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SSAT’s response to Ofsted’s draft Education Inspection Framework consultation

On 5 April, SSAT formally responded to the draft Ofsted framework, which is scheduled to be used in schools, colleges and other education providers from September 2019. SSAT does not formally represent members’ views, rather our response is informed by conversations and dialogue with member schools and our own analysis.

Proposal 1:

To what extent do you agree or disagree with the proposal to introduce a ‘quality of education’ judgement?

Strongly agree Agree Neither agree nor disagree Disagree Strongly disagree Don’t know
x

Comments:

  • SSAT welcomes the shift away from a focus on historical data and the move towards a greater emphasis on the providers’ current curriculum intent, implementation and impact.
  • SSAT’s ‘Four Pillars of Principled Curriculum Design’, developed in 2016, is a resource that allows school leaders and teachers to reflect on their curriculum’s intent, content, delivery and experience. We feel that this aspect of the draft framework could reinforce our approach to principled curriculum design.
  • Our special schools’ steering group particularly welcomes a move from performance data to curriculum experience.
  • At various SSAT events over the last 12 months, where these ideas have been discussed, members have generally been favourable towards this approach – although we do share some concerns.
  • The draft framework seems to present the Ebacc as the foundation of an academic curriculum. We dispute this for several reasons. SSAT is clear that the Ebacc is not a curriculum model or even foundation for a curriculum but a school-level performance measure. We have continually campaigned for the Ebacc not to be compulsory for all students, although it should be available to all. Our modelling shows that a compulsory Ebacc would lead to a narrowing of the curriculum, particularly at a time of financial pressure. We agree with the assertion in the draft framework that ‘at the heart of an effective KS4 curriculum is a strong academic core’, however we do not think this can only be achieved with the Ebacc.
  • Can Ofsted guarantee that inspectors’ evaluation of the curriculum will be consistently reliable and valid? We have concerns that a lack of both subject- and phase-specialism within inspection teams will limit the quality and effectiveness of discussion about progression and subject curricula. This could also undermine the consistency of judgements, both between providers and within them. We would welcome public reassurance from Ofsted of how it intends to ensure that judgements on the quality of education will be robust, reliable and valid.
  • SSAT members have expressed concern that the draft framework will lead to a notion of an ‘Ofsted-approved’ approach to curriculum design. We recognise that HMCI has repeatedly dismissed this idea, but we would welcome further reassurance. We would like to see Ofsted taking action when third-party providers claim to have off-the-shelf, Ofsted-approved solutions to curriculum planning.

Proposal 2:

To what extent do you agree or disagree with the proposed separation of inspection judgements about learners’ personal development and learners’ behaviour and attitudes?

Strongly agree Agree Neither agree nor disagree Disagree Strongly disagree Don’t know
x

Comments:

  • It seems broadly sensible to separate these two judgements. While there will inevitably be some overlap, the two judgements complement one another and do describe different aspects of providers in meaningful ways to parents and other stakeholders.
  • In the judgement on ‘personal development’, we are pleased that Ofsted recognises that providers can only do so much in the context of wider societal issues.
  • In recognising this, Ofsted should also publicly acknowledge the increased pressure on schools due to the reduction in support from local agencies and real-time school cuts in school budgets.
  • The continued use of the terms “personal development” and “behaviour and attitudes” is not consistent with the language of EYFS where these concepts sit within the areas of learning (personal, social and emotional development) and the Characteristics of Effective Learning.

Proposal 3:

To what extent do you agree or disagree that the judgements will work well for:

Strongly agree Agree Neither agree or disagree Disagree Strongly disagree Don’t know
Childminders x
Childcare on non-domestic premises x
Childcare on domestic premises x
Childcare settings that offer care exclusively before and after school x

Comments:

  • Early years providers and schools are subject to the same statutory requirements for the EYFS. However, there are significant differences between the Early Years inspection handbook and the Early Years section of the School Inspection Handbook. It is important that all settings are inspected using equivalent criteria so that parents can compare inspection reports between providers and that children’s experiences are of equal quality regardless of the provider they attend.
  • We welcome the shift during inspection from a narrow focus on data to one on the quality of education and curriculum as a whole. However, how can a snapshot observation during an inspection ensure consistency in judgements from inspectors in relation to ‘impact’? For EYFS settings where no national data exists, there should remain discretion to use internal progress data as evidence for inspectors to see what children are achieving, while retaining flexibility for settings to use the form of evidence they find most appropriate, including the professional judgement of staff.
  • Ofsted should review the Early Years draft inspection handbook and the school inspection handbook to ensure that the only criteria against which providers will be inspected are based on the Statutory Framework for the EYFS and are consistent between the schools and early years handbooks.
  • The language of the framework is very school-based and not easily accessible to all EY providers. The school inspection handbook talks about ensuring there is no narrowing of the curriculum from KS2 onwards. There should equally be no narrowing of the curriculum in the EYFS or KS1. The handbooks need to make clear that all children are entitled to the full range of the EYFS.

Proposal 4:

To what extent do you agree or disagree with the proposed focus of section 8 inspections of good schools and non-exempt outstanding schools and the proposal to increase the length of these inspections from the current one day to two days?

Strongly agree Agree Neither agree nor disagree Disagree Strongly disagree Don’t know
x

Comments:

  • It would be unhelpful to lose the short, one day ‘health-check’ section 8 inspection. Given the percentage of good schools, this additional requirement would be a poor use of Ofsted’s resources which might be better spent providing more support to schools that need it.
  • There is already provision to convert a section 8 inspection into a full section 5. Under the new framework, inspectors should continue to use this option judiciously.
  • We also question what the difference would be between a two-day section 8 and a two-day section 5 inspection. The proposal would blur the distinction between them.
  • The logical implication that two days are required for a section 8 inspection is that two days may be insufficient for a section 5. Ofsted needs to confirm how they will ensure that evidence collection is robust and sufficient within the current time available, without putting undue stress or increased workload on schools.

Proposal 5:

To what extent do you agree or disagree with the proposed introduction of on-site preparation for all section 5 inspections, and for section 8 inspections of good schools, on the afternoon prior to the inspection?

Strongly agree Agree Neither agree nor disagree Disagree Strongly disagree Don’t know
x

Comments:

  • Currently, headteachers have a long telephone conversation with the lead inspector the day before the inspection, after which they compile and send agreed documentation and brief staff. It is not until the following morning that firm arrangements are made for the inspection activity.
  • Conceivably, the proposed arrangements could benefit school leaders by giving them the opportunity to shape the inspection activity and to discuss issues face-to-face with the lead inspector, before the inspection starts.
  • Senior leaders generally have expressed to us appreciation of the usefulness of the initial meeting on day one of a current section 8 inspection. If this can be replicated, without putting additional demands on the school, this could be a positive change.
  • However, there is also some genuine concern about this proposal which has been regarded by some as a no-notice inspection. While we generally think such an approach could improve preparations for the subsequent inspection, Ofsted would need to ensure that the on-site meeting was not used by lead inspectors as an early start to the inspection itself.
  • We also recognise that if a headteacher is out of school on the day of the phone call (which can currently be conducted remotely), it may be difficult to return to school that afternoon. This would put additional pressure on headteachers, and may discourage some headteachers from undertaking potentially valuable external CPD.

    Proposal 6:

    To what extent do you agree or disagree with our proposal not to look at non-statutory internal progress and attainment data and our reasons why?

    Strongly agree Agree Neither agree nor disagree Disagree Strongly disagree Don’t know
    x

    Comments:

  • We agree that it is not possible during an inspection to verify the accuracy of an individual schools’ internal assessment practices and that looking at internal data can therefore be meaningless.
  • However, we do not want this to be interpreted as inspectors not being interested in learning about the progress of current year groups. It would be a backward step if the impact of the curriculum were to be evaluated only by historical data.
  • Ofsted should be clearer about the type of discussions inspectors will have about progress.
  • We welcome Ofsted’s continued attempts to reduce unnecessary workload and hope that, by not asking for internal data sets, schools only collect appropriate data to help students’ progress teachers’ planning.
  • However, we are concerned that the draft framework places an over-emphasis on work scrutiny, which we feel is not always a reliable source of evidence to judge whether students are progressing, especially when undertaken by a non-subject or -phase specialist.
  • Colleagues from special schools are encouraged by the emphasis and spirit of the proposed new framework.
  • Although they welcome the greater emphasis on SEND, they note that hospital schools are not referred to.
  • They are concerned by the emphasis on reading and suggest that “communication and interaction” should be highlighted in special schools.
  • There is nothing in the grade descriptors for leadership and management relating to SEND (although there are under Quality of Education). Paragraphs 293 to 295 highlight leaders’ clear obligations for SEND. Should these be referred to in the L&M section?
  • SSAT welcomes the increased scrutiny of off-site provision and the attention to be paid to potential gaming and off-rolling.
  • Will the findings from the consultation be published before the final framework?

    Is there anything you would like us to improve or do differently for future consultations? If so, please tell us below.
  • The direction of travel has been articulated by Ofsted for a long time, and senior members of the Ofsted team have engaged well with professional bodies and the school sector generally. This is very welcome.
  • However, providers are concerned that the final framework will be published with very little time before the summer holidays. Providers that are inspected early in 2019-2010 under the new framework, should not be penalised by this, nor should it add to any providers’ workload over the summer.
  • The consultation was limited in its design, which did not allow for nuanced responses. For example, while SSAT generally agrees with the proposal to introduce a ‘Quality of Education’ judgement in place of a judgement on ‘Outcomes’, we do not endorse several aspects of the draft framework under that heading.
  • This includes a much-needed consultation on the future of graded judgements.

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