Memorandum submitted by NASUWT
The NASUWT's submission sets out the Union's views
on the key issues identified by the Committee in the terms of
reference for the Inquiry and is based upon the work of its representative
committees and other structures made up of practicing teachers
and lecturers working in the sectors within Ofsted's statutory
remit.
The NASUWT is the largest union representing teachers
and headteachers in the UK, with over 280,000 serving teacher
and school leader members.
EXECUTIVE SUMMARY
— The
education system should be subject to an appropriate, constructive
and proportionate system of public accountability, a key element
of which must include an effectively resourced, professionally
staffed inspectorate located firmly within the public sector.
— Aspects
of the inspection of schools in England have led to significant
problems in terms of the impact of inspection on the ability of
schools to raise standards and support and enhance the wider wellbeing
of children and young people.
— In
practice, the inspection framework has had a significant and adverse
impact on the workload of teachers and headteachers and on levels
of organisational bureaucracy.
— The
inspection framework is focused to an excessive extent on the
identification of perceived "failure" to the detriment
of the critical role to be played by inspection in supporting
schools in their work to raise standards and contribute to the
wellbeing of all children and young people.
— The
operation of the inspection has framework has acted to constrain
the breadth and balance of the learning experiences that schools
can offer their pupils.
— The
focus on outcomes for pupils as part of the inspection process
is driven to a disproportionate extent by pupil performance data
and underplays significantly the wider contribution the schools
make to pupils' development, progress and wellbeing.
— However,
diminishing or undermining the role of inspectorates and of the
work they undertake would represent a seriously misguided response
to these concerns.
— In
principle, there are good reasons for the existence of a single
inspectorate for children's services and learning but its ability
to operate effectively is dependant on significant reform to the
basis upon which inspection is conducted.
— There
are profound contradictions in the Government's proposals to give
schools greater apparent autonomy and its views on the principles
upon which systems of school accountability including inspection
should be established.
BACKGROUND AND
CONTEXT
1. The NASUWT welcomes the opportunity to submit
evidence to the House of Commons Education Select Committee Inquiry
into School Accountability. The range of issues highlighted in
the terms of reference of the Inquiry are wide ranging and merit
extended further discussion and consideration. However, within
the confines of the 3,000 word limit for submissions, the Union
can only provide a brief overview of its views on the key areas
of concern highlighted by the Committee.
THE PURPOSES
OF INSPECTION
2. The NASUWT's assessment of the impact and
effectiveness of the work of Ofsted is based on the belief that
the inspection of schools must:
— place
a minimal burden on schools;
— not
lead to excessive workload for teachers and headteachers or increase
bureaucratic burdens in schools;
— not
require schools to undertake any special preparation for inspection;
— make
use of the wealth of data that is already available and not require
schools to prepare or collate data for the sole purpose of inspection;
— shift
from being a punitive inspection regime to one that is supportive
and focuses on helping schools to improve;
— focus
on the school's management arrangements and processes, and their
outcomes for pupils and staff in terms of efficiency, equity and
effectiveness;
— not
duplicate other systems of monitoring, performance management
and support;
— operate
in unity with other systems of audit, performance management,
advice and support, including that which is carried out by HMIs
and local authorities; and
— provide
judgements that are fair and in which the profession and the public
can have confidence.
3. The NASUWT is clear that in many important
respects, these principles have not been reflected in the series
of frameworks within which inspection in England has been undertaken
to date. The most important implications of these deficiencies
in the context of the remit for the Committee's Inquiry are set
out in more detail below.
4. However, it is important to be clear at the
outset that while legitimate concerns can be identified about
the inspection process in terms of its impact upon staff and learners,
diminishing or undermining the role of inspectorates and the work
they undertake would represent a seriously misguided response.
The NASUWT maintains that as a publicly-funded universal service,
the education system should be subject to an appropriate, constructive
and proportionate system of public accountability, a key element
of which must include an effectively resourced, professionally
staffed inspectorate located firmly within the public sector.
5. In the context of the significant cuts to
education-related public expenditure planned by the Government,
the Union is concerned that well-founded concerns about the inspection
system could be used as a pretext for significant reductions in
the resources available for the inspection of schools. The effect
of this would be to limit the potential of inspection to act as
a means of securing sustained system-wide improvement and would
lead inevitably to pressures to privatise key aspects of the inspection
process in an attempt to drive down costs, thereby undermining
its quality still further.
6. Instead, the NASUWT calls for an approach
to reform of inspection that seeks to establish a system based
on the key principles set out above, to reshape the role of Ofsted
to allow its work to reflect these principles and to ensure that
it has the resources, staff and support from Government it requires
to contribute to supporting and sustaining improvement.
7. Concerns about
future approaches to inspection have been heightened by the stated
intention of the Government to scale back Ofsted's operations
and to limit its principal focus to schools that are "faltering
or coasting"[177].
This view reflects a fundamental misunderstanding of the purpose
of inspection, given its conceptualisation of inspection as a
punitive process, to be deployed only in circumstances where schools
are perceived as "failing". While it is clear that schools
facing challenging or difficult circumstances will always need
additional support, an inspection system established on the basis
of the principles set out by the NASUWT should be seen a process
from all schools can and should benefit.
THE IMPACT
OF THE
INSPECTION PROCESS
ON SCHOOL
IMPROVEMENT
8. In many important respects, the inspection
frameworks within which Ofsted has operated have led to significant
problems in terms of the impact of inspection on the ability of
schools to raise standards and support and enhance the wider wellbeing
of children and young people.
9. A particular concern in this context relates
to impact of inspection on teachers' and headteachers' workload
and on levels of organisational bureaucracy. The findings of the
Union's audit of the workload of teachers and headteachers in
England and Wales, published in March 2008, provide clear evidence
of this consequence of the current inspection framework. The audit
surveyed the views of teachers and headteachers and received over
16,500 responses and found that, in relation to views about the
factors responsible for excessive workload, the demands associated
with inspection were ranked third, ahead of factors such as meetings,
coursework annotation and target setting. While much of this additional
workload and bureaucracy has been related directly to the process
of generating evidence to support schools' self-evaluation, the
NASUWT believes that rather than reducing bureaucracy, the decision
of the Government to abolish the self-evaluation form (SEF) risks
increasing workload further by removing the set template within
which the outcomes of self evaluation can be recorded.
10. There is a clear link between the high-stakes
context within which inspection takes place and the workload and
bureaucracy-related problems inspection generates. The grading
of schools in the inspection system leads to their categorisation
as failing or succeeding institutions with severe consequences,
such as special measures and potential closures, for those identified
as ineffective. Often, schools do not receive the appropriate,
timely and non-judgemental support that they need to take forward
school improvement strategies. This emphasis on the identification
of failure and the high-stakes consequences incurred discourage
collaborative forms of working and the formation of effective
partnerships between schools and teachers.
11. The operation of the Ofsted inspection framework
has also had a significant impact on pupils' learning experiences.
There is considerable evidence to confirm that the current inspection
arrangements are focused almost exclusively on the nature and
operation of school processes. Many schools have reported that
they lack the confidence and are unwilling to develop alternative
approaches to teaching and learning for fear of receiving a negative
inspection judgement or because there is no discernable recognition
from Ofsted for doing so. This has significant implications for
schools seeking to broaden the range and nature of pupils' learning
experiences.
THE PERFORMANCE
OF OFSTED
IN CARRYING
OUT ITS
WORK AND
THE CONSISTENCY
AND QUALITY
OF INSPECTION
TEAMS IN
THE OFSTED
INSPECTION PROCESS
12. In considering the performance of Ofsted
in carrying out its functions. It is important to draw a clear
distinction between concerns that have arisen in relation to the
framework for inspection within which Ofsted is required to operate
and the capability and conduct of inspectors. Although inspectors
may work in a highly professional manner, the positive impact
of their activities for individual settings and the system as
a whole can be constrained by shortcomings in the inspection framework.
13. The NASUWT remains concerned that in too
many instances, it is clear that inspectors' knowledge, experience
and understanding of key elements of the areas they are seeking
to inspect are inadequate or insufficiently up to date. These
issues are often associated particularly with the use of externally
contracted inspectors. Despite recent increases in the use of
directly employed Her Majesty's Inspectors (HMIs) in the inspection
process, the use of contracted inspectors is still widespread.
Therefore, if inspection findings are to have the highest positive
level of credibility, the current system of contracting inspectors
through private companies must be reformed. The concerns set out
above in respect of the risk of further privatisation of Ofsted's
inspection functions are especially significant in terms of safeguarding
future inspection quality.
14. Similar issues can be identified in respect
of Ofsted's monitoring of the quality of inspection which is inadequate.
Given the significant emphasis in the current inspection framework
on the judgements of individual inspectors, more effective monitoring
of inspection quality is critical to securing improvement within
the system. It is essential that Ofsted is given the means to
ensure that every inspector and inspection should be monitored
from start to finish. Further reductions in the resources available
to Ofsted would undermine still further its ability to evaluate
its work effectively.
15. In relation to the management of complaints
by Ofsted, the current procedure is heavily weighted towards the
judgement of the inspector and it is not acceptable that there
is no effective appeals process to challenge an inspection judgement
that relates to standards. The current system makes it extremely
difficult for individual members of staff to pursue complaints
about an inspection and the timescale for making complaints is
too rigid and excludes cases where it has taken time for the full
evidence to become available.
16. For all inspectors, effective training and
development remain key concerns. It is for this reason that the
NASUWT remains concerned that the nature, scope and quality of
Ofsted's training programmes are not open to independent scrutiny.
Without any meaningful assessment of the fitness for purpose of
Ofsted's provision of training and development for inspectors,
confidence among members of the school workforce, parents and
the public more generally in the ability of inspectors to undertake
their wide-ranging and complex responsibilities will be compromised
to an unacceptable extent.
THE WEIGHT
GIVEN TO
DIFFERENT FACTORS
IN THE
INSPECTION PROCESS
17. The Union is concerned that the focus on
outcomes for pupils as part of the inspection process is driven
to a disproportionate extent by pupil performance data. Whilst
it is quite right that inspection focuses on standards and pupils'
progress, an overemphasis on data risks distorting inspection
judgements. The nature of this overemphasis on data in the inspection
process can result in inspection overlooking a school's achievements
and effectiveness in, for example, engaging disaffected young
people in education. The primacy of pupil performance data in
the current framework is highlighted by the fact that pupil achievement
is a "limiting judgement"; regardless of the success
of schools in all other areas of their work, where pupil achievement
is judged to be less than outstanding or good, schools cannot
be rated as higher than satisfactory overall.
18. Notwithstanding the core role of schools
to help pupils make the best possible rates of educational progress
and achievement, this feature of the current framework denies
that schools have a key part to play, in collaboration with well
resourced and supported wider children's services, in contributing
to the development of all aspects of lives of children and young
people.
19. For these reasons, the NASUWT took the view
that the School Report Card proposed by the previous Government
had the potential to recast positively the ways in which the school
accountability system, including the inspection of schools, recognises
and evaluates the wide range of work undertaken by staff in schools.
20. The School Report Card was being developed
in way that reflected a broader vision of the work of schools
and work was well advanced in identifying indicators of school
performance and activity that would more accurately describe the
contribution made by schools to the wider progress and achievement
of children and young people. A key element of this work was to
ascribe relative weightings to different indicators of performance
based on judgments of the relative importance of different aspects
of the work that staff in schools undertake with pupils and the
outcomes for children and young people for which members of the
school workforce, including teachers and headteachers, can reasonably
be expected to take some degree of responsibility. It is therefore
regrettable that the current Government has decided to discontinue
work to develop the revised approach to school accountability
that the School Report Card represented.
21. The NASUWT is clear that the intention of
the Secretary of State to focus the inspection process to an even
greater extent on a narrow range of performance criteria than
is the case currently[178],
threatens to increase further the inconsistencies between the
ways in which staff in schools support the wider development of
children and young people and the capacity of the inspection system
to capture and reflect the full extent of this work.
THE INSPECTION
OF ALL
ORGANISATIONS, SETTINGS
AND SERVICES
TO SUPPORT
CHILDREN'S
LEARNING AND
WELFARE BY
A SINGLE
INSPECTORATE
22. The NASUWT supported the principle of reforming
Ofsted as a single inspectorate for children's services and learning
and recognised that the challenges involved in managing the overlapping
responsibilities of previous inspectorates in a broader policy
context with significantly greater emphasis on joint working between
services for children provided a reasonable basis for the establishment
of a single inspectorate. Nevertheless, this support was conditional
upon significant and sustained reform of the frameworks within
which Ofsted operates. In the absence of this reform, the expansion
of Ofsted's remit has been undertaken on the basis of an unreconstructed
model of inspection and has, to some extent, been problematic
in terms of the ability of the organisation to manage its wide
ranging remit.
23. This has led to concerns that the scope of
Ofsted's responsibilities is now so broad that its ability to
play an informed, balanced and constructive role in sustaining
improvements in the quality of the services it inspects, including
state-funded education, has been compromised. In relation to schools,
particular concerns can be identified in respect of the declining
ability of Ofsted to gather meaningful and robust evidence of
practice additional to that gathered from routine school inspection
to produce effective sectoral or systemic reports which have been
valued by educational professionals in terms of the contribution
they made previously to supporting the development of policy and
practice.
24. However, reform of the basis upon which inspection
is undertaken across the children's services sector, combined
with adequate resourcing of the inspection system by central Government,
could create the circumstances within which inspection of distinct
sectors could be undertaken by a single inspectorate in a way
that allows for effective account to be taken of the connections
between these services and the ways in which they should collaborate
to meet the children and young people's needs. The coherence and
economies of scale that a single inspectorate can provide in comparison
with a wider range of smaller distinct inspectorates is a clear
potential advantage of an inspection system constituted on this
basis.
The Role of Ofsted in Providing an Accountability
Mechanism for Schools Operating with Greater Autonomy
25. The NASUWT recognises that this aspect of
the Inquiry reflects the determination of the Government to increase
significantly the number of state-funded schools operating outside
the maintained sector, either as academies or so-called "free
schools", as well as the commitment set out in the Coalition
Agreement to give all schools "greater freedom" over
the curriculum and other key areas of schools activity related
to the progress and achievement of pupils.
26. Although it is not possible at this stage
to state with any complete degree of confidence the exact nature
of the extent of autonomy in these respects the Government intends
to grant to schools, this aspect of the Inquiry calls into question
key principles upon which important aspects of the Government's
policies in relation to schools and the ways in which they should
be held to account appear to be based.
27. The NASUWT maintains that a hallmark of an
effective and equitable education system is that all children
and young people, regardless of where they live, are able to access
a local school that secures their common entitlement to a high
quality, relevant and engaging education. In light of their identity
in this context as public institutions providing universal services,
it is right that schools are held to effective public account
for their performance through a common school accountability framework
which works to secure consistency of quality and educational experience
throughout the system as a whole. Data from recent research commissioned
by the NASUWT and UNISON confirms that this view of the state
education system and the need for it to be held accountable to
secure consistency of standards is shared by the majority of the
public.[179]
28. This coherent view of the relationship between
the state education system and the role of mechanisms for holding
schools to account, including school inspection, contrasts markedly
with the tensions inherent in the approach adopted by the Government.
The Government's view involves an assertion that schools should
be a given greater degree of organisational freedom over key aspects
of their practice but also maintains correctly that there should
be a common system of school accountability. However, given that
the Government remains committed to deepening the high stakes
nature of school accountability and school inspection still further
through a greater focus on the identification of perceived "failure",
it is not clear how, in practice, schools will be able to operate
in a more autonomous manner given that they will need to ensure
that their policy and practice is consistent with that demanded
by the school accountability regime the Government intends to
establish.
29. This contradiction at the heart of Government's
education policy suggests that it is underpinned by a lack of
clear thinking about the implications of its approach to school
structures and their relationship with the school accountability
system. In relation to the future work of Ofsted, it is important
that the Committee examines critically the rationale underpinning
the Government's policies in this critical area and considers
the extent to which the Government's policies on school accountability
and school autonomy, particularly in relation to the expansion
in the academies programme and the creation of free schools, form
a consistent and credible basis for the future development of
policy in these important areas.
October 2010
177 Department for Education (17 June 2010), Michael
Gove to the National College Annual Conference, Birmingham,
(http://www.education.gov.uk/news/speeches/nationalcollegeannualconference)
retrieved on 22/9/10. Back
178
Ibid. Back
179
Ipsos MORI (2010), Who Should Run Our Schools? A survey of
Public Opinion, NASUWT/UNISON, (www.nasuwt.org.uk/research),
retrieved on 23/09/10. Back
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