The New Visions for Education Group consists of a number of the country’s leading educationalists, among them professors of education, head teachers, teachers, lecturers, administrators, parents and governors, lecturers and well known writers on education. The group was founded over 30 years ago. The group consists of about 100 members. It is not connected to a political party and exists to promote a high quality, collaborative, inclusive and equitable education service.

Key messages

• The proposals are rushed; a full independent review of Ofsted’s culture must be undertaken without delay.

• The DfE’s report card and Ofsted’s school profile must be properly aligned, and account take of work being trialled independently of the DfE and Ofsted.

• The school improvement model based on the work of RISE teams and Ofsted needs further thought to develop the proposed model to ensure it is fit for purpose.

• A new inspection model taking the form of a health check based on the validation of providers’ own self-evaluation must be developed.

• The proposed Ofsted report card as outlined in the consultation and draft toolkit do not reflect an improvement on the existing Ofsted inspection system.

Introduction

NVEG members fully recognise the case for an effective accountability framework for all parts of the education service. Education accounts for a vast amount of public investment and is of vital importance to the wellbeing of young people, their learning and education, their preparation for happy and productive adult lives and for their contribution to the economy. We recognise that inspections have a major part to play in the development of a system which ensures effective accountability, and we are committed to helping to improve that.

We welcome Ofsted’s commitment to transparency and rebuilding trust following the Big Listen exercise, ‘doing with’ rather than ‘doing to’ and the publication of inspectors’ training materials.

Consultation – scope and timing.

However, we are concerned about the narrow scope of this consultation. The design, content and format of a ‘report card’ seem to be its prime focus. Yet there is a need for a review of the wider aspects of the inspection process, its purpose and culture as well as the impact it has on the leadership and management of schools including their capacity to innovate and improve. Without this we will remain within a system that is not currently serving the best interests of students, stakeholders and providers.

We believe these proposals as they stand are a missed opportunity – they will not help the system move to a more intelligent and collaborative model of inspection. The proposals have been rushed – the deadline for implementation of reforms needs to be delayed pending a return to first principles.

Report card and school profile

It is difficult to understand why these proposals have been conducted separately from the DFE plans for school profiles which were widely expected to be the ‘report card’ promised in the government’s 2024 election manifesto. The Ofsted report card is simply a new format for presenting school grades. This confusion between two separate and seemingly unconnected documents does not help with Ofsted’s stated desire to provide parents with useful and easily accessible information. This response should be read in conjunction with NVEG’s response to the DFE consultation.

We recommend that the school profile and report cards are properly aligned perhaps by considering examples that are currently being trialled by a number or organisations such as Camden Learning, Rethinking Assessment and Professor Lee Elliot-Major’s equity scorecard.

Ofsted culture and the Gilbert Learning Review.

There does not appear to be the kind of ‘reset’ of the culture of inspection that had been promised. This proposed system still visits schools and passes judgements on them in too little time and on too little meaningful data, without having any responsibility for the actions that follow. This will not address the serious issues highlighted by the tragic death of Ruth Perry or in Dame Christine Gilbert’s independent review, nor do they increase the degree of confidence of professionals working within those providers in Ofsted.

We recommend revisiting recommendation 4 of the Gilbert review by contracting an independent research body to collect better evidence:

“A programme of external review and evaluation, undertaken by an independent research organisation, should be built into Ofsted’s plans for reform, particularly of school inspection, at key stages of implementation. Rather than just annual surveys, research will need to be nuanced in timing and approach to support decision-making. As part of this transparent approach, rather than being returned directly by the school to Ofsted, post-inspection surveys should be administered through a third-party, independent organisation.”

We would also note with concern that we are still learning about examples of inconsistency in the approach of inspection teams not all of which seem to have taken on board the promised ‘reset’ of the relationship between schools and inspectors. We are also seeing examples of inspections of schools facing high levels of disadvantage where those improvements that have been made are not given the same degree of recognition that schools in less challenging circumstances receive.

Ofsted inspection – professional practice and standards

A mature inspection system should be based on a professional dialogue between inspectors and teachers. Where inspectors have highly successful experience in the sector they inspect, this kind of conversation can be greatly beneficial to the school or trust; as well as improving the quality of the inspection findings. This is not always the case. Ofsted still deploys some inspectors with secondary experience to inspect primary schools without adequate skills or knowledge and those with no experience of higher education to inspect teacher education.

Moreover, not all school and college leaders make good inspectors. The consultation states: “We will go about our work with professionalism, empathy, courtesy and respect. Our inspections must feel ‘done with’, not ‘done to’. The conversations we have with leaders will start with their own evaluation of how their provision is doing, based on clear toolkits, published data and professional standards.” We are very doubtful that the proposed methodology fulfils this aim. We return to this later in our response.

The stakes are just as high as in previous inspection arrangements and will therefore give cause to just as many unintended or perverse incentives driving practice in schools.

Accountability v system improvement: clarifying the roles of RISE and Ofsted

The relationship between inspectors and RISE teams needs clarity. How much will Ofsted rely on the RISE team to provide intelligence on what is going well or otherwise in a particular context? Will the RISE team inform the scheduling of inspections and the identification of ‘exemplary practice’? We recommend that the respective roles of RISE teams and Ofsted are clearly defined.

These proposals do not appear to consider the sophisticated systems of monitoring, evaluation and accountability that many schools have developed for themselves. The proposed model does not appear to incorporate any flexibility to adapt to the individual context of schools risking an unnecessary duplication of information for parents and trustees. The same one size fits all model is applied to all institutions.

We recommend that further research and consultation is conducted into the respective accountability roles within each part of the system in order to ensure that any proposed model is fit for purpose.

Inspection practice

Whilst the restriction of notice of an inspection to Mondays is an improvement, the one-day notice period is still a huge disruption to schools’ routines. Is it not time to move on from this as a practical demonstration of the intended establishment of a high trust culture? The argument based on anecdote rather than evidence that schools can ‘hide’ pupils or ‘cover tracks’ with more notice raises questions about the competence of any inspectors who would not be able to spot such behaviour or indeed that any school determined to do this can still deploy previously planned strategies at very short notice? The ability of schools with sophisticated website analytics to predict when an inspection is about to occur must be tackled.

We recommend that the notice period is extended following a consultation with the sector. We also recommend that Ofsted discontinues the practice of inspecting schools in the last weeks of the Christmas and Summer Terms when this adds considerably to workload at the busiest time of year and makes it particularly difficult to gain an accurate picture of the school.

School self-evaluation as part of the inspection model

NVEG and many other stakeholders have long advocated a system based on school self-evaluation validated through a structured process using external partners. The process does not need to be in a centrally dictated or uniform format. It would be a ‘health check’.

Ofsted would however determine whether a school’s self-evaluation was a robust process and would look intensively at schools where issues arise. This should achieve reasonable consistency in the self-evaluation process and enable lay readers to understand a school’s self-evaluation.

We welcome Ofsted’s distancing from a single Self-Evaluation Form (SEF) format. Nevertheless, the previous SEF format contained a large amount of data which would not be required if a school profile were in place.

If the DfE school profile contained a concise summary of the school’s self-evaluation, it could also provide the kind of information parents might find useful. The advantage of such an approach would be for these to be “living” documents as opposed to a snapshot at one moment in time of the Ofsted Report Card.

The onus in inspection should therefore be on schools and trusts to demonstrate how they provide a quality of education that meets external requirements as well as the specific needs of their local context through self-evaluation.

We absolutely reject HMCI’s assertion in his speech to the March 2025 ASCL conference that such an approach would be a move to a low accountability model. Where a cause for concern was identified, this could lead to a full inspection conducted by a larger team and the identification of suitable interventions and support. This would have the benefit of allowing for a more efficient targeting of Ofsted resources where they were most needed maintaining appropriate rigour within the inspection system.

We recommend an inspection model taking the form of a health check based on the validation of a school’s own self-evaluation.

Report cards and grades

The report cards as outlined do not reflect an improvement on the existing system for the following reasons:

The five grades do not reduce the high stakes of the previous single grade system. By increasing the number of grades there will be an increase in grade boundaries which combined with the woolly definitions and distinctions between various grades in the toolkit this is likely to lead to more challenges on grades which were largely uncontested previously.

The definition of the grades will confuse rather than inform stakeholders and support inconsistency. Effectively ‘strong’ will be what all schools aim for; but the difference between ‘secure’ (or ‘average’) and ‘strong’ (or ‘above average’) is often difficult to discern. In the section on ‘Achievement in national tests and examinations’ in the School Inspection Toolkit the difference is between ‘in line with’ and ‘above’ national averages. We foresee all kinds of arguments about these often minor or fine distinctions. It is beyond the scope of this consultation to comment on the specific details of the entire toolkits, but we believe that they need a radical rethink. The criteria are far too vague and very difficult to operationalise in a short inspection.

‘Attention needed’ is particularly problematic – the definition of this grade which states: ‘inspectors have determined that leaders have the capacity and means to make the necessary improvements’ will not be understood by parents or other stakeholders when a red flag appears against the school. It will be viewed as a failure as is the current ‘requires improvement’ grade; thereby exacerbating staffing and student recruitment and retention problems. A school only has genuine problems when that issue is not recognised, or the local authority/school/trust does not have the capacity to address them. That is where intervention/support is needed.

The majority of inspections will need to make 45 or 50 refined judgements against these criteria. The reality is that most inspections are conducted by a very small number of inspectors effectively gathering evidence for less than two full days. This cannot provide a substantial enough evidence base. Such a superficial assessment will lead to inspections drawing generalised conclusions based on minimal first-hand evidence. The simplistic layout of the report card gives the impression that these judgements have a validity and credibility that cannot be the case under the inspection process and will mislead the wider audience including parents, as well as being unfair to providers.

The ‘exemplary’ grade is equally problematic. First of all, a clear definition of “exemplary” is needed. In some cases, it simply describes what should be provided. Even more importantly the source of such examples will be severely constrained by the sample of providers inspected in any year. It is also very difficult to imagine how a remote panel might be able to validate judgements about a school in this way. This grade borrows the assumption that “best practice” can be defined without regard to context – very little schools do assumes that level of generality.

Ofsted inspections –capacity

We welcome the decision to move away from deep dives and Ofsted’s recognition that these focused a vast proportion of their time on a limited number of areas. Nevertheless, the issue still remains of how a small number of inspectors can realistically evaluate the quality of teaching and learning especially when many classroom visits only cover a small section of lessons. A number of members of NVEG have extensive inspection experience and are well aware of the limitations of such a superficial approach. Schools and trusts and approaches such as the London Challenge now used by large numbers of schools on the other hand visit many different lessons and possess a detailed first-hand knowledge of what takes place in their classrooms. Validation of their evaluations and the impact of their work would therefore be far easier than relying on the potentially unreliable judgements made during inevitably brief inspection visits.

Other consultation questions

What do you think about the other evaluation scales we have considered? (as set out in the consultation document)

Of the three options we have a preference for option 2.

A detailed Ofsted report is not the best way for parents to ‘choose’ schools. (Actually, they can only state a preference). Parents need to visit schools themselves and read the information schools provide in order to find out how well suited a school might be to their child’s needs. Ofsted reports are a snapshot taken at a point in time: they inevitably reflect characteristics (e.g. the make-up of the school body, its leadership, staffing and pupils) that can be expected to change rather than hold constant during the time the pupil will be at the school.

Inclusion

The definition of inclusion does not include any reference to admissions. Schools that are strongly committed to inclusion will admit pupils with a wide range of needs. This impacts on outcomes compared with schools that are effectively selective (officially or otherwise). Many of the incentives in published accountability data are weighted in favour of schools that avoid admitting, or exclude in one way or another, pupils who may harm outcomes. The inspection model does not place enough emphasis on external factors that influence school performance. This could be the aggressive actions of other schools, weak local authority SEND provision, slow processing of EHCPs etc. The link with admissions and exclusions needs to be taken into consideration. To make an accurate evaluation of a school’s inclusion provision is a big and specialised task highlighting again the weakness of Ofsted’s methodology. It is not clear from the document how inclusion will be measured.

Conclusion

We have welcomed the opportunity to respond to this consultation. However the role inspection needs to play in our education service has moved on since its inception as has the structure of England’s school system. For this reason any proposals need to be underpinned by a root and branch review of first principles about the purpose of inspection. This would need to consider the systems and procedures for monitoring, review and evaluation that are now well established in many schools and trusts and would need to be integrated into a wider vision about accountability and the school profile of which Ofsted’s reports would be one part. Without this taking place the implementation of detailed proposals would be deeply flawed.

21 April 2025