1.Do You Agree That There Should Be a Single Inspection Framework from September 2008?

INTRODUCTION

1. The National Union of Teachers (NUT) welcomes the opportunity to respond to the above OFSTED consultation. The NUT has commented below on each of the proposals made by OFSTED, in the order that they appear in the consultation document.

1.Do you agree that there should be a single inspection framework from September 2008?

1. The proposal to bring together the two different inspection frameworks for initial teacher education (ITE) which exist currently into a single framework is sensible as this development should promote consistency across all forms of ITT provision, both in terms of quality of experience for trainees and inspectors’ perceptions of this.

1. The NUT welcomes in particular the reference in the consultation document to the employment-based training routes to Qualified Teacher Status (QTS) and OFSTED’s acknowledgement that they “have not been looked at in depth”. The NUT has expressed concerns consistently about the variations in quality of such provision and hopes that the proposed new arrangements will bring increased rigour to such ITE providers’ quality assurance procedures, as well as improving the quality of trainees’ experience overall.

1. The distinctive features of ITE for schools and for further education should be reflected adequately in both the revised framework itself and the guidance and training provided for inspectors. There will need to be sufficient flexibility within the framework to ensure that such a common approach to inspection is able to capture and evaluate accurately the extent to which provision prepares trainees for the type of setting in which they will teach.

1. The proposed alignment of therevised ITT inspection framework with OFSTED’s Common Inspection Framework should reinforce commonality of approach throughout the education system. The demands of the new arrangements on school-based providers should, however, be subject to particular consideration in terms of workload. A commitment to ensuring that ITE inspections are not conducted in the same year as a Section 5 inspection, for example, would be a welcome first step.

1. As the consultation document notes, it would be timely to introduce new inspection arrangements from September 2008, given the introduction of the new QTS Standards and ITE provider requirements, in addition to the timeline for the current inspection cycle.

2.Do you agree that the proposed inspection schedule will enable fair and accurate judgements to be made of the quality of provision?

1. The use of the statutory requirements for ITE as the criteria which underpin the draft inspection schedule is welcome, as is the proposal that provision will not be graded satisfactory if all of the statutory requirements were not met. Such an approach should help to ensure a minimum standard of provision for trainees, regardless of the training route they choose.

1. Much of the contents of the proposed inspection schedule appear to be relevant and useful in helping both providers and inspectors to reach judgements on the quality of provision. The emphasis placed on partnership working in the schedule is particularly welcome as, in the experience of the NUT, this is often the most problematic area of ITE provision. Poor communications and inconsistencies of practice, including assessment, between providers and placement schools are the most common causes of difficulties for NUT student members

1. The proposed focus on trainee ‘outcomes’ is, however, a cause for concern. Inspectors’ scrutiny of retention rates and the proportion of trainees who successfully complete the course will inevitably lead to some providers feeling under pressure to prevent trainees from leaving a course early, even if it was in their best interests and, at worse, could influence decisions about whether a trainee had passed or failed.

1. In order to assess the quality of trainees’ achievements and progress, it will be necessary to establish a benchmark against which individuals’ progress and “fulfilling their potential”is measured. How this may be done, given that many ITE programmes are of one year’s duration and that most trainees do not have prior experience of teaching, is not explained. In addition, QTS trainees receive either a ‘pass’ or ‘fail’ grade, which could make the definition of achievement even more rigid.

1. In terms of trainees’ level of performance, the effect of factors arising as a direct result of the nature of their placement school(s) should be taken into account by inspectors and explicit reference made to it in the inspection schedule. Trainees placed in challenging schools, for example, could be less able to demonstrate a full range of teaching methods compared to those placed in more affluent areas as a result of pupil behavioural issues. Conversely, the level of behaviour management expected of trainees working in challenging schools might be much higher than that demanded in other areas. Inspectors’ application of the inspection schedule should enable them to make such fine distinctions when making final assessments of overall effectiveness of provision, to be both fair to providers and to prevent more challenging schools from being excluded from involvement in ITE.

3.Do you agree that future inspections should be proportionate to risk and tailored to the context and needs of each provider?

1. The NUT has had long-standing concerns about theidea that inspection should be in inverse proportion to success. Although it could be argued that this approach represents a more cost effective use of inspectors’ time, and would certainly be welcomed by the minority of providers which would be classified as eligible for a reduced inspection, there is a danger that the provision which would receive increased inspection visits could experience a decline in morale and difficulties in recruiting and retaining staff, which would have an additional adverse impact on the quality of provision. The full inspection proposed for new providers and for those which do not comply with the statutory ITE requirements is logical however.

1. No details of the form “even lighter touch inspections” would take are included in the consultation document. It is vital that the further streamlining of the inspection arrangements now proposed does not reduce the opportunities for proper dialogue to develop. The much greater emphasis given to performance data should, however, lead to less direct contact between inspectors and providers, trainees, placement schools and other stakeholders, which would be a retrograde step.

1. The consultation document says that the proposals are predicted on “achieving better value for money” (page 4). Value for money, however, should not be the main criteria for basing fundamental changes to inspection arrangements. It is essential that the effectiveness of the service provided by OFSTED to ITE providers should be considered when framing any new proposals. The inspectorate is in the optimal position to present an overview of best practice and ‘what works’ in a wide range of contexts. In terms of value for money, this function should be exploited far more.

4.Do you agree that providers’ assessment of their own performance, with a primary focus on the outcomes for trainees, should be at the heart of the new inspection framework?

1. The introduction of self-assessment as a central feature of the new inspection arrangements for ITE providers would bring inspection practices for this sector into line with those for other educational settings. Although OFSTED might stress in the consultation document that this proposal is intended to reduce bureaucratic and administrative burdens on providers, this has yet to have an impact at schools level, where self assessment has been at the heart of inspection since September 2005. Under the proposed arrangements, it is likely that the majority of providers could feel under increased pressure to have a wide range of documentary evidence available ‘just in case’ they are inspected, especially as there would be less time when inspectors were on-site to observe evidence at first hand.

1. OFSTED’s commitment to non-statutory status for the self-assessment documentation and the option of providers using other forms of submitting evidence of their self-assessment work is welcome. In practice, however, it is unlikely that many providers will choose to use this option, as the information which OFSTED required would be tightly prescribed. This could lead to a ‘check list’ approach to self-assessment, rather than the richer, and more developmentally useful, outcomes derived from genuine self-evaluation, of which the NUT has long been a leading advocate. In addition, this proposal could encourage providers to view self-assessment as self-inspection, which will also dilute the potential of identifying and using this information in partnership with all ITE stakeholders.

1. The NUT has particular concerns about the potential burden the proposed self-assessment arrangements may place on school-based ITE providers. Evidence from a recent survey of NUT members suggested that the school self evaluation form (SEF) was a significant driver of workload, particularly for head teachers and other senior staff. To in effect double the amount of such documentation for schools which lead ITE partnerships may become a disincentive for schools to take on such roles in the future. Greater consideration needs to be given to streamlining these requirements for schools, so that evidence which is provided as part of Section 5 inspections is not required to be duplicated for ITE inspections.

5.Is it reasonable to expect providers to submit evidence of their use of the views of initial teacher education users?

1. The proposed inclusion of the views of trainees, those who have recently completed their training and their employing institutions is a welcome development. Wherever possible this should be aligned to existing relevant activities, including the TDA’s annual survey of trainees, to minimise bureaucracy and eliminate duplication of effort.

1. It is unclear from the consultation document whether schools and other settings involved in ITE partnerships will be invited to contribute to this process. The day-to-day practical perspective which could be provided from placement schools, for example, would be invaluable in the formulation of a complete picture of ITE provision’s quality.

6.Is it feasible to ask for self-assessments to be submitted as soon as the provider’s own review process has been completed, and by the end of November at the latest?

1. Clarification is needed of what is intended by the reference in paragraph 28 of the consultation document to “updates of the self-assessment”. OFSTED should not encourage providers to believe that the self-assessment documentation should be updated more than once a year and should include guidance on this in the final version of the revised framework.

7.Do you agree in principle that inspections should be planned so that all providers receive one inspection event encompassing all phases, routes and sectors simultaneously?

1. The proposed move to a single inspection which would scrutinise all ITE provision offered by a provider is a welcome development. This should reduce the burden of inspection on providers and their partners substantially and should also encourage greater consistency of approach between the different types of ITE provision inspected. A well-matched and experienced inspection team would be even more essential in such circumstances, however, to ensure equality of coverage and accuracy of judgements for all provision to be inspected.

8.Do you agree that, under normal circumstances, the standard period of notice for initial teacher education inspections should be six working weeks before the inspection visit?

1. The reduction of the notice of inspection for ITE providers to six working weeks is a sensible compromise which balances the desire by OFSTED to conduct ‘short notice’ inspections with the need for providers to make arrangements with partners which would be involved in the inspection. As the consultation document notes, the notice period used for school inspections would not be appropriate in these circumstances, because of the substantially more complex logistics of ITE inspections.

NUT RESP - OFSTED ITT 2008-11_KDR27 September 2018

Created: 22 February 2008/CS

Revised: 28 February 2008/LO