to be "good" or "outstanding" the interim
assessment needs to give sufficient weight to value-added scores
and local views to ensure that schools previously determined to
be high-performing have not begun to coast.
Whether Inspection of all Organisations, Settings
and Services to Support Children's Learning And Welfare is Best
Conducted by a Single Inspectorate
17. The effectiveness of the inspections are
not judged by the structure or make up of the organisation conducting
them, but by the quality of the evaluative framework and the skills
and knowledge of the inspectors involved. The primary question
should therefore be whether there are enough inspectors available
for the work which needs to be completed.
18. The secondary question of how these inspectors are organised
should recognise that improving outcomes and safeguarding children
and young people includes the work of a wide range of organisations.
Services for children and young people at a local level are increasingly
working in effective, integrated ways. A national inspectorate
that reflects this is more likely to understand the work of children's
services at a local level. However, this assumes that there are
sufficient inspectors, who have the necessary range of skills
and knowledge, working for the organisation operating in a similarly
integrated way.
The Role of Ofsted in Providing an Accountability
Mechanism for Schools Operating with Greater Autonomy
19. Extension of the time between inspections
for Good and Outstanding schools will make it harder for Ofsted
to maintain effective accountability arrangements for schools
with greater autonomy.
20. As the number of free schools and academies
increases the proportion of pupils educated outside of establishments
over which the local authority has a standards role will increase.
Local authorities provide an effective challenge and support
role for settings on a more regular basis than Ofsted. Substantial
change, both positive and negative, is possible in a school over
five years. It is possible that such change could go unnoticed
by Ofsted in schools operating outside the ambit of local authorities.
21. For the majority of Good and Outstanding
providers this will not be the case and they will, through high
quality self-improvement, sustain their performance.
October 2010
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