Submission: Ofsted's proposed Framework

27 March 2019


Ofsted's proposed Education Inspection Framework


Submission from Challenge Partners

We welcome the opportunity to respond to the proposed new Framework and note that the consultation document invites responses to a limited number of propositions rather than the proposed criteria for inspecting schools. Our response is much wider and we hope that the observations and suggestions we have made will be considered as part of the consultation process.


The overall effectiveness of the school and curriculum focus

We agree that the overriding judgment should rest on ‘what it is like to be a pupil at the school’ in which the teaching, learning and other opportunities provided by the school should feature.


We agree that curriculum – defined in terms of all the learning planned by the school – is the necessary ‘substance of education’ and that the promotion of subject communities is worthwhile. There is some concern across our schools about the lack of subject specialists in the primary phase and the difficulties of recruiting  and retaining teachers in STEM and MFL at the secondary stage, for which schools may be penalised under the new framework.


In judging the standard of education, more emphasis should be given to what learners are gaining: their progress and achievements in the broadest sense, including their personal, social and cultural development, alongside the academic. School effectiveness is also about the school’s vision, aims and values, and the extent to which its work fulfils these.


Given the need for inspectors to be unbiased, we suggest the removal of references to EBacc and urge that the framework and inspectors evaluate curriculum with openness to different approaches so long as they provide a rounded education.


‘Outstanding’ schools            

Although school leaders in our network do not share a common view on inspection judgements, we understand, on balance, Ofsted’s desire to maintain a grading system and recognise high achieving schools. However, we believe that achieving the top grade should be dependent on both outcomes for disadvantaged children (as proposed) and the extent to which schools can prove they are acting systemically to support other schools. If inspection aspires to promote improvement, it should do more to recognise the impact of those schools and organisations that are active agents of improvement. To reflect this emphasis, we suggest the grade is renamed ‘Leading’.


We have always based our work on the goal of ‘upwards convergence’ — the idea that collaborating and spreading our combined knowledge helps all to improve and accelerates improvement most for those with the greatest need. It is important to stimulate the top to rise higher and share their wisdom so that the whole system moves upwards. We do this by establishing learning partnerships, engaging in research, stimulating innovation and through the process of peer review. By stretching the top, a momentum is created with the highest achieving schools driving the system forward. Ofsted could support this drive for upwards convergence in a school-led system by making it a requirement of the top grade that high-performing schools actively seek continuous improvement in themselves and others.


Recognising peer review and collaboration

We suggest that inspection considers evidence of peer review and collaboration with other schools. Peer review is well established in many school networks and MATs, and schools' engagement in it can provide inspectors with evidence of a school’s capacity and willingness to improve themselves and other schools. While we would not want inspectors to look at peer review reports - as knowing they would be looked at in this way would inhibit the powerful openness of peer review - inspectors could ask headteachers what they do to assure quality, who they benchmark themselves against, and what action they are taking as a result.  


One important feature of our network is that partner schools all commit to having an annual peer review led by experienced independent reviewers. Feedback suggests our schools benefit significantly from the rigorous evaluation of the review process, while peer reviewers benefit from working with other schools and leaders, and playing an active role in their development. Evidence for the benefits of the Challenge Partners quality assurance peer review is outlined in an independent evaluation report, Multiple Gains, published by the UCL Institute of Education.  


Supporting the pupils who need it most

We welcome Ofsted’s assertion that schools will not be classed as Outstanding (or Leading) unless they can show disadvantaged children are being supported and are doing well. Challenge Partners runs programmes within and between schools to help the most disadvantaged pupils, with proven success in closing the attainment gap. We suggest Ofsted value not only the  work within schools to help disadvantaged pupils, but also the work many schools do to support other schools to close their attainment gap.

Some Challenge Partners schools are concerned at the duty imposed on school leaders to secure support for SEND pupils if public sector support cannot be accessed. This seems to be a large additional commitment being handed to school leaders to secure specialist support even when public sector help is not available.

Ofsted’s proposal NOT to look at non-statutory internal progress and attainment data

We are concerned that Ofsted's proposal not to look at internal data will disadvantage some schools. For example, at special schools pupils may arrive and leave below expected standards so schools would like their own assessments and evidence of added value to be considered, which may never be captured in official data.

Schools have spent a great deal of time investing in systems to monitor the progress of their pupils over time. Indeed, in Special Schools and AP settings use of internal data is an important tool to measure not just academic but social and emotional development and progress. Inspectors need to have regard to schools wanting to share internal data that is relevant to their improvement journey.

There is a concern among some of our school leaders that a greater focus on work scrutiny will affect workload by encouraging a return to written feedback, which many schools have moved away from (without compromising progress or outcomes). Expectations around being able to review written work are also out of step with a school environment that is increasingly digitised. Inspectors should be open to gathering evidence of progress and attainment from a range of sources, including online platforms and students themselves.

We would welcome Ofsted returning to an intelligent focus on pupil outcomes over a period of time as opposed to the latest set of national test and examination results.

Leadership and management

This section is quite inward looking and reads more like an audit tool in parts. It focuses more on the management of schools as opposed to leadership. Ofsted could also spell out the value of leaders being catalysts for change, dealing with the unknown and being innovative.

We would welcome recognition in the framework for schools who are acting systemically and supporting other schools. The EIF reflects little of the developments in school-to-school support and collaboration both before and after 2010.

Where schools can show that they are using and acting on peer quality assurance review, it is good evidence of effective leadership and management.

Personal development

We support the idea of splitting personal development judgements from attitudes and behaviour, and believe it offers an opportunity to acknowledge the personal development work undertaken in many schools. The soft skills of pupils are also important so how that is articulated and what that looks like in a classroom is an important element of what is really happening in the school.

S5 and S8 Inspections

The EIF proposes to precede the inspection with a half-day on-site preparation visit. Ofsted should regard this as the beginning of the inspection, because schools will. We are opposed to this return to what is, in essence, a no-notice inspection, particularly because the peer collaboration and challenge our leaders engage in means that they may not be on site when inspectors arrive.

We also question the purpose and value for money of lengthening ‘short’ inspections. There is little reason why section 8 inspections, particularly of primary schools, cannot be completed in 1.5 days if the first half day is used constructively for interviewing a cross-section of leaders. Contributory cost savings would accrue from reduction in the HMI resource needed.

Ofsted’s research

We recognise the steps taken to have regard for inspection and research evidence in formulating the inspection criteria and the efforts made to set out what is and is not expected from schools and inspectors. But in its attempts to ensure consistency of inspection and cover the minutiae of school practice, the Framework has become unwieldy and tends to de-professionalise inspection.

The research overview used to develop the framework is entirely mainstream-based and includes no research base for those with SEND. In an inclusive education system, we would expect to see research used that reflect the whole system, as opposed to parts of the system.

Re-professionalising inspection

Schools need confidence in the judgements being made and so the inspection system needs to ensure lead inspectors are experienced, trusted professionals, to give schools greater assurance about their reliability. We therefore argue that lead inspectors should always be fully trained, inducted and experienced practitioners or HMI, who are expected-and recognised to be inspection professionals.

Running counter to the idea of a professional inspectorate, the EIF draft handbook is becoming more and more of an audit tool, trying to secure quality of judgement through a battery of criteria, do’s and don’ts. In some cases it struggles not to be contradictory. For example, the admonition that ‘inspectors will not take a random sample of lesson observations’ precludes a walk through classes which can give the inspector an indication of a key characteristic of good schools: consistency. Later (274) inspectors are told that on s8 inspections they will ‘always observe a sample of lessons’. If lesson observations are not going to be a random sample but 'relevant to the focus of the inspection' the inspection trails could skew the evidence, particularly in weaker schools.

Inspection is a professional judgment which has to be evidence based. It needs a suitably qualified person to take responsibility for making, evidencing and justifying inspection judgements. We believe Ofsted must have the best professional inspectors (whether HMI or suitably trained and qualified practitioners) to lead inspections and make what are often nuanced judgements. This will be particularly important in making the curriculum-related judgements required in the EIF and giving appropriate weight to the determinants of overall school effectiveness.