Memorandum submitted by the Association
of School and College Leaders
INTRODUCTION
1. The Association of School and College Leaders
(ASCL) represents 15,000 members of leadership teams of maintained
and independent school and colleges throughout the UK. This places
the association in a particularly good position to provide evidence
for this inquiry.
SUMMARY
2. ASCL believes that inspection should be part
of an overall framework of intelligent accountability for schools
and colleges, which should be not excessive but fit for purpose.
3. Inspection should move to being a process
of validating schools' and colleges' self evaluation subject to
external moderation.
4. Inspection alone cannot bring about improvement.
Only when there are sensible links with subsequent action and
external support will inspection contribute to improvement.
5. ASCL believes that self-evaluation, subject
to external verification and the determination of improvement
strategies, places the improvement of the institution in the hands
of those people best placed to drive that improvement.
6. Therefore, though ASCL welcomes an end to
the overly detailed and bureaucratic SEF in its current form,
inspection must follow robust self-evaluation. A written record
of the outcomes of self- evaluation has a value and a short working
document could helpfully serve this purpose.
7. Schools and colleges should not be judged
on a single data set.
8. ASCL has expressed concerns about the 2009
inspection framework but has welcomed the way in which inspectors
are now engaging more meaningfully with school and college leadership
teams.
9. Inspection should provide support as well
as challenge. It should be an experience shared between the leadership
team, other staff and the inspection team rather than an external
invasion.
10. There must be consistency between successive
inspections. This has not been the case as Ofsted adjusts its
framework, sometimes radically, with each round of inspections.
Such changes invariably include "raising the bar". Thus
it is impossible to make comparisons over time. It also creates
a false impression of the quality of schools and colleges across
the country declining, when in fact the reverse is the case.
11. ASCL argues that in the interests of consistency
all inspection teams should be led by full-time HMI.
12. ASCL would like to see a consistency in terms
of criteria and their application across the inspection of all
institutions for post -16 learners.
13. ASCL would support a narrowing of the focus
of inspection to core activities within a school or college, for
example teaching and learning and leadership, which would provide
evidence to judge if a good education is being given and if there
is the capacity to improve further.
14. Compliance issues such as financial probity
and safeguarding should be moved away from Ofsted to a biennial
audit as part of the standard external auditing process of a school
or college.
15. ASCL does not believe that there should be
a single inspectorate for all organisations, settings and services
that support children's learning and welfare.
16. Inspection should be proportionate to the
need for it. ASCL believes that those schools and colleges judged
by Ofsted to be performing at the highest grade should have very
light touch quality assurance.
What the purposes of inspection should be
17. One of the main purposes of inspection should
be to validate a school's or college's self- evaluation; verifying
strengths, highlighting good practice and identifying any areas
for improvement. Inspection should be part of an overall framework
of intelligent accountability for that is not excessive, as has
been the case for some years, but fit for purpose. This will help
bring about improvement - a core purposes of inspection.
18. While England may not yet have intelligent
accountability for schools and colleges, the phrase has at least
found a firm place in the education policy lexicon.[27]
19. The association defined intelligent accountability
in 2003 as "A framework to ensure that schools and colleges
work effectively and efficiently towards both the common good
and the fullest development of their students. It uses a rich
data set that gives full expression to the strengths and weaknesses
of the school in fulfilling the potential of students. It combines
internal school processes with levels of external monitoring appropriate
to the state of the development of each individual school".[28]
20. ASCL stands by this definition which is as
important to apply in 2010 as it was in 2003.We would add that
data should only be used for valid statistical inferences that
can be drawn from it.[29]
21. From the outset ASCL has argued that it is
as important to apply an intelligent accountability framework
to colleges as to schools.
The impact of the inspection process on improvement
22. The proportionality of inspections according
to the performance of the school or college is a sensible use
of Ofsted's resources, although ASCL does not believe that an
increased amount of inspection alone brings about improvement.
Inspection alone cannot bring about improvement. Only when there
are sensible links with subsequent action and external support
will inspection contribute to improvement.
23. ASCL believes that self-evaluation, subject
to external verification, leaves the improvement of the institution
in the hands of those people best placed to drive that improvement.
24. Schools and colleges have made great progress
in developing rigorous and wide-ranging self-evaluation systems.
These include structured lesson observation with feedback, regular
reviews of strategic areas such as pastoral care, assessment and
behaviour and annual surveys of student and parent views.
25. An end to the SEF in its present form, overly
bureaucratic and detailed, is welcome. However, inspection should
follow robust self-evaluation. A written record of the outcomes
of the school's self-evaluation has value and a short working
document could helpfully serve this purpose.
26. Focusing on self-evaluation as the centre
of the quality assurance system would help to move from a low
trust to a higher trust accountability environment.
The performance of Ofsted in carrying out its
work
27. Though ASCL expressed concerns about the
2009 inspection framework and its application, it has welcomed
the way in which inspectors are now engaging more meaningfully
with leadership teams. Inspections should provide support as well
as challenge, and that cannot happen when inspectors are overbearing
or narrowly focused on data.
28. This process should continue so that inspection
is a collaborative process done with, rather than to, schools
and colleges. Such a process could then be a shared professional
experience based on fairness, trust and mutual respect between
the leadership team, other staff and the inspection team; and
less of an external invasion.
29. The increased attention that inspectors have
paid to listening to students' views is also welcome as it aligns
with ASCL's longstanding commitment to student voice.
The consistency and quality of inspection teams
in the Ofsted inspection process
30. "Raising the bar" and additions
to the framework have led to inconsistency in inspections carried
out in different years/parts of year. There needs to be consistency
between successive inspections otherwise it is impossible to make
comparisons over time.
31. This inconsistency also creates a false impression
of the quality of schools and colleges across the country declining,
when on average the reverse is the case.
32. ASCL members report that the behaviour of
and the standards applied by different Ofsted teams vary significantly.
In the interests of consistency all inspection teams should be
led by a full-time HMI.
33. The present system does not allow for consistency
in judging all institutions where post-16 learners are studying.
Different frameworks are used even though students may be the
same age, studying for the same qualifications and are in the
same geographical area.
34. Different sets of benchmarks and different
methodologies are used to assess the progress of post-16 learners
in different settings; for example, success rates are used in
colleges and not in schools.
35. The current system encourages some inspectors
to an over-reliance on data, which can lead to inconsistency in
judgements especially when the quality of teaching and learning
seen in the school or college does not match the data.
36. Under the current Ofsted arrangements the
cut off point between good and satisfactory lies at around the
50th/60th percentile - close to the most densely populated part
of the distribution and for most institutions well within the
confidence intervals of data available to Ofsted. Such data cannot
present evidence that can be validly used to make the distinction
between good and satisfactory. Therefore, the current grading
system is inappropriate in that it offers no valid statistical
distinction between good and satisfactory, but can imply that
the standard of education is less than satisfactory.
37. In the interests of consistency and fairness
ASCL, therefore, recommend that the current grading system should
change and that there should be three grades:
Above expected level of performance.
Around expected level of performance.
Below expected level of performance.
The weight given to different factors within the
inspection process
38. ASCL welcomes a move to a tighter focus on
core activities within a school or college, such as teaching and
learning, and leadership and management. This will provide evidence
to judge if a good education is being given and if there is the
capacity to improve further. The first incorporates examination
results but also looks deeply into the student's experience. The
second involves a judgement on the quality of leadership and management.
39. School self-evaluation and college self-review
generate a rich data set and inspectors should take account of
this data and should not restrict themselves to national measures.
Many schools and colleges use other data to good effect, such
as Fischer Family Trust, Durham University CEM Centre, ALIS and
ALPs. ASCL cannot support a situation in which any single measure
is taken as the sole true measure of performance. Intelligent
use of statistics to improve performance cannot rely on one measure
alone.
40. ASCL believes that intelligent accountability
demands that the contribution of a school or college to student
wellbeing should be assessed by a person, not a statistic. It
should, therefore, be a part of self-evaluation and if external
judgement is deemed necessary it can be validated by inspectors.
41. ASCL has already stated that compliance issues
should be moved away from Ofsted to a biennial audit as part of
the standard external auditing process of a school or college.
That would free Ofsted to focus on the quality of education as
described in paragraph 38.
42. These issues include financial probity, and
the obligations on governing bodies to comply with teachers pay
and conditions regulations[30]
and safeguarding.
43. Safeguarding has become a danger zone for
schools being inspected, as inspectors check that the safeguarding
procedures and records observe the letter of the law. ASCL recommends
compliance with safeguarding should be taken out of the inspection
process. Instead we would prefer to see a clear statement of what
is required, against which schools and colleges can check their
own compliance, subject to a biennial external audit as described
in paragraph 41. This is already the case with colleges.
Whether inspection of all organisations, settings,
and services to support children's learning and welfare is best
conducted by a single inspectorate
44. ASCL does not believe that there should be
a single inspectorate for this purpose. Dividing Ofsted into more
specialized inspectorates would allow for inspectors who are experts
in particular organisations, settings and services to carry out
the inspections.
45. However, ASCL would like inspections to cover
the whole of an organisation rather than separate inspections
of sectors within the same school or college, for example of different
aged students, or of boarding provision, so that there are not
fragmented and multiple inspections which place an unnecessarily
heavy burden on schools and colleges.
The role of Ofsted in providing an accountability
mechanism for schools operating with greater autonomy
46. There is still a role for Ofsted in providing
a mechanism for accountability, though inspection should be proportionate
to the need for it. ASCL believes that schools and colleges judged
by Ofsted to be performing at the highest grade should have less
frequent inspections than those where there are concerns. Proportionality
of inspections is a sensible use of Ofsted's resources.
47. ASCL considers that the very best schools
and colleges should be subject to a very light touch quality assurance
as they already make good use of data, self-evaluation and feedback
from parents and students to improve their performance without
needing regular visits from inspectors.
48. Such an approach would be consistent with
intelligent accountability and with the government's commitment
to proportionate regulation.
49. As a safeguard for students and parents,
a school's self -evaluation could be checked by Ofsted during
the cycle of a pupil's attendance at school, once every five years.
This would also be an appropriate interval for a check on the
SAR of the highest performing colleges.
50. The shorter notice period of an inspection
has been well received. However, inspections can be so short that
there is an undue reliance on data with insufficient time to check
the student experience behind the data. Where an inspection does
take place, ASCL believes that its length should be fit for purpose.
51. Inspectors should avoid relying on single
national data indicators and one year's results. A single measure
should not be seen as the sole verdict on performance. Schools
self-evaluation and colleges self-review generate a rich data
set and inspectors should take account of this (see paragraph
39).
52. The quality seen in schools and colleges,
for example the inspectors' observation of teaching and learning,
can differ from the data. Therefore, judgements should not be
made on data alone.
53. ASCL believes that CVA is a more legitimate
measure of school and college performance than value added, and
that value added is more legitimate than raw results.
54. However, CVA and LAT (Learner Achievement
Tracker) have several shortcomings so that ASCL recommends that
the government convenes a group to improve the measure on which
schools and colleges are judged in context.
October 2010
27 At the Times Educational Supplement general election
debate in London on 15 March 2010 the phrase "intelligent
accountability" was used by all three major party spokesmen
within the first half hour. Back
28
Towards intelligent accountability for schools: a policy
statement on school accountability, March 2003. Back
29
Intelligent accountability in practice, Policy Paper 68. Back
30
As set out in the School Teachers Pay and Conditions Document. Back
| 
