Yes, but… A personal response to the Ofsted consultation

Ofsted are consulting on a new framework for the inspection of maintained schools, academies, further education and skills providers, non-association independent schools and registered early years settings.

This is a personal response to the three main proposals. Please read that disclaimer again! It is a personal response that is not in any way intended to represent the views of any employer of mine – past, present or future. And my response in general is “Yes, but…”

The closing date for the consultation is 5 December 2014.

Please be consulted too.


Q1. Do you agree or disagree with the introduction of a new common inspection framework for maintained schools, academies, further education and skills providers, non-association independent schools and registered early years settings from September 2015?

Yes, but…

Yes, it makes sense to me that similar provision should be inspected under the same framework. 16-18 year-olds in a school sixth form, a sixth form college or a General Further Education (GFE) college are all still receiving provision for 16-18 year-olds. You should be able to compare easily the provision they receive.

Yes, having one framework that can capture the provision in one institution seems a sensible, simplified and consistent way to judge provision. Many schools have 11-16 and 16-18 provision. GFEs have Early Years, 14-19, 19+ and most variations thereof.

Yes, therefore, if we can devise a framework that works for all, let’s do it.


But, a common framework to judge and compare different provision only provides accurate comparisons if all of that provision is operating on a level playing field. If we are to have a common framework, then we also need our equivalent of football’s Financial Fair Play (FFP) to make those judgements reasonable and equitable.

The Association of Colleges (AoC) is starting to talk about “Catch-22”, the fact that a 16 year-old attracts 22% less EFA funding than a 15 year-old. An 18 or 19 year-old in a college attracts even less than this. And this reduction in funding occurs at an age when provision becomes much more expensive.

Most non-selective schools are dealing with a bell-shaped curve of ability ranges and a spread of relatively non-resource intensive provision. FE Colleges are delivering on balance a more vocational, resource-intensive provision (in terms of capital equipment, consumables, and the lower class sizes required for workshop facilities to be healthy and safe). They are also putting in place extra teaching and pastoral support costs to deal with learners who have failed or been failed in the 11-16 system.

And of course, by the time a full-time 18 year-old moves from FE into HE, the amount of money they bring into their institution can more than double.

So, yes, let’s have a common inspection framework, but only with Financial Fair Play alongside it.

Q6. Do you agree or disagree with the specific additional judgements proposed for the common inspection framework (paragraphs 28-31)?

This new common inspection framework begins to look as if it doesn’t hold quite so many things in common! At least six extra judgements will be made about FE (for example study programmes, traineeships) which could either offer the benefit of a more sophisticated disaggregated reporting mechanism for FE, or signify a much more burdensome and fragmented inspection regime for colleges.

The 157 Group has talked about the space between policy and implementation. We need to understand that space, and what is in it. Those of us who have tussled with the unintended consequences of well-intentioned reform to the treatment of English and maths in colleges know that space well. Until we see the specifics of the inspection handbooks that will lay out the detailed application of this framework for FE, it is hard to tell…

Q9. Do you agree or disagree with the proposals for short inspections of good further education and skills providers (paragraphs 35–36 and 41-45)?

Yes, but…

Yes, five or six years is a long time since a Good college’s last inspection, and in that time you can certainly have, to paraphrase Rhianna, a good college gone bad.

Yes, three years does seem like a more reasonable timescale. Yes, the “inspection” should be shorter and less intrusive.


But, does it have to be called an inspection? Does it have to be an inspection? Ofsted has done some excellent work getting alongside underperforming colleges and working with them to achieve a Good rating. Why would Ofsted not want to work in an equally supportive but challenging way with a Good college?

Inspection is something that is done to you. Good colleges have earned the right to have something done with them. Sure, if that visit is conducted against a background of ringing alarm bells, then a wider inspection is called for.  In the absence of sirens and claxons, however, let’s have a “what if?” review visit from Ofsted, a challenge to take risks, to push back the boundaries of how we deliver an outstanding service, and a celebration of good practice.

Q10. Do you agree or disagree with the proposals for the inspection of non-association independent schools?

Yes and no buts. If it’s appropriate for all other schools, it’s appropriate for all schools. Let’s do it, but do let’s make sure it’s appropriate, for all schools.

Q11. Are there specific changes to the way that inspectors gather evidence that you think could make our judgements more reliable and robust?

Mmmm. Let’s talk about data. In particular, let’s talk about the use of provider or national averages. The most recent Ofsted Annual Report on Learning and Skills said that only a quarter of colleges were not ‘good or better’ at their most recent inspection. At the current rate of improvement, this might well be as low as 20% in this year’s report. What does that mean for our use of national averages, and in particular for the use of the Ofsted data dashboard in inspections?

Gone are the days when there was a rule of thumb of “5% above national average = Good”. Because, if 80% of colleges are Good, and assuming that 80% of outcomes and success rates are Good as well, then national averages are no longer any judge of the ‘Good-ness’ of a college’s performance. Strictly speaking, the criterion for ‘Good’ success rates would become “not in the bottom quintile (the bottom 20%) of success rates”.

Even as I write that it seems dangerously non-aspirational, and the last thing I would ever want to be is non-aspirational. But although, clearly, outcomes for learners are about much, much more than qualification success rates, we still need a grown up discussion about how we report and use data and the dashboard to review and compare performance and set targets. The SEPI and Value Added measures have already added to the sophistication of the data tools we have in our hands, but let’s discuss this further.

Q12. Do you have any other comments about this consultation?

Probably, but that’s it for the moment.

In summary, reducing all this wordage down to a 140 character tweet:

Ofsted proposals? Yes, but…

  1. Financial Fair Play
  2. “What if?” reviews
  3. All schools and no buts

and a second tweet for further things to look into? PS:

  • Good = NBQ? (Not the Bottom Quintile)
  • Does the new CIF really have enough in common to be a common framework?

About dp40days

A senior leader in Further and Higher Education, now based in Moray (pronounced "Murray") on the coast of the Scottish Highlands. (I know, I love paradox). We have more sunshine and less rain each year than my previous home in Manchester, and about fifty more distilleries too! You can find me on Twitter as @DP40days. Blogs so far have been mainly about work and travel but frankly, I've been a bit quiet recently. Maybe that's about to change...
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1 Response to Yes, but… A personal response to the Ofsted consultation

  1. Pingback: Yes, but… A personal response to the Ofsted consultation by @dp40days | BB2 Collaborative

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