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/ THE NUT’S RESPONSE TO
THE DEPARTMENT FOR EDUCATION CONSULTATION ON SECONDARY SCHOOL ACCOUNTABILITY
APRIL 2013

Introduction

  1. The NUT would welcome a broad debate including professionals, service users and the general public on the accountability of public sector service organisations. The consultation on secondary school accountability does not invite that broader debate. A problem with public sector accountability measures is that they often create a target-driven culture which may at times be at odds with the best interests of service users – in the case of secondary schools, learners and their parents or carers.
  1. The NUT has consistently opposed accountability measures which translate into crude performance tables which rank schools in a ‘league table’ order. It is immensely damaging to schools, teachers and other school staff, and learners themselves where schools are ‘ranked’ lower than others in their area and are labelled as ‘failing’ or ‘inadequate’.
  1. ‘League tables’ of performance based on particular targets can also create perverse incentives to adjust practice to meet the demands of achieving targets as an end in itself, over and above the interests of learners, parents and carers ad the wider community. While the consultation acknowledges some of the perverse incentives that have applied in the past, the fact that there is no departure from a league table and target culture overall runs the risk that a revised system of accountability which merely alters the detail of targets to be achieved will simply introduce its own unintended consequences.
  1. Accountability described in terms of a rank order of performance are also misleadingly presented to the public as enabling parental choices. Many people live in more remote or rural areas which lack the transport infrastructure to make a ‘choice’ of school meaningful. Even in more metropolitan areas with a larger density of school provision and availability of transport, parents and carers might more accurately be described as being able to express a preference for a particular school or schools, rather than exercising a choice, as many learners fail to gain admission to their first choice of school. Within the context of the myth of school ‘choice’, rank orders based on performance against specific targets serve only to demonise particular schools and fuel an unhealthy competition between institutions rather than facilitating improvements to provision overall, or, for example, encouraging collaboration between institutions for mutual benefit.
  1. Schools must collaborate on a wide number of issues in order to meet the best interests of learners, their parents and carers, and the wider community. These include the provision of the broadest range of 14-19 curriculum and qualification choices within an area, working appropriately and effectively on pupil behaviour, meeting appropriately the needs of hard to place pupils, and managing moves for children at risk of exclusion, to name a few. The use of performance tables as an accountability measure has the consequence of placing institutions in competition with each other, and directly undermines a spirit of collaboration and cohesion which could help improve individual, local and national secondary school provision.
  1. The NUT therefore puts forward its observations on the consultation questions as set out within the overall context of opposition to a culture of performance tables and targets.
  1. In making its observations, the NUT notes also the findings of its poll of over 2000 parents, commissioned from YouGov plc in March 2013, which found that when asked who they most trusted to deliver their child’s education other than themselves, 58 per cent of parents trusted teachers, and 59 per cent per cent head teachers, while only 6 per cent trusted the Secretary of State. The NUT believes that the interests of parents and carers, learners, and schools themselves are best met through a dialogue and relationship between schools and homes and families, rather than through the use of crude and potentially misleading ‘accountability’ measures expressed in terms of performance tables. The NUT does not argue that schools should not be held accountable, but it believes that the most effective form of accountability is a direct and democratic accountability to the communities schools serve.

Question 1: Do you agree with the proposals for the headline accountability measures?

  1. The NUT agrees that progress in 8 subjects represents an improvement to some previously existing models, but retains the problems of public sector targets. The decision to broaden attainment measures in such a way as to include subjects outside the EBacc, including vocational qualifications, is however a step in the right direction.
  1. It is not clear why the DfE and Government maintain their opposition to the use of contextual value added data. Without the use of contextual data, it is unlikely that schools with particular intakes that militate against a high proportion of students achieving high results, as the result of socio economic circumstances outside the control of the school, will receive the appropriate credit and recognition for their work.
  1. The proposed progress measure between Key Stages 2 and 4 ignores the fact that pupils’ progress does not follow a simple, linear route in every case. There are a number of factors affecting pupil progress and attainment, many of which are outside the scope and influence of the school itself.
  1. Simplistic statistical information is too crude a measure of institutional effectiveness. However, more detailed information which could contextualise the type of information the DfE is proposing to put forward to parents, carers and the public becomes too complex for individuals to readily make sense of. This is one of the reasons that the NUT continues to believe that performance tables of schools are inappropriate.

Question 2: Is there any further information which we should provide about the performance of disadvantaged pupils?

  1. The NUT agrees strongly that it is “unacceptable” that “poverty remains strongly associated with poor performance” in terms of educational attainment. This needs to be tackled by setting clear aims to reduce child poverty rather than by placing the onus on schools to ameliorate societal problems through a system of ‘naming and shaming’ through league tables.
  1. Disadvantage also needs to be tackled by ensuring that families and parents have access to appropriate services, particularly services for disabled children, for example, as having a disabled child places families at a higher risk of poverty.
  1. The NUT believes that the allocation and use of the Pupil Premium is not transparent, and its support for the restoration of an Education Maintenance Allowance payable directly to learners themselves is well documented.

Question 3: Should we look to use a relative measure as the floor standard in the first year of new exams?

  1. The NUT is opposed to the use of floor standard measures. The consultation recognises that reformed GCSEs will by definition have a new ‘standard’ and that benchmarking data will not be available for the setting of floor standards. The correct response to this should simply to be to eradicate the use of floor standard measures rather than damaging the reputations of schools and learners who are “the worst performing”. In any rank order of performance by definition there must always be a group that are “the worst performing”. Rather than using a ‘relative measure’ in the first year of new exams, the use of floor standards should at the very least be suspended until new qualifications and examinations can be demonstrated to have become established.

Question 4: Are there any other measures we should consider publishing?

  1. The NUT would welcome any encouragement from the DfE and Government for prospective pupils and their parents or carers to visit schools in their locality while making decisions about secondary school places, rather than relying on crude numerical information which is hard to interpret without knowing all the contextualising information about the school and the community it serves.
  1. The NUT continues to believe that the EBacc measure is too narrow and continues to urge its removal. The NUT does not agree that the EBacc represents “the full range of academic subjects”.
  1. The NUT believes also that schools, when serving learners well, do far more than simply deliver a menu of ‘academic subjects’. The NUT would welcome any moves from the DfE, in taking forward its proposals, to emphasise to the public the important work that schools do in terms of preparing pupils for adult life and active citizenship, further study, employment, and in terms of social education and the development of life skills, much of which cannot be readily measured within a league table format.

Question 5: Do you think that we should collect and publish test data from internal assessment through the Data Warehouse?

  1. The NUT disagrees strongly that internal assessment should be collected in this way, as it will run the risk of distorting the nature and practice of such assessment. Firstly, it may lead to an unhelpful ‘standardisation’ of internal assessment to meet the needs of data collection rather than the interests of learning and teaching. Secondly, any data provided in this way would need to be robustly moderated to ensure a consistency of standard of assessment throughout the country.
  1. It is important for schools to provide feedback from assessment to learners and to their parents and carers. This is best done through a dialogue between teachers, their pupils, and the pupils’ parents and carers. To publish such information, even in an anonymised way, risks altering the relationship between schools and the communities they serve.
  1. Parents and carers seeking information about their child’s progress should be encouraged to maintain a constructive dialogue with schools, for example through attendance at parents’ evenings, rather than being encouraged simply to log onto a website to seek numerical information which they may not fully understand without the context that can be explained through meaningful dialogue between the school and homes.
  1. It is unclear to the NUT where the specific benefit would be at key stage 3, as stated in the consultation document. As the document itself states, there is statutory teacher assessment at key stage 3 and this is already reported to parents.

Question 6: What other data could be published to create the right incentives for schools, including special schools, to ensure the best progress and attainment for all their pupils?

  1. The NUT agrees that the achievements of all pupils should be recognised, and that there should be high, but appropriate, expectations of all learners. The NUT believes that incentives to achieve the best for all pupils may be better achieved by the publishing of less, rather than more, numerical data about attainment and achievement, especially where, for example, achievement for a small number of learners may be most meaningful in terms of skills for independent living rather than the attainment of specific qualifications such as GCSE. Such progress is hard to measure numerically, and the individual circumstances of some learners are such that it may not be meaningful to use national averages of attainment or achievement as a comparator for their own progress and achievement.

Question 7: Do you agree that the Department should stop the collection of key stage 3 teacher assessment results?

  1. The NUT agrees that if the DfE proceeds with proposals to remove level descriptors from the National Curriculum – and given the fact that academies and free schools are in any case exempt from the statutory use of the National Curriculum – it would no longer be meaningful to collect attainment data at key stage 3 since there will be no single, national system.

Question 8: How should we ensure that achievement beyond formal qualifications is recognised?

  1. Schools have a variety of methods of communicating to parents the full range of experiences and opportunities made available to learners, including through their own regular communications with learners’ homes, through their websites, through parents’ evenings, through school prospectuses and through school events. The NUT does not believe that such opportunities can or should be reduced to numerical information which can be set out in a table alongside, for example, results achieved through qualifications.
  1. Additionally, the reporting of such information distorts the nature of the opportunities being made available to young people. For example, there could be a perverse incentive for ‘opportunities’ to become more a compulsion than a choice. Additionally, many learners themselves might consider that their activities in school beyond the minimum statutory requirements are private rather than something which needs to be publicly reported.

Question 9: How can national sample tests best be introduced?

  1. The NUT has strong reservations about the proposal to introduce the sample test.
  1. It is important that any such test, if introduced, remains separate from school accountability measures as otherwise they will become simply another ‘high stakes’ test. If introduced, it is likely that schools will need to be given clear guidance on the use of the test in order to avoid any teaching to the test.
  1. More clarity would be welcome on the question of why, when ‘respected’ international comparators such as PISA, PIRLS and TIMMS already exist, the DfE considers it necessary to develop an additional test.
  1. The DFE may be aware that in Wales, the Minister for Education has faced criticism that he misuses PISA data and has become unhelpfully focused on seeking to raise Wales’ ranking in future rounds of the study. The Welsh Government has been criticised also for issuing guidance around PISA which has been interpreted as advocating a teaching to the PISA test.
  1. Similarly the DfE and Government need to be clear that the purpose of tests is to measure performance. Much of the richness of the OECD PISA study is that it enables an assessment of the features of successful education models internationally. It was never intended to be treated as a ‘league table’ ranking of national performance, and a focus on improving national ‘rank order’ would be to misunderstand the fact that it is genuine improvements in provision, including narrowing attainment gaps caused by socio economic inequalities which will improve educational outcomes rather than a narrow focus on improving test scores through practice, coaching, or teaching to the test.
  1. It is important also that any such test is not used cynically as a ‘preparation’ of pupils for studies such as PISA which are intended to give international comparisons, in order to seek to boost a national ‘league table’ ranking in such comparisons.
  1. The NUT has in the past suggested a national sampling model of testing to track the effectiveness of the education service overall rather than retaining whole cohort testing such as that which exists at the end of Key Stage 2. It is likely that the introduction of any new sampling tests will be more welcomed by teachers if they are within the context of lowering the overall burden of assessment. However teachers in key stage 4 will be likely to wish to be assured that any key stage 4 sampling test is not disruptive of teaching and learning, especially where it relates to pupils’ qualifications.
  1. Greater clarity would be welcome also in establishing what means, if any, the DfE will use to ensure that learners are not over assessed. In addition to national sampling tests, some learners may be included also in international samples, and may be required within their schools to sit various internal assessments.
  1. There is little detail on the test provided in the consultation – for example what its content will be, what subjects or areas will be included in the test, how long it will take, or who will mark tests. If teachers are expected to mark tests they will be likely to see it as an additional workload burden.
  1. If a decision is taken to introduce a sampling model, it is vital to include the teaching profession in any detailed discussion around the tests, the purposes for which they are used, and the timing of their administration in order to ensure professional confidence in them.
  1. Since the test will be used to measure educational standards over time it is vital that the Department for Education is able to demonstrate its ability to maintain standards in the sample test itself over time. The public will also need to be reassured that any reporting on national standards in education through the use of such a test is based genuinely on an objective measure and not through the result of the political manipulation of the test or its outcomes.
  1. For these reasons the DfE, if it proceeds with proposals, should introduce a robust procedure to trial and evaluate independently any proposed system of test.
  1. More detail is needed also on the reporting of outcomes. Where pupils are included in the sample, it is likely that they or their parents will wish to know their individual outcome and, potentially that for the school cohort as a whole. It is likely to be difficult to explain to learners and their parents why they may not be aware of their test outcome. Schools, local authorities, academy chains and others may also wish to know the outcomes for individual schools in comparison with others. However, any reporting of individual or school outcomes is likely to undermine the intention of the test being separate from accountability measures aimed at individual schools.
  1. If it is proposed that reporting to the press and public will be at a national level only, consideration needs to be given also to ensuring that the data remains secure and can not be obtained – for example through an FoI request – by the media or others in order to devise a ‘league table’ of performance of individual schools, categories of school, or areas and regions. Were it possible for individuals or organisations to have access to information in order to compile such data, the purpose of the test would be undermined and it would become in reality, if not in intention, a ‘high stakes’ test.

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