Consultation Response Form
Consultation closing date: 16 April 2013
Your comments must reach us by that date.

Reform of the National Curriculum in England

Consultation Response Form

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Name / Rory Cobb
Organisation (if applicable) / Royal National Institute of Blind People
Address: / 56-72 John Bright Street
Birmingham
B1 1BN

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Please tick one category that best describes you as a respondent

/ Primary School / / Secondary School / / SpecialSchool
/ Organisation representing school teachers / / Subject Association / / Parent
/ Young Person / / Higher Education / / Further Education
/ Academy / / Employer/Business Sector / / Local Authority
/ Teacher / X / Other
/ Please Specify:
Royal National Institute of Blind People (RNIB) is the largest organisation working with blind and partially sighted people in the UK. We work closely with specialist teachers and support services in local education authorities and health authorities, and undertake policy, research and training activities regarding the development and learning of all children who are blind or partially sighted, including those with additional and complex needs.
Vision impairment, which includes both blindness and partial sight, is a low incidence impairment. Based on research carried out for RNIB it is estimated that there are just over18,000 children in England between the ages of five and 16 with a vision impairment of sufficient severity to require specialist support. Approximately 50 percent of these children have a single impairment, while the remainder have additional SEN including a substantial proportion with complex needs. Out of all pupils with a vision impairment around 5 percent read and write through braille.

Are you answering this consultation in response to particular subjects? Please tick all those that apply.

/ English / / mathematics / / science
/ art & design / / citizenship / / computing
/ design & technology / / geography / / history
/ languages / / music / / physical education
X / Not applicable

1 Do you have any comments on the proposed aims for the National Curriculum as a whole as set out in the framework document?

Comments:
RNIB notes that the wider aims of the National Curriculum are listed in 6.2 of the ‘Reform’ document as follows:
  • promotes the spiritual, moral, cultural, mental and physical development of pupils at the school and of society, and
  • prepares pupils at the school for the opportunities, responsibilities and experiences of later life.
However, these do not appear as aims in the ‘Framework’ document and we question whether 3.1 and 3.2 here are aims at all – they are simply factual statements setting out what the National Curriculum is and focus exclusively on ‘core knowledge’. We believe the National Curriculum should cover more than knowledge and should also include skills and understanding. Starting from a narrow interpretation of its purpose inevitably constrains the scope of what follows.
The statement that ‘there is time and space….to range beyond the National Curriculum specifications’ overlooks the fact that many children with SEND require a specialist curriculum which addresses their individual needs. Many children with vision impairment need to learn disability specific skills such as braille, habilitation and independence skills, which are essential if they are to be adequately prepared for the responsibilities, opportunities and experiences of later life. The time available is already too tight to include this specialist curriculum alongside the National Curriculum and it would be a mistake to assume that it can expand to include yet more activity.
We also query how ‘coherence across the school system’ (6.1 in Reform document) can be achieved when academies and free schools are free to opt out of the National Curriculum. We believe a ‘National Curriculum ‘ should apply to all maintained schools and that a failure to insist on this will undermine the continuity and progression that is so important to children’s education.

2 Do you agree that instead of detailed subject-level aims we should free teachers to shape their own curriculum aims based on the content in the programmes of study?

/ Agree / X / Disagree / / Not sure
/ Comments:
RNIB believes that flexibility is essential not just at school/classroom level but at the level of each individual to ensure that children are offered a curriculum which is relevant to their identified needs.However, we do not believe it is in children’s best interests for the curriculum to be defined as it is here, primarily in terms of content with just a few overarching aims. We are concerned that an increased emphasis on subject content may lead to pressure on teachers to become purveyors of knowledge rather than teachers of skills and understanding. There is also a danger that an increased emphasis on what children know rather than how they learn may reduce opportunities for children to learn independently and through direct experience.
One of the key benefits of a National Curriculum is that it establishes the principle of an entitlement shared by all children, including those with SEN and disabilities.RNIB believes that this entitlement to a broad and balanced curriculum needs to be protected and that schools should not be given complete freedom to choose what to teach, especially in a context where their access to specialist advisory services may increasingly be influenced by cost considerations. The danger is that this may narrow the curriculum offered to pupils with such specialist needs. In particular, it is essential that teachers are encouraged to hold high expectations of pupils with vision impairment, which they will only be able to do if they understand the implications of learning without sight and are taught appropriate strategies for addressing these. The importance of good teacher training cannot be overstated.

3 Do you have any comments on the content set out in the draft programmes of study?

/ Comments:
RNIB is concerned that the draft programmes of study vary greatly in approach, with considerable detail provided for the core subjects and very little for the remaining foundation subjects. We believe a balance needs to be struck between these two extremes so that teachers of all subjects find the programmes of study helpful without being prescriptive.
The KS1 programme of study for English is particularly detailed in setting out expectations for the teaching of literacy. RNIB wrote a detailed response to the 2011 consultation on the Year 1 Phonics Screening Check, pointing out the potential difficulties which young blind children learning literacy through braille could face with a phonics-based approach and the danger that they could underperform unless the check was suitably modified to take account of the differences between learning literacy through print and braille. We attach that response again here as the points made are still relevant.
While RNIB supports the need for greater rigour in the teaching of spelling, grammar and punctuation we are keen to avoid a situation where this takes undue precedence in the curriculum. We note the point made in the ‘reading’ section of the introduction to the English programme of study that ‘good comprehension draws from linguistic knowledge (in particular of vocabulary and grammar) and on knowledge of the world’. Many children with severe vision impairment have limited experience of the world because they lack opportunities for incidental learning through observation. It is essential that the curriculum provides these children with real opportunities to learn about the world in a hands-on and meaningful way, and that this aspect of their learning is not restricted in favour of an undue emphasis on the mechanics of literacy.

4 Does the content set out in the draft programmes of study represent a sufficiently ambitious level of challenge for pupils at each key stage?

/ Sufficiently ambitious / / Not sufficiently ambitious / X / Not sure
/ Comments:
Different subjects present different challenges in terms of providing equal and meaningful access to blind and partially sighted children. RNIB's view is that no subject should be considered unsuitable for blind or partially sighted children on the basis that it may be deemed too visual, or for Health and Safety reasons too dangerous, but the specific curriculum made available to an individual child should be designed to take account of their own needs, strengths and weaknesses.
RNIB believes that the National Curriculum needs to provide more opportunities for children with vision impairment to learn disability specific skills in areas such as social interaction, mobility, braille and assistive technology. Research supports the view that good mobility and social skills are essential to obtaining employment for individuals with vision impairment, regardless of their academic attainment. Yet pressure of time within the school day frequently involves juggling the competing priorities of these specialist activities with the demands of National Curriculum subjects.These skills should therefore be recognised as a central part of children's curriculum entitlement, and progress and attainment in them should be recognised as valid outcomes in their own right. It should not simply be assumed that they are a means to an end, of value only in supporting access to the 'proper' curriculum.

5 Do you have any comments on the proposed wording of the attainment targets?

/ Comments:
RNIB is concerned that the proposed wording of the attainment targets is too simplistic and could easily lead to a pass/fail mentality among both teachers and pupils. While this approach may encourage more able pupils to aspire to reach higher standards, it will be at the expense of many others who will be continually reminded that they are falling short.
We do not agree that the existing level descriptions are too abstract and we believe that focusing the attainment targets so much on subject knowledge will make it difficult to recognise the real progress made by pupils with SEN who may learn in less conventional ways.

6 Do you agree that the draft programmes of study provide for effective progression between the key stages?

/ Agree / / Disagree / X / Not sure
/ Comments:
RNIB believes that pupils' interests would be better served by studying fewer subjects during primary education, particularly in KS1; and that aspects of the EYFS should be extended into the primary curriculum, such as placing emphasis on the full range of areas of learning and development currently contained in the EYFS, including personal, social and emotional development, and widening the curriculum opportunities for child initiated, play based activity. We believe that this is the right approach for all children, but particularly those children whose development may be at risk due to a disability such as vision impairment. These children would benefit from having a longer period to embed the knowledge, skills and attitudes of the EYFS through play into KS1. RNIB believes that the new National Curriculum should build on the recommendations in Dame Clare Tickell's review of the EYFS, particularly the concept of 'school unreadiness'.

7 Do you agree that we should change the subject information and communication technology to computing, to reflect the content of the new programmes of study?

/ Agree / / Disagree / X / Not sure
/ Comments:
RNIB understands the reasons for changing the name of the subject to computing and for the significant change in the subject content. The development of new technology in recent years has opened many opportunities for disabled people and pupils with vision impairment are often skilled users of assistive and mainstream technology. A key problem with the current ICT curriculum is that it assumes the use of standard visually based software applications and is not easily adapted to more specialist access methods such as screen readers. RNIB seeks reassurance that the new computing subject will be more flexible and that pupils with vision impairment will be able to demonstrate and gain credit for the specialist skills that many of them possess.

8 Does the new National Curriculum embody an expectation of higher standards for all children?

/ Yes / X / No / / Not sure
/ Comments:
While visual impairment itself is not a barrier to attainment, around 50% of children and young people with visual impairment have additional or complex needs and it appears from these proposals that the interests of these learners are being overlooked in the pursuit of traditional academic standards. International comparisons are obviously important but must not be used as a justification for developing a National Curriculum which is geared to the interests of an academic minority at the expense of other learners.
We are pleased to see a commitment to including all children’s progress in schools’ accountability measures and a recognition that this needs to include children who do not gain recognised qualifications. Individual progress is more important for many SEN pupils than being measured against fixed attainment standards. In a low incidence area such as vision impairment it is also important that individual progress and attainment can be measured against other children with the same disability and not just against fully sighted children.

9 What impact - either positive or negative - will our proposals have on the 'protected characteristic' groups?

/ Comments:
RNIB believes the underlying philosophy behind the proposed National Curriculum is flawed because it assumes that the majority of children are 'typical' learners whose learning can be predetermined as a hierarchy of levels of knowledge, skills and understanding. In reality, all learners have individual needs and the curriculum should be built on universal design principles from the outset. Many children with vision impairment learn in a highly individualised manner and do not follow a pre-determined linear learning pathway. If the pace of the curriculum is too fast, there will be too little time for them to consolidate their learning before being moved on to new work.
The effects of vision impairment on learning are complex. For sighted children, skills relying on vision are often more readily achieved than those that use hearing or touch. For example, reaching for an object that has been perceived visually is a skill that is simpler and acquired at an earlier age than reaching for an object on sound cues alone. Knowledge, skills and understanding which sighted children acquire incidentally by visual observation need to be taught explicitly to children who cannot see.
Depending upon the degree and nature of their vision impairment, a pupil may use non-sighted or sighted methods, or a combination of both, to access the curriculum. Examples of non-sighted methods are braille, audio-tape, and computer with speech software. Sighted methods include enlarged or modified print, low vision devices such as magnifiers and computers with large screen monitor and/or enlarged text on screen. Some environmental adaptations may also be necessary, for example increasing or decreasing the level of illumination in the pupil’s work space. The class or subject teacher plays a crucial role in ensuring that the range of strategies or approaches used enables a pupil with vision impairment to be fully included in the class.
Around half of children with vision impairment have additional SEND. There is considerable evidence that these children are especially vulnerable to poor educational and wellbeing outcomes. A high proportion of children who have severe or profound and multiple learning difficulties also have a significant vision impairment. The impact of poor sight has a compounding effect on their other disabilities. The difference between the chronological and developmental ages of children who have this complex combination of needs increases as they get older. Typically they have a developmental level that is expressed in months rather than years and their development is very, very slow.
The development of children with vision impairment and complex needs is not linear and is not typical of that of "normally" developing children. Children may acquire skills that are developmentally out of synchrony with other skills. Similarly they may require a great deal of practice to allow skills gained in one setting or with one set of materials to be generalised to a different setting or to a different set of materials.
The picture presented above is one of small numbers of children with a wide range of needs, most of whom are educated in settings which do not specialise in vision impairment. Whatever the shape and structure of the National Curriculum, it is imperative that the teachers who are responsible for teaching these children have regular access to qualified teachers of children with vision impairment who can advise them on how to present learning opportunities and resources in ways which will maximise their chances of making progress.
For all these reasons RNIB believes the National Curriculum proposals fall short of guaranteeing children with vision impairment an education which is relevant and responsive to their individual needs. We suggest that the statement in para 9.4 of the Reform document about ‘enabling’ schools to make reasonable adjustments should be strengthened to ‘requiring’ as this is a legal duty under the Equality Act. It is particularly important to emphasise schools’ own responsibilities in a context where the resources of the Equality and Human Rights Commission have been reduced
We are also concerned that the proposed inclusion statement (section 4 in the Framework document) is simply set out as a series of high level statements which sit alongside the subject orders but do not engage with them at a practical level. We do not believe that a passing reference to the forthcoming new SEN Code of Practice is sufficient to safeguard the needs of SEN pupils when the SEN framework itself is being significantly revised.

10 To what extent will the new National Curriculum make clear to parents what their children should be learning at each stage of their education?