Memorandum submitted by the Association
of Directors of Children's Services |
The Association of Directors of Children's Services
Ltd (ADCS) is pleased to submit this brief written evidence to
the House of Commons Education Select Committee. This submission
does not address every aspect of the Inquiry's terms of reference.
It focuses principally on the inspection of local authority children's
ADCS is the national leadership organisation in England
for directors of children's services appointed under the provisions
of the Children Act 2004 and for other children's services
professional in leadership roles. The Association provides a national
voice as a champion for children, with local and central government,
and with the public.
In summary, we would make the following points:
- Inspection is a vital part of ensuring public
accountability and the continuous improvement of children's services.
- There is potential for significantly reducing
the costs associated with inspection activity without reducing
the value of inspection in providing this accountability and improvement.
- These reductions in cost can be achieved through:
- a significant reduction in the bureaucracy associated
with inspection and improvement; and
- ensuring inspection is proportionate and risk
- Overall, inspection and improvement should
involve less activity for both the inspectorate and the services
1.1 The relationship between inspection and
It is vitally important that the quality of public
services for the most vulnerable is inspected; inspection is an
important part of the public accountability framework. Inspectorates
and those charged with delivering services have a shared interest
in making a difference to service users by striving to identify
and make the improvements that are necessary in order to continuously
improve the positive impact that those services achieve. This
must especially apply to the protection of society's most vulnerable
children and young people.
Continuous improvement must be a shared endeavour
between Regulators and those charged with delivering services.
Any inspectorate must work closely together with the sector it
inspects and must itself be willing to learn, adapt and play an
appropriate part in improving public services. Open and regular
dialogue between inspectorate and the sector is essential.
1.2 The purpose of inspection
We believe firmly that a single inspectorate should
conduct inspection of all organisations, settings and services
to support children's learning and welfare.
It is important that inspection recognises service
failings; it is particularly important that inspection is able
to identify children and young people who are unsafe or at risk,
be that a safeguarding or an attainment risk, or that a young
person is at risk of becoming NEET for example. Detecting and
preventing service failings can be carried out through the use
of risk analysis of publicly available information.
We need a system that improves services, works in
an integrated way and allows our very best practitioners to influence
the development of models of quality.
Inspection should be a formative not a punitive process.
The current frameworks under which local authority children's
services are inspected do very little to ensure that service leaders
are managing for improvement, rather the reverse is more frequently
the case that service leaders are managing for the inspection
itself. Indeed an industry has grown up around the preparation
for announced inspection. This is because the consequence of a
poor service inspection outcome on the overall annual rating of
a children's services department is serious indeed. The perceived
punitive effects and the impact of judgements on services in terms
of the local (and national) media and political response have
created the climate whereby the inspected manage for inspection
rather than managing for quality and continuous improvement of
services for children and young people.
ADCS advocates a new approach to the inspection of
local authority children's services. We need a framework that
supports continuous improvement and is proportionate to risk,
with targeted sector-led improvement support. Alongside this there
would be an attendant reduction in the burden of performance monitoring
and inspection by central government and inspectorates.
The role of Ofsted in providing an accountability
mechanism for schools operating with greater autonomy is crucial,
indeed if admissions and exclusions are to be the responsibility
of individual schools rather than the local authority, there is
an even greater need for accountability particularly with regard
to excluded and off-roll pupils who are particularly vulnerable.
2. LOCAL AUTHORITY
2.1 Unannounced inspections of safeguarding
The principle of unannounced inspection is right
and drives improvement without the excessive preparation for announced
inspections. Such inspection should remain short, sharp and focussed,
although the current focus of unannounced inspection of contact
and referral centres (front door duty rooms) could helpfully be
broadened to include other aspects of safeguarding and child protection
2.2 The annual rating of Local Authority Children's
A wide range of organisations, settings and services
are inspected in order to give local authority children's services
departments a graded annual performance rating, including a number
of settings over which the LA has no control eg child minding
services provided by sole child minders, academy results etc.
There is a mismatch between the organisations that contribute
to the annual assessment rating and the powers and levers that
local authorities have to improve those establishments - for example,
inspection results for private child minders and academies contribute
to the annual rating but local authorities do not have levers
to drive improvement or, in the case of childminders, to prevent
poor providers from continuing to offer registered child care.
In addition, as more schools become autonomous, less information
and data and 'soft intelligence' is available to the local authority,
removing the current "early warning signals".
Dropping the requirement to undertake an annual rating
would significantly reduce the volume, burden and cost of inspection.
The current four-point graded annual performance rating is a simplistic,
unsophisticated approach to describing the extremely wide-ranging
and complex services that are the responsibility of the DCS. We
believe that the publication of this data by each local authority
would provide accountability to the public and allow for risk
based inspection based on identified triggers - such as a decline
in attainment. This could be accompanied by a local authority's
self-assessment report on its progress where this already exists.
A more proportionate risk-based approach to inspection
would focus attention on improvement. Local authorities that have
evidenced an improvement trend need not be inspected routinely
unless there are concerns, for which a series of triggers exist.
Sampling could also take place.
3. SCHOOL INSPECTION
3.1 The impact of the inspection process on
Inspection should comment on all major aspects of
the work of schools/settings which contribute to the all-round
development of children and young people. If something is not
inspected, schools will tend to give those important aspects less
attention. Inspection should continue to provide clear pointers
The more rigorous Framework put in place since September
2009 has helped raise standards in schools.
Ofsted's role as a moderator of school self-evaluation
has been a good development. The Evaluation Schedule provides
clear guidance on achieving the highest quality in different areas
and acts as a means by which schools can self-evaluate rigorously
and accurately by using the grade descriptors to judge their performance.
The descriptors enable school leaders to hold staff and themselves
to account. They also help governing bodies to have some kind
of benchmark through which they can monitor school progress. The
clarity of the guidance supports objectivity. Overall, the process
supports schools in building their own capacity for improvement.
Any longer than three years between visits is too
long, even for outstanding schools. Outstanding schools need regular
monitoring. Just because they have been judged as outstanding
in one inspection, it doesn't follow that the level of performance
will be maintained.
The current emphasis on judging EYFS and post-16
provision as separate aspects has been helpful.
The short notice before an inspection is appropriate.
The possibility of revisiting satisfactory schools a year later
helps accelerate the rate of progress by providing a sense of
3.2 The performance of Ofsted in carrying
out its work and the consistency and quality of inspection teams
in the Ofsted inspection process of schools
Schools report generally that they are satisfied
with the inspection process. Where there is dissatisfaction it
is usually because the attitude or approach of the lead inspector
has been unhelpful. Usually the quality of inspection teams is
Because inspectors are observing a large number of
lessons during the process, judgements on the quality of teaching
and learning tend to be accurate.
3.3 The weight given to different factors
within the inspection process
The weight given to different factors within the
inspection process seems to have helped schools focus on improving
outcomes for all learners. The specific focus on the attainment
and progress of pupils with SEN/LDD has also been helpful. We
are concerned that schools will no longer be accountable for their
contribution to the well-being of pupils and would advocate that
schools are accountable through the inspection process or otherwise
for the way in which the pupil premium, once it is introduced,
is used to improve the attainment of the most vulnerable pupils.