Consultation closing date: 18 December 2015
Your comments must reach us by that date
Intervening in failing, underperforming and coasting schools
If you would prefer to respond online to this consultation please use the following link:
Information provided in response to this consultation, including personal information, may be subject to publication or disclosure in accordance with the access to information regimes, primarily the Freedom of Information Act 2000 and the Data Protection Act 1998.
If you want all, or any part, of your response to be treated as confidential, please explain why you consider it to be confidential.
If a request for disclosure of the information you have provided is received, your explanation about why you consider it to be confidential will be taken into account, but no assurance can be given that confidentiality can be maintained. An automatic confidentiality disclaimer generated by your IT system will not, of itself, be regarded as binding on the Department.
The Department will process your personal data (name and address and any other identifying material) in accordance with the Data Protection Act 1998, and in the majority of circumstances, this will mean that your personal data will not be disclosed to third parties.
/ Please tick if you want us to keep your response confidential./ Reason for confidentiality:
/ Name:
/ Please tick if you are responding on behalf of your organisation.
/ Name of Organisation (if applicable):
/ Address:
If your enquiry is related to the DfE e-consultation website or the consultation process in general, you can contact the Ministerial and Public Communications Division by email: or by telephone: 0370 000 2288 or via the Department's 'Contact Us' page.
Please insert an 'x' into one of the following boxes which best describes you as a respondent.
/ Local authority / / X
/ Teacher /
/ Parent or carer
/ Headteacher or school leader /
/ Governor /
/ National representative body
/ Pupil /
/ Other (please specify)
/ Comments:
I am a teacher in a primary/secondary/special/16-19/early years school/setting/college/
I am a Head Teacher/School Leader etc….
I have taught for 00 years. I am a specialist in …..I am a head of department in ……Iam a SENCO etc.
I am incensed about the proposals set out in this consultation. I hope you will take my views seriously.
If you indicated that you are a teacher, headteacher, school leader or governor, please indicate what type of school
/ Local authority maintained school /
/ Academy school or academy chain /
/ College, FE or HE institution
/ Special school /
/ Alternative provision or pupil referral unit (PRU) /
/ Other (please specify)
/ Comments:
- Do you think the revised Schools Causing Concern guidance describes clearly the powers, processes and responsibilities for intervening in underperforming maintained schools? Please specify any elements you think require further clarification.
/ Yes / / X
/ No /
/ Not Sure
/ Comments:
The guidance fails to address the impact on the morale of the teaching profession of the proposals in the Education and Adoption Bill and the guidance itself. Labelling schools as ‘failing’ ‘coasting’ and ‘underperforming’ is both counter-productive and unnecessary. If I found myself, as a teacher, in a school defined in one of these ways I would feel undermined and demoralised. These new incendiary categories will not be effective interventions to improve teaching or learning. The profession already faces intense challenges over funding, recruitment and retention and low teacher morale. These proposals will only make things worse.
- Chapter 3 of the Schools Causing Concern guidance proposes how RSCs should make decisions about what action should be taken in schools that meet the coasting definition. Do you think that the described approach and process is appropriate?
/ Yes / / X
/ No /
/ Not Sure
/ Comments:
There is nothing to be gained by labels such as ‘coasting’. If my school were labelled in this way I would feel very angry because I know how hard myself and my colleagues work within the constraints of funding, class size and pupil deprivation. The idea that an unaccountable RSC can use their own ‘discretion’ to decide whether my school has a ‘sufficient plan or capacity to improve’, whether we might need ‘additional support and challenge’ or whether s/he might simply ‘intervene’ without really knowing or understanding the specific circumstances of our school, its pupils or its context is shocking.School improvement won’t be brought about by alienating teachers and labelling schools.
- Chapter 3 explains that RSCs could use their discretion to decide not to intervene where a coasting school is supporting its pupils well, but has fallen within the coasting definition because of its circumstances or pupil characteristics. Do you agree that this is appropriate? The guidance is not intended to be exhaustive, but please specify if there are other such circumstances or factors you think should be mentioned in the guidance that currently are not.
/ X
/ Yes /
/ No /
/ Not Sure
/ Comments:
Whilst I agree that RSCs should use discretion and not intervene where a school is supporting its pupils well, I do not have confidence that this is likely to happen. This provision is fatally compromised by the extensive powers given to RSCs to intervene in so-called ‘underperforming’ schools (see my answer to question 4 on this) and by the political statements made by Ministers about wanting all schools to become academies.
- Chapter 4 describes what may constitute low standards of performance and what factors local authorities and RSCs may take into consideration to identify this, for the purpose of issuing a performance standards and safety warning notice. Do you agree with the factors listed which may indicate that a warning notice may be necessary?
/ Yes / / X
/ No /
/ Not Sure
/ Comments:
The factors which the RSC may use to identify an ‘underperforming’ school are too many and too open ended. They include, for example, ‘a sudden drop in performance’, which,as any teacher will tell you, may be a legitimate and explicable development because of variations between cohorts year on year. They rest on the assumption that all children nationally should be able to attain at the same standard and make the same amount of progress. This is simplistic and fails to recognise the hard work that schools and their teachers put into supporting their pupils, often in very challenging circumstances.
The guidance makes clear that RSCs will be expected to issue a warning notice and to do so quickly in schools that they decide are underperforming. Governors will have no chance to appeal against a warning notice under the Education and Adoption Bill. Once a warning notice is issued, RSCs will have extensive powers of intervention which could include issuing an academy order. The Secretary of State could even order the school to close.
Teachers I have spoken to in my school are appalled by these proposals.
- Chapter 5 describes the specific powers of local authorities and RSCs (using the powers of the Secretary of State) in schools eligible for intervention. Are the respective responsibilities, and the interactions between the local authority and RSC powers, sufficiently clear?
/ Yes / / X
/ No /
/ Not Sure
/ Comments:
Most local authorities (LAs) know their schools well and understand the context in which they operate. The jurisdiction of LAs is genuinely local whereas RSCs operate over a huge Region with incoherent geographical boundaries. LAs are better placed to determine whether a local school is providing its pupils with the standard of education they are entitled to, and whether or not a school’s response to a warning notice is adequate.
Chapter 5 makes clear that the powers of democratically elected LAs are being substantially weakened and that in turn the powers of unaccountable and unelected RSCs acting on behalf of the Secretary of State are being hugely strengthened. It makes apparent that, where there is disagreement between the LA and the RSC over the issuing of a warning notice or the attitude to take to the school’s response, the views of the RSC will take precedence over those of the LA.
I believe that the powers being given to RSCs to intervene in maintained schools are too great. Originally RSCs were established to oversee academies and free schools, not maintained schools. There is no good reason why RSCs should take over the powers currently exercised by LAs, who are in a far better position to understand schools in their area. There is certainly no justification for them to have authority to override decisions taken by LAs, as this guidance makes clear they will be able to.
- Do you have any other comments on the revised Schools Causing Concern guidance?
/ Comments:
The guidance has virtually nothing to say about school improvement. Instead it seeks to label schools in a way that is punitive, divisive, arbitrary and unfair. It will demoralise teachers and worsen an already serious teacher recruitment and retention situation.
In an effort to avoid the ‘failing’, ‘coasting’ and ‘underperforming’ labels, schools are likely to implement policies that will increase teachers’ already unmanageable workloads. Schools are also likely to increase the focus on those subjects which feature in attainment and progress measures, meaning that children will be further taught to the test in a way that undermines their right to a broad and balanced curriculum. Schools in England are already in danger of becoming exam factories. These proposals will make things worse.
- Do you agree that the three principles (explored in paragraphs 16-20) underlying our coasting definition are the right ones?
/ Yes / / X
/ No /
/ Not Sure
/ Comments:
The ‘coasting’ definition is based on highly subjective expectations about how much attainment and progress children should make. Education is much more complicated than that. Schools full of hard working teachers, and their pupils, will be deeply offended by this label. Teachers are committed to ensuring that all children achieve the best possible outcomes and life chances. We work extremely hard, often at the expense of our own family and social lives, and we deserve respect. We expect accountability measures to be credible, constructive and realistic.
Teachers in a school labelled as ‘coasting’ will feel equally labelled by implication.Teachers will be incredulous that the Government intends to label professionals working 60-70 hours a week as ‘coasting’ teachers. The Government seems not to have noticed that there is a teacher recruitment and retention problem and that labelling schools in this way will only make things worse. It’s time the Government treated teachers as professionals and sat down with us to discuss real measures to support schools to bring about the consistently effective learning and good outcomes we all want for all pupils.
- Should the definition of a coasting school be where data shows that, over a three year period, the school is failing to ensure that pupils reach their full potential?
/ Yes / / X
/ No /
/ Not Sure
/ Comments:
Schools should be judged on the quality of education overall that they provide, not just on a narrow range of data measures over an unrealistically short time period.
Data does not define a school. Data alone cannot determine that a ‘school is failing to ensure that pupils reach their full potential’. Data cannot demonstrate the quality of teaching nor the full and rounded education that pupils receive. ‘Coasting’ is a meaningless and counter-productive label and there is no evidence to suggest that it will improve pupil outcomes or enhance school effectiveness.
9a) Should the proposed interim definition for coasting in 2014 and 2015 be based on
the accountability measures for those years, against which schools were held to
account?
/ Yes /
/ No / / X
/ Not Sure
9b) If so, are the thresholds right? Alternatively should the new 2016 accountability
measures be applied retrospectively for 2014 and 2015?
I do not accept the coasting label and so reject the thresholds set out in both 9a and 9b above.
10a) Should coasting standards be applied to special schools?
/ Yes / / X
/ No /
/ Not Sure
10b) Can this be data driven – if so, what metric could be used? What other indicators
might be used?
The coasting label should not be applied to any school. It should certainly not be applied to special schools. Special schools educate children with a wide range of special educational needs. It is the quality of the education in the round that they provide that should be considered, not the test scores of pupils.
11a) Should coasting standards be applied to Pupil Referral Units?
/ Yes / / X
/ No /
/ Not Sure
11b) Can this be data driven – if so, what metric could be used? What other indicators
might be used?
The coasting label should not be applied to any school. It should certainly not be applied to pupil referral units (PRUs). PRUs educate children with a wide range of behavioural and other special educational needs. Children do not spend their entire school life in a PRU, the aim should be their reintegration into mainstream schooling. Therefore it would not be right to judge schools by their pupils’ performance and progress during what may be a difficult and short period of their school life. It is the quality of the education in the round that PRUs provide that should be considered, not the test or progress scores of their pupils.
12a) Is our proposed approach for schools that chose to opt in early to Progress 8 in
2015 – that the more favourable of the two coasting definitions be applied – the
right one?
/ Yes /
/ No / / X
/ Not Sure
12b) If not, what is the fairest way of defining coasting for these schools in 2015 and
why?
I do not accept the coasting label and so reject the thresholds set out in both 12a and 12b above.
Thank you for taking the time to let us have your views. We do not intend to acknowledge individual responses unless you place an 'X' in the box below.
/ Please acknowledge this reply./ X
/ Email address for acknowledgement:
Here at the Department for Education we carry out our research on many different topics and consultations. As your views are valuable to us, please confirm below if you would be willing to be contacted again from time to time either for research or to send through consultation documents?
/ X/ Yes /
/ No
All DfE public consultations are required to meetthe Cabinet Office Principles on Consultation
The key Consultation Principles are:
- departments will follow a range of timescales rather than defaulting to a 12-week period, particularly where extensive engagement has occurred before
- departments will need to give more thought to how they engage with and use real discussion with affected parties and experts as well as the expertise of civil service learning to make well informed decisions
- departments should explain what responses they have received and how these have been used in formulating policy
- consultation should be ‘digital by default’, but other forms should be used where these are needed to reach the groups affected by a policy
- the principles of the Compact between government and the voluntary and community sector will continue to be respected.
If you have any comments on how DfE consultations are conducted, please email:
Thank you for taking time to respond to this consultation.
Completed responses should be sent to the address shown below by 18 December 2015.
Send by post to:
Nathan Hug
System Reform Group, 3rd floor
Department for Education
Great Smith Street
London, SW1P 3BTSend by email to: