Better Inspection for All

Better inspection for all

Maintained schools and academies, further education and skills providers, non-association independent schools and registered early years settings – consultation questionnaire

Age group: 0–19+

Published: October 2014

Reference no: 140165

Better inspection for all

We welcome your views on our proposals for new arrangements for the consistent and proportionate inspection of maintained schools, academies, further education (FE) and skills providers, non-association independent schools and registered early years settings from September 2015.

We propose:

a common inspection framework for all early years settings on the Early Years Register, maintained schools, academies, non-association independent schools and FE and skills providers – this framework will mean that the same judgements will apply in each of these remits

introducing shorter inspections for maintained schools, academies and FE and skills providers that were judged good at their previous inspection – these short inspections, conducted approximately every three years, will report on whether or not a provider has maintained its overall effectiveness but will not provide a full set of graded judgements

conducting a full inspection of non-association independent schools within a three-year period.

We are also keen to hear your views on how inspection methodology should be developed and whether or not we should introduce a separate graded judgement for the curriculum.

Your views will help to refine and develop our framework for inspecting these services.

This document should be read alongside the full consultation document available from

How to submit your views

There are three ways of completing and submitting your response.

Complete the online questionnaire

Download this document from:

complete it on your computer and email your response to

.

Print this document, complete it by hand and post it to:

FOIE consultation
Ofsted
8th floor
Aviation House
125 Kingsway
London
WC2B 6SE

The consultation will be open until 5 December 2014.

Confidentiality

The information you provide will be held by Ofsted. It will only be used for the purposes of consultation and research to help us to become more effective, influence policies and inform inspection and regulatory practice.

We will treat your identity in confidence, if you disclose it to us.

Are you responding on behalf of an organisation?

YesXplease complete Section 1 and the related questions

Noplease complete Section 2 and the related questions

Section 1

Which organisation are you responding on behalf of?

Organisation:The Communication Trust

Would you like us to consider anonymously publishing your views?

YesX

No

Section 2

Please tell us in which capacity you are completing this survey (please choose one option):

Teacher / Local government representative
Governor / Inspector
Headteacher / A registered early years group provider
Other school staff / A registered early years childminder
Pupil/student / An early years provider run directly by a school
Academy chain representative / Leader/manager of a further education and skills provider or college
Parent/carer / Other employee of a further education and skills provider or college
Teacher/trainer of a further education and skills provider or college / An employer with an SFA training contract
An adult learner/student / An employer without an SFA training contract
A member of the public / Proprietor of an independent school
Representative group or union representative / Prefer not to say
Other, please tell us – Representative of a coalition of 50 not for profit organisations who work together to support children and young people’s speech, language and communication.

If you are responding in a professional capacity, please specify where you work:

A maintained primary school / A primary academy
A maintained secondary school / A secondary academy
A non-association independent school / An early years provider
A general FE/tertiary college / A not-for-profit organisation / X
A sixth form college / An independent specialist college
A local authority / A higher education institution
An independent training provider / Prefer not to say
Other, please tell us
Introduction from The Communication Trust
We welcome the opportunity to input to this extremely important consultation from Ofsted. We have provided detailed and evidenced answers to the questions in this consultation most relevant to achieving quality support, childcare and education for all children and young people in relation to their speech, language and communication and also for those with speech, language and communication needs. Here we take the opportunity to outline our key points, which we develop in further detail and with additional issues in our full response.
We would very much welcome the opportunity to work with Ofsted to support improvements around these key points we raise here, sharing our expertise in supporting speech, language and communication/speech language and communication needs to ensure this review has the best possible results and impact for children and young people.

• We recognise the value of a coherent approach to inspections and the aim for improved comparability and consistency across providers and settings, but have a range of concerns about how this will be achieved through the suggested framework and undefined proposals for remit guidance.

• We have selected ‘disagree’ in relation to questions around the judgements proposed, not because we disagree with the existence of that particular category of judgement, but with the content (or lack of in some cases) included within them.We have provided evidenced suggestions around issues we’ve picked up on in the graded judgement areas and would be happy to discuss any of these further with Ofsted.

• We are very concerned that communication has lost its specific mention in the framework proposed and is now being included under the hugely broad ‘other skills’ descriptor. This omission does not sufficiently recognise the crucial role language and communication skills play across all areas of learning and development across all aspects of childcare and education and also to support a successful transition into adulthood and the world of work as an ‘economically active member of society’- the CBI itself includes communication skills within its definition of employability[i]. The 2012 schools’ framework mentioned explicitly that when evaluating the achievement of pupils, inspectors would consider how well pupils develop a range of skills, including reading, writing, communication and mathematical skills, and how well they apply these across the curriculum. This was an absolutely essential inclusion which we very much welcomed and we’re disappointed to see that it’s not been reinstated in this proposed framework.
• Overall we are concerned that there are inherent challenges in devising a common framework which will apply equally to babies and young children as to young adults in the FE sector and the current proposals do not achieve this balance. We are particularly concerned that the common framework does not adequately relate to or reflect the requirements of quality provision in early years settings, and most particularly in relation to babies and young children aged 0-2.
• We urge Ofsted to ensure that special educational needs and disability (SEND) has an appropriately high emphasis in the framework. The central importance of provision for children and young people with SEND has never been more prominent than it is currently with the new Children and Families Act and Code of Practice. It is essential that any inspection framework holds settings strongly to account in relation to SEND. The proposed framework only lists how well provision meets the needs of those with a disability and/or SEN as an ‘additional consideration for inspectors’ with no specific grade attached. Whilst we recognise the difficulty of adding additional grades to the evaluation schedule, serious consideration should be given to a requirement that there be a separate section in the report on the quality of provision for pupils with SEN to ensure that parents are able to appropriately compare the quality of provision in this respect.The current proposal greatly undermines the key importance and requirement for schools and settings to offer high quality SEND provision and the importance of judging settings and schools effectiveness on this is diminished in comparison to previous frameworks. Evidence has shown that speech, language and communication needs (SLCN) is an SEN where the gaps have not narrowed – they’ve widened - and it is essential that all settings and schools are accountable for their pupils with SLCN making good progress through the Ofsted inspection.
• Whilst we have engaged with this consultation, providing detailed and well evidenced points, a definitive view is difficult given the lack of clarity about the content of the centrally important remit handbooks that there is in the proposals currently. It will be essential for considerable detail to be included within remit handbooks.
  We would welcome the opportunity to input to and provide feedback on proposals around the remit handbooks and in particular would welcome an SEND specific remit handbook.

Proposal 1: A common inspection framework

We propose, from 1 September 2015, to introduce a new common inspection framework that we believe will provide greater coherence across the inspection of different providers that cater for similar age ranges. It will ensure more comparability through inspection as children and learners move from one setting to another and support greater consistency across the inspection of different remits.

See paragraphs 10–31 of the full consultation document for more detail.

Q1. Do you agree or disagree with the introduction of a new common inspection framework for maintained schools, academies, further education and skills providers, non-association independent schools and registered early years settings from September 2015?

Strongly agree
/ Agree
/ Neither agree nor disagree / Disagree
/ Strongly disagree / Don’t know
X

Comments:

Principle of a Common Inspection Framework and Remit handbooks
While we recognise the value of a coherent approach to inspections and the aim for improved comparability and consistency across providers and settings, we have considerable concerns in relation to specific aspects of the proposed common framework.
We feel that there are inherent challenges in devising a common framework which will apply equally to babies and young children as to young adults in the FE sector and the current proposals do not achieve this.
We are hugely concerned that the framework, as it is written, does not adequately relate to or reflect the requirements of quality provision in early years settings and most particularly in relation to babies and young children aged 0-2. This is an absolutely critical period of development,as is widely recognised,and the lack of applicability and reference to very young children in the proposed framework is of great concern. Within the current inspection framework for early years for example, there is clear reference to children’s learning and development; it is essential that any common inspection framework going forward appropriately and explicitly reflects this.
Whilst we understand that there will be inspection handbooks with detail specific to each remit, we are concerned that as a principle, the overarching common inspection framework covering all age ranges in this way is not sufficiently ‘common’ and therefore the level of detail requiredin the handbooks to make them applicable and relevant to different settings/ages will minimise the possibility of making clear comparisons.
Speech Language and Communication
In the new framework, we would very much welcome a greater emphasis on the role of language and communication skills (point 12). Speech, language and communication skills are crucial throughout every age and phase of development and a common assessment framework would ideally place importance for all providers to ensure that they are effectively supporting children’s development and effectively identifying and supporting those children and young people with speech, language and communication needs (SLCN)
Special educational needs and disability (SEND)
We would also very much recommend a key emphasis within the framework on provision for special educational needs and disabilities. The central importance of provision for children and young people with SEND has never been more prominent than it is currently with the new Children and Families Act and Code of Practice which makes it absolutely clear that “special educational provision is underpinned by high quality teaching and is compromised by anything less”[ii]. It is therefore essential that a common inspection framework holds settings strongly to account in relation to SEND.
The proposed framework only lists how well provision meets the needs of those with a disability and/or special educational needs as an ‘additional consideration for inspectors’ with no specific grade attached or further detail provided. Whilst we recognise the difficulty of adding additional grades to the evaluation schedule, serious consideration should be given to a requirement that there be a separate section in the report on the quality of provision for pupils with SEND. SEND pupils’ achievement must (already) be referred to in the achievement section and a specific section on SEND in the report would provide richer information for parents and other readers, if reporting as a separate grade is not feasible. It would also provide a stronger accountability measure. The current lack of specific attention paid to SEND greatly undermines the key importance and requirements for schools and settings to provide high quality SEND provision and the importance of judging settings and schools effectiveness in relation to SEND is diminished in comparison to previous frameworks. Evidence has shown that speech, language and communication needs (SLCN) are an SEN where the gaps have not narrowed – they’ve widened[iii] - and it is essential that all settings and schools evidence that their pupils with SLCN are making good progress through the Ofsted inspection.
We would therefore recommend Ofsted ensure SEND has an appropriately strong emphasis in the framework and that SEND is reported on specifically and in detail, to ensure that parents are able to appropriately compare the quality of provision in this respect. We very much welcome the commitment that inspectors will inspect provision for which they have appropriate expertise and training and we would be very happy to continue to provide information and support in relation to language and communication and SLCN to help achieve this in practice across inspection teams.
Narrowing the Gap
As outlined above, we have concerns about whether a common inspection framework can adequately reflect the requirements of all children and young people in the age ranges catered for by different school and settings. However, if this approach is taken we feel that a continued and explicit focus on narrowing the gap in relation to social disadvantage and SEND should beclearly included, as they are common themes across all ages. Evidence shows across both the early years and throughout school, that high quality provision plays an important role in maximising attainment for socially and economically disadvantaged children. This group of children and young people is particularly susceptible to speech, language and communication delays. SLCN is the most common SEND; therefore we would welcome the continuing need for settings to narrow gaps to be more strongly recognised within any assessment framework that is adopted.
We welcome the high level of scrutiny of the curriculawhich schools and settings are implementing with their children and young people (point 18). We would very much welcome the inclusion of a key focus on how effectively settings are supporting the speech, language and communication development and spoken language skills of all their babies, children and young people within their curriculum offer. Evidence has shown that language and communication skills are in fact one of the strongest common themes across all remits, and indeed there are evidenced links to other areas of development, including attainment, behaviour and transition to adulthood. We would hope therefore that there is scope within the inspection framework for a clear focus on these skills as part of the scrutiny of the curricula on offer.
Non-maintained Special Schools
Finally, we wished to query the omission of non-maintained special schools within the list of providers for whom the common framework would apply as we feel they should be included.
We would be very pleased to work with Ofsted to exemplify what strong curricula in relation to language and communication look like.
Finally, we wished to query the omission of non-maintained special schools within the list of providers for whom the common framework would apply.

Making judgements in full inspections

Inspectors will use all the available evidence to evaluate what it is like to be a child, learner or other user in the provision. They will make judgements about a provider’s overall effectiveness during a full inspection and will consider whether the standard of education, training or care is good, outstanding, requires improvement or inadequate. They will make these graded judgements in four areas:

Effectiveness of leadership and management

Quality of teaching, learning and assessment

Personal development, behaviour and welfare

Outcomes for children and learners.

See paragraphs 15–24 of the full consultation document for more details.

Q2.Do you agree or disagree with the proposed ‘effectiveness of leadership and management’ judgement(paragraphs 19–20)?

Strongly agree
/ Agree
/ Neither agree nor disagree / Disagree
/ Strongly disagree
/ Don’t know
X

Comments:

As outlined in our introduction, whilst we agree that the effectiveness of leadership and management is an important area for judgements to be made, we feel that paragraphs 19 and 20, which have been specifically highlighted in the question, must be strengthened in terms of content.
As with the overall framework, we feel that the omission of ‘development’ from the judgements around the effectiveness of leadership and management results in a considerable gap for very young children and babies and also for those children and young people with significant SLCN or other SEN. It is essential that the leadership and management of schools and settings are required to provide and improve effective support for development of the babies, children and young people in their setting, not just their learning.
We welcome the prominence given to ‘users’ views’ in this section. The voice of the children and learners in the settings is essential for any meaningful judgement about the provision they’re accessing and we’re pleased to see it included. It will be important within the remit handbooks that there is appropriate guidance on how to achieve this with very young children and those with complex SEND.
We welcome the prospect of the inclusion of appropriate professional development provision as part of this judgement. At the Communication Trust, we have developed a framework for professional development (the Speech, Language and Communication Framework) which may be a useful tool for inspectors to be aware of and share with schools and settings developing their staff in relation to speech, language and communication and SLCN.
We would welcome the inclusion of the word ‘balanced’ within the description of the curriculum requirements.
We are concerned that key points for leadership and management in relation to narrowing the gap are lost within wider judgements about diversity, bullying etc and we would recommend that this is separated to have a clear and specific judgement in its own right.
Across the judgements for effective leadership and management we are concerned over the lack of prominence of any focus on SEND provision or policies. The leadership team is essential in spearheading effective policies across the whole school or setting, including language and SEND policies. The Ofsted ‘Removing barriers to literacy’ report found specifically that “The most effective providers visited had at least one senior member of staff with an excellent knowledge of literacy and its pedagogy. They understood the stages of language development and how and when to provide additional support”[iv]. Similarly, The 2014 Code of Practice is clear that the role of the SENCO will be most effective if they are part of the school leadership team[v].Because of the crucial role of language across all settings, we would welcome reference to a whole setting focus on communication and language development as part of the leadership and management inspection.
We’d also welcome a specific judgement around the role of an effective leadership and management team in relation to SEND provision more broadly.As has already been flagged in this response, the 2014 Children and Families Act and SEND Code of Practice makes it clear that it is the responsibility of school leaders and governors to be actively involved in and have oversight of the school’s arrangements for SENDand to “regularly review how expertise and resources used to address SEN can be used to build the quality of whole-school provision as part of their approach to school improvement”[vi]- this should be clearly reflected in the judgements of any new Ofsted framework.

Q3.Do you agree or disagree with the proposed ‘quality of teaching, learning and assessment’judgement(paragraph 21)?

Strongly agree
/ Agree
/ Neither agree nor disagree / Disagree
/ Strongly disagree
/ Don’t know
X

Comments: