Memorandum submitted by the Association
of Colleges (AoC)
- The Association of Colleges (AoC) represents
and promotes the interests of Further Education and Sixth Form
Colleges and their students. Colleges provide a rich mix of academic
and vocational education. As independent, autonomous institutions
established under the Further Education Act 1992, they have the
freedom to innovate and respond flexibly to the needs of individuals,
business and communities.
- The following key facts illustrate Colleges'
contribution to education and training in England:
- Every year Colleges educate and train three million
people.
- 831,000 of these students are aged 16-18 which
compares to 423,000 in schools.
- 74,000 14-15 year olds are enrolled at a College.
- One-third of A-level students study at a College.
- 44% of those achieving a level 3 qualification
by age 19 do so at a College.
- 69% of those receiving an Education Maintenance
Allowance (EMA) study in a College.
- Colleges are centres of excellence and quality.
The average A-level or equivalent point score for Sixth Form Colleges
is 800.1, compared with 761.6 for school sixth forms. 96% of Colleges
inspected in 2008-09 were judged satisfactory or better by Ofsted
for the quality of their provision.
1. METHODOLOGY
To inform the AoC's response a membership survey
was conducted. We have incorporated feedback from the survey into
the text.
2. THE FUTURE
OF QUALITY
ASSURANCE IN
FE AND SIXTH
FORM COLLEGES
- ENSURING STANDARDS,
ACHIEVING VALUE
FOR MONEY
AoC would argue that the time is right to overhaul
the inspection regime and system. Over the last eight years, the
quality of education and training and achievement rates in Colleges
has significantly improved. Colleges have matured and the sector
now boasts less than 4% inadequacy. This is not reflected in
other parts of the FE sector. Self-assessment is embedded and
is at the heart of Colleges' annual review of their performance.
A key component of the self-assessment process is the observation
of teaching and learning. In fact, Ofsted rely on Colleges' own
improvement plan, and teaching and learning improvement strategies,
to form their judgements.
Over the past four years Ofsted has reduced its inspection
intervention in proportion to the rise in achievement and standards.
In fact it is now proposed that Colleges graded "Outstanding"
are no longer inspected and that, based on a risk approach, Colleges
graded "Satisfactory" and above will be subjected to
a "light-touch" inspection regime. So the move to the
sector taking ownership of the quality improvement agenda has
already begun. Unfortunately the burden and bureaucracy of inspection
has not decreased, and AoC would suggest a better use of public
funds would be in supporting a sector-led peer review model.
AoC would therefore advocate a system which draws
on the experience of Higher Education. A rigorous programme of
peer review, with trained reviewers working within an agreed framework
validated through a quality improvement/inspection agency, would
not only reduce the cost per intervention but would also build
capability within the sector. Colleges would work with Ofsted
to design and agree a toolkit which would not only include the
framework and criteria for peer review but also clearly set out
a set of indicators against which performance would be measured.
Colleges would like to work with Ofsted to design this toolkit
around which peer validation would be consistent and rigorous.
Ofsted could then sample the peer validations to ensure that the
highest standards are maintained. The advantages of this are:
- Reduction in the cost of inspection.
- Development of the sector to ensure national
standards are met.
- Peers are recruited and trained to acceptable
standards by Ofsted.
- The enhancement of performance is encouraged
through a community of professionals who take their experiences
of peer validation back to their own institutions.
- It allows Ofsted to target its interventions
where performance is declining or is failing.
- The model can be applied more directly to the
context of Colleges rather than the "one size fits all"
approach in current practice.
- This system is similar to the peer review model
used in Integrated Quality and Enhancement Review (IQER) used
by the Quality Assurance Agency to assure standards of HE delivery
in FE Colleges.
- Ofsted could provide a service to Colleges who
would pay for this, similar to external audit.
We would want to see the continuation of Ofsted's
role in thematic enquiries. However these should be better informed
and driven by the sector through the National Improvement Partnership
Board (NIPB).[19]
3. AREAS OF
SPECIFIC INTEREST
TO THE
SELECT COMMITTEE
What the purposes of inspection should be
1. Ofsted's role is to ensure standards and to
provide assurance to students, employers and tax-payers, that
the institutions in which they are investing their future or resources
can deliver to an appropriate standard. However commissioners
also measure performance and have developed intervention strategies.
The Skills Funding Agency measure FE College performance annually
through:
- Framework for Excellence.[20]
- ILR[21]
audits.
- An annual assessment against minimum levels of
performance (MLPs).
- Monitoring Notices to Improve which result from
failing to meet financial or qualification MLPs.
If Ofsted's role is to regulate standards then it
is a duplication of systems already in place and it would be advisable
in value for money terms to resolve this.
2. AoC was pleased to see an increased focus
on teaching and learning delivery in the
Cycle 3 inspections (from September 2009).
3. IN SUMMARY
- Ofsted's purpose is unclear - if it assures standards
then other performance management can be removed or vice versa.
- The qualitative judgements Ofsted make are of
importance to the sector and to inform choice.
The impact of the inspection process on College
improvement
4. From our survey results Colleges feel that
inspection does motivate improvement but they vary in their estimation
of how much. Ofsted inspection continues to inform self-improvement
strategies. Management teams in Colleges report that inspection
is a major tool in their drive towards improvement. However many
Colleges say they are already able to influence this direction
of travel without Ofsted.
5. Colleges value Self-Assessment, particularly
as it is not a prescribed procedure and can serve their individual
missions. It is currently a requirement of funding bodies and
Ofsted expect a College's own judgement to match their own. A
positive step to reduce the amount of time spent on self-assessment
would be to agree with Ofsted a slimmer version on which to base
peer validation.
6. The Common Inspection Framework (Common Evaluation
Framework) and the handbook for inspectors has been a useful engine
for motivating improvements. Thematic reviews have given useful
insights to focus development work. The "How Colleges Improve"
(September 2008)[22]
and the inquiry into progress on implementation of Workforce Reforms
(Initial Teacher Training - an overview of Ofsted Inspections
2004-08)[23]
were of particular interest.
7. Ofsted reports are brief and serve the needs
of a lay audience but do not give the forensic detail that a College
might want to aid its improvement agenda.
8. Ofsted has a light touch and now a no touch
methodology for Colleges considered Good or Outstanding. In these
cases it will have no role in improvement - that is for 63% of
Colleges. Only 4% (seven Colleges) are graded Inadequate.
9. IN SUMMARY
- Ofsted's role in the future should be to support
a peer validation process based on an agreed self assessment tool.
- The element of professional qualitative judgements
needs to be preserved.
- In depth thematic reviews informed by the sector
should be a continued role for Ofsted.
The performance of Ofsted in carrying out its
work
10. The current inspection methodology is far
too bureaucratic and burdensome. It currently involves Colleges
addressing:
- 272 areas which contribute to judgements and
grades for Overall Effectiveness, Capacity to Improve, Outcomes
for Learners, Quality of Provision, Leadership and Management,
Safeguarding and Equality and Diversity.
- 27 areas must be addressed in the Effectiveness
of Teaching Training and Assessment.
- 22 for Safeguarding.
- 24 for Promoting Equality and Diversity.
- 24 areas are scrutinised under the heading of
Value for Money.
This unacceptable level of regulation results in
considerable resource being diverted from the front line. The
burden of inspection is self evident and not commensurate with
its impact on improvement.
11. In the future students and employers may
pay entirely for their provision with no support from the public
purse. In that world there will be a purely customer oriented
relationship which will depend on good quality for its survival.
This would require a re-evaluation of the role of Ofsted in this
market.
12. AoC is disappointed that the Ofsted website
is so difficult to access for Colleges seeking others who have
just been inspected. We would encourage Ofsted to improve radically
its search facilities.
13. Making a complaint about an Ofsted inspection
is a complicated process. A College inspection report can be published
before the complaint is resolved. We encourage Ofsted to revise
their procedures substantially and ensure they include the ability
to complain not only about the conduct of inspection but the evidence
that supports judgements. Reports should be delayed until resolution
of the complaint.
14. IN SUMMARY
- Inspection is burdensome, bureaucratic and diverts
resources from front line delivery.
- The website and complaints procedure need attention.
The consistency and quality of inspection teams
in the Ofsted inspection process.
15. Inspection teams are professional and, with
a 50% contribution from serving practitioners, have improved the
currency of inspection.
16. AoC has concerns about the consistency of
inspections. Many of our members have experienced a number of
inspections during their careers, including from the now defunct
FEFC, ALI as well as Ofsted, and can make valid comparisons. The
current system of contracting with inspection providers[24]
has led to increased feedback from Colleges on the disparity between
differing training and support for inspectors. We have already
raised with Ofsted the problems perceived by our members of a
conflict of interest between inspection contractors who are also
consultants marketing their services to Colleges.
17. There are separate bench marks for General
Further Education and Tertiary Colleges, Sixth Form Colleges and
Independent Specialist Colleges. Ofsted measure Qualification
Success Rates against these. However it is increasingly difficult
to categorise by types of College. Some Sixth Form Colleges may
have more in common in terms of their curriculum and student cohort
with a General Further Education College. Institutional benchmarks
serve little purpose.
18. The weight given to different types of provision
in inspection has no relationship to the volumes of delivery in
an institution. Ofsted focuses on 16-18 delivery and does not
recognise the diversity of College provision.
19. IN SUMMARY
- Full-time inspectors need to update their experience
of College practice.
- The training of inspectors varies.
- Benchmarks by institutional type should be removed.
- There is insufficient focus or expertise on post-19
Employer Responsive provision.
The weight given to different factors in the inspection
process.
20. Qualification Success Rates (QSR)[25]
have an overwhelming influence on inspection results and we believe
they are a very important indicator of responsiveness to learners.
But they have a direct influence over almost all of the 272 factors
that culminate in a grade. The hypothesis that an inspection team
arrive with will be based almost entirely on success rates.
21. This encourages institutions to recruit the
students whose success is predictable. Challenging qualifications
are discarded in favour of more achievable alternatives.
22. AoC would encourage a more reasonable approach
to securing standards. We think there is a role for the FE sector
in deciding with Ofsted what the threshold standards should be
each year. Policing the complexity of individual qualifications
is unnecessarily costly and not in the students' interest.
23. The issue of the retention element of success
rates needs to be re-examined. School achievements are based on
the success in gaining the qualification, not on how many students
registered at the beginning of the programme. Colleges acknowledge
the importance of focusing on retention and it has led to further
innovation in teaching, learning, target setting, attendance monitoring
and tutorial. However a student leaving for employment, illness
or change of address has a negative and unfair impact on College
success rates, therefore this requires re-evaluating.
24. We are also disappointed that measuring student
success after the age of 16 in schools and Colleges is still not
comparable. It leads to uninformed decisions being made by those
unaware of the complexity of measuring success.
25. College inspections since September 2009
have focused on Safeguarding and Equality and Diversity. Grades
for these areas have a limiting effect on the Overall Effectiveness
grade. AoC believes that Safeguarding has assumed an importance
in inspection way beyond the problem that needed a solution. In
many Colleges adults make up the huge majority of students. Procedures
that might apply to younger students and school settings have
little relevance to most College students. Colleges do not have
the resources to invest in electronic security procedures, controlled
entrances and secure closed campuses. Colleges have been involved
in costly CRB checking and training of staff when their students
have already felt safe and clear about how they need to protect
themselves. We would encourage Government to remove this from
the Ofsted remit.
26. The judgements on Equality and Diversity
have ensured a focus on the success of students on an individual
basis. This has also led to innovative teaching delivery, a focus
on tutorial and assessment for learning.
27. However we do not think that either Safeguarding
or Equality and Diversity should be a limiting grade at inspection.
Equality and Diversity should be integrated into overall College
practice.
28. The inspection process does not give enough
weight to value added measures.[26]
Colleges lead the field in engaging young people and adults not
engaged in education or training (NEET). They have developed programmes
for ex-offenders, those with mental health problems and people
with learning disabilities and difficulties (LLDD). A much greater
emphasis on the distance travelled by all students would be welcome.
29. Ofsted has given more weight to student satisfaction
in the current cycle of inspections. Our members feel that national
assessments of student satisfaction under Framework for Excellence
should be used by inspectors.
30. Inspection does not take into account the
resources available for Colleges to deliver its programmes. In
a recent report by Ofsted on Special Education Needs it criticised
Colleges for the weekly Guided Learning Hours delivered to students
with learning difficulties and/or disabilities, and only acknowledged
in the small print that this was all Colleges were resourced to
do.
31. IN SUMMARY
- The overwhelming dependence on QSR has led to
perverse behaviour. Outcomes for learners should address a wider
range including employment.
- Safeguarding and Equality and Diversity should
be removed as a limiting grade in inspection.
- Greater emphasis should be placed on value added
and student satisfaction.
Whether inspection of all organisations, settings
and services is best conducted by a single inspectorate.
32. The inspection process should offer value
for money and reduced bureaucracy. Inspectors need to understand
the context in which they are making professional judgements.
A single inspectorate, if structured and managed appropriately,
should be able to achieve the standards above.
33. IN SUMMARY
We do not advocate a return to different inspection
services. The model we have explained at the beginning of this
evidence would be a cost effective and robust system, and would
provide the expertise for different contexts.
The role of Ofsted in providing an accountability
mechanism for Colleges operating with greater autonomy.
34. AoC believes the time is right to review
the role of performance management in the College sector. We have
explained our ideas in Section One for a peer validation model
supported by Ofsted.
35. We are moving to an era where Colleges will
have much greater autonomy to manage their budgets in delivering
their agreed business plans.
36. The oversupply of performance indicators
and kite marks, each with their costs in people and time, needs
reform. Framework for Excellence, Minimum Levels of Performance,
Matrix, Investors in People, the Training Quality Standard, the
quality assurance requirements of Awarding Bodies and now Sector
Skills Councils, National Skills Academies and of course Ofsted
all have their different methods and requirements. Possession
of one does not influence another.
37. AoC is part of the National Improvement Partnership
Board which is progressing the provision of publicly available
information to aid student choice (mentioned above). Framework
for Excellence will be part of this information. This project
is supported by the current Government and the sector itself,
and is a good example of a voluntary partnership to give stakeholders
the information they need without compulsion. The motivation is
the student/customer who has a choice to go elsewhere. Thus kite
marks and performance indicators could be part of this landscape
but paid for by the College where it deems it will improve its
standards, and give its students and employers more information.
38. IN SUMMARY
- Ofsted should be part of a co-regulating system.
AoC's model provides a blueprint for the future, borrows from
international good practice, is used in higher education and would
reduce costs whilst further increasing the quality of College
provision.
October 2010
19 NIPB brings together all the parties interested
in improvement in the FE Sector. It is hosted by the Learning
and Skills Improvement Service. Back
20
Framework for Excellence is a set of performance indicators for
Qualification Success Rates, learner and employer views, and learner
destinations. All Colleges are part of this framework but schools
are not. Back
21
The student records database for funding and performance measurement
in the FE sector. Back
22
http://www.ofsted.gov.uk/Ofsted-home/Publications-and-research/Browse-all-by/Documents-by-type/Thematic-reports/How-colleges-improve Back
23
http://www.ofsted.gov.uk/Ofsted-home/News/News-Archive/2009/February/Initial-teacher-training-for-further-education-an-overview-of-2004-2008-inspections Back
24
Ofsted contract with SERCO, Tribal and CfBT to deliver inspection
services. Back
25
QSR are measured by counting the number of students who start
a qualification programme and those who achieve. For example if
10 people start in year one and only five take the qualification
at the end of two years the QSR will be 50%. In schools using
the same numbers their achievement would be 100%. School attainment
is only measured on who gains the qualification not on who has
dropped out. Back
26
Value added is a calculation based on where a student starts,
the qualifications they enter a programme with, and where they
finish. Positive value added scores are where a student achieves
beyond what could be predicted. It is a good measure of College
effectiveness. Back
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