Dear Ms Spielman,
Many headteachers believe that our education system stands at a crossroads. School leaders face huge challenges in relation to teacher supply, school funding and designing and delivering a curricular and pastoral provision that meets the complex and diverse needs of the schools, families and children that we serve.
We acknowledge Ofsted’s aim to develop an inspection framework with a greater emphasis on a child’s curriculum, to complement performance tables. However, following consultation with a wide range of colleagues, the Headteachers’ Roundtable and ‘Worth Less?’ have significant concerns about the proposals put forward.
The retention of a four point grading system is hugely problematic. The absence of any independent empirical evidence base for the reliability of the grades produced and the validity of conclusions reached, fundamentally undermine the proposals presented by Ofsted. These concerns have not been satisfactorily addressed in the past 25 years. The impact of the grading system on schools serving the most challenging areas is causing more teachers to leave the profession or move from these schools. Long standing concerns about inspection outcomes being dependent on a school’s intake rather than its effectiveness and which inspectors walk through the door have simply not been addressed. This is an inconvenient truth that needs acknowledging and properly addressing.
Many headteachers assert that our flawed and bloated accountability system is at the root of the workload issue. The current retention and recruitment challenges are in part driven by teachers’ and school leaders’ excessive workload. The new inspection framework will not address this and may well exacerbate the situation. Given this, Ofsted holding school leaders’ to account for workload issues we do not have control over is untenable. Parents’ expectations that their child is taught by a well-qualified and capable teacher are likely to be further undermined as workload and consequentially teacher shortages increase.
Funding plays a crucial element in the capacity of any school to deliver high quality provision. Headteachers agree that real terms cuts have had a profoundly negative effect on our schools. The lack and uneven funding of schools, whilst maintaining a common standard for all to reach, lacks a fundamental logic and basic fairness. Ofsted need to develop systems to assess these issues and also consider the impact of ongoing funding disparities that have been maintained under the new National Funding Formula.
The guidance on the curriculum is frequently confused and contradictory. This may well lead to unintended consequences relating to workload and/or inconsistent judgements. Support for certain curricula, within the inspection handbook, in particular the proposed implementation of the Ebacc, shows a lack of independence by the inspectorate and no evidential base. The Ebacc and new content heavy GCSE syllabi are limiting the range and balance of subjects studied and the completion of GCSE in two years; there is no recognition of this in the draft inspection framework or handbook.
Whilst the inspection handbook refers to a broad curriculum or broad range of subjects on nine separate occasions only once does it refer to a balanced curriculum. The support for the aesthetic aspect of the curriculum and the creative arts will be further undermined if this framework is implemented.
The extent to which a school’s data – especially outcomes arising from external examinations – determines key judgments remains uncertain. Any new framework must provide far greater clarity on how significant data arising from assessments, attendance, exclusions and the like are considered. Headteachers recognise the importance of such statistical measures, but know too that any such data is frequently influenced by a variety of contextual factors. For far too long, schools have been held accountable for statistical indicators that include substantive and important variables over which a school has limited or no control: the lack of STEM and Modern Foreign Language teachers to deliver the Ebacc or the level of deprivation or ethnicity of their intake.
With respect to all key stages, the needs of pupils whose attainment is significantly behind their peers or who have SEND was limited; in the SEND appendix, for example, SEMH is not mentioned as a category of need. A greater focus, for these pupils, on ensuring the basics for future success at school takes additional time and support. There appears to be little understanding of these matters in the current framework. Schools with more disadvantaged intakes, where attainment on entry is lowest and pupils have furthest to travel to the expected standard may need to prioritise English and Mathematics.
With respect to inspection of primary schools, recent Ofsted documents (Primary Science) suggest substantial curriculum changes are required. The preferred curriculum is one that is more rigorous and vertically integrated than is currently the case outside of the core subjects of Mathematics and English. There are considerable implications for this at a practical level – employment of teachers, their professional development and processes for curriculum development – which many school leaders and governors may not yet fully appreciate. The consequential reduction in curriculum coherence needs to be given greater consideration; for example, in the area of reading where related knowledge plays a significant part in comprehension and understanding.
Far greater work is required on how effective school leadership is scrutinised and judged. There seems little practical wisdom, based upon the expertise gained through experience, about the complexity of leading schools. Some of the terms used are unnecessarily pejorative and will almost certainly lead to inconsistent judgements, magnified through inspection reports, with unforeseen consequences. Permanently excluding a pupil so s/he is then educated in Alternative Provision is seen as strong leadership with respect to behaviour. However, a pupil who has a managed move into Alternative Provision leads to concerns about off-rolling and gaming of accountability measures.
A new inspection process must be far more collaborative, thorough and nuanced. This can only come about if schools themselves are much more engaged with the process of inspection and evaluation. Peer to peer scrutiny validated by external inspection would support ongoing school improvement much more than an infrequent ‘snapshot‘ approach.
Ofsted’s laudable aspiration to develop an inspection system that is intelligent, responsible and focused, in order to be a force for improvement, is not well served by the current draft proposals. We are concerned that the timescales, currently being proposed by Ofsted, gives little or no time for considered and deep reflection and revisions before implementation in September 2019. School leaders are already being asked many questions, aligned with the new framework. It would seem eminently more sensible to evolve the current framework rather than imposing another significant change on an already fragile school system.
We hope, therefore, that you will take on board our views and meet with representatives to further develop a finalised Framework that ensures rigorous and reliable external scrutiny is matched to an inspection system that is trusted and valued by every stakeholder.
Stephen Tierney Jules White
Headteacher’s Roundtable ‘Worth Less?’
Headteachers’ Roundtable and ‘Worth Less?’ are grassroots organisations. They provide an important mechanism to represent the opinions of those professionals who have to deliver on the aspirations and strategic intent of the Department for Education and Ofsted. Our collective views are designed to complement the work of our professional associations and other influential contributors.