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 rely exclusively on actions that are to be managed centrally by DfE and ignore the wealth of intelligence about schools held by local authorities, MATs and local communities including parents

• Reliance on Ofsted inspections and national data to identify schools needing support or intervention is inadequate

• The focus on structural intervention is not supported by evidence and will often distract attention from the real issues.

• RISE teams cover far too great an area and will not have the capacity or the local knowledge to identify and manage support and intervention on the scale envisaged.

• RISE teams will be reliant on mobilising school improvement capacity from local authorities, MATs and the private sector. There is no analysis of how this would work and whether such resources would be available wherever and whenever they are needed.

Introduction

All educational institutions must be accountable for their use of public money and for their performance. However, NVEG have serious reservations about the DfE’s approach to accountability as set out in the consultation paper. Our constructive criticism aims to improve the accountability of educational institutions so that issues can be identified and support provided in timely and appropriate ways.

The consultation makes assumptions about how the DfE and Ofsted intend to proceed. This is disappointing as it pre-empts the opportunity to ask more fundamental questions about how the accountability of schools and colleges should be managed. See the NVEG response to the Ofsted consultation.

A national school improvement strategy for all schools is needed. It is not sufficient to claim that the proposed RISE teams “will also offer universal support, fostering a self-improving school system by spreading effective practice between schools” (page 19) without supporting evidence.

The consultation is on a relatively small proportion of schools which fall into particular Ofsted categories. A national school improvement strategy would ensure that both challenge and support are available to all schools and not just those which fall into a particular category. Regrettably, the great majority of schools will be left to manage improvement through whatever pathway they can find in our diverse school system

School Profiles

There will be confusion in having a DfE School Profile and an Ofsted Report Card. A single report card as proposed by the Labour Government in 2009 is necessary which includes DfE and Ofsted information as well as locally produced information.

Statistical information derived from national data collections will be of limited value in enabling parents and others to assess a school. Comparing schools purely because of their shared location given what we know about how admission arrangements can distort the picture in any given area is problematic. Encouraging comparisons will almost certainly end up favouring schools that have, one way or another, achieved a more favoured intake. Ofsted gradings have fallen into this trap (question 13).

If this proposal is to be taken forward, the profile could usefully include some more challenging material such as (question 14):

– Governance arrangements and in particular the part played by parents in governance

– Leadership salaries including those in any relevant MAT

– Staff turnover

– Pupil turnover

– Exclusions

– Admission arrangements

– Whether the school’s intake is representative of its local community.

The profile should not become a way in which schools advertise themselves in a competitive way. Anything in the profile should be objective and confirmed either by data or by external scrutiny (question 15)

There is a real risk that schools with favoured intakes can, for example, with parental support and funding, demonstrate a wider range of enrichment activities than is possible for schools in more challenging circumstances.

Intervention

Identification of schools needing support or intervention

The proposals consider four categories of school as needing support or intervention. They are:

• Schools requiring special measures
• Schools requiring significant improvement
• Stuck schools
• Schools where attainment is considered too low.

In all cases it is proposed that schools in these categories are to be identified either by Ofsted or through attainment data.

However, inspections happen infrequently and are, given how little resource is allocated to most inspections, often inconsistent and unreliable. We have set out in much more detail our reservations about the proposals for inspection in our response to the Ofsted consultation.

Reliance on national data sets will be equally ineffective. Data needs to be interpreted in the particular context of the individual school.

No one at the national and regional level will have the time or knowledge to know what is happening in so many schools and most importantly no one will have the capacity to identify warning signs before the issues reach crisis point.

The proposals ignore the wealth of intelligence about schools held by local authorities, MATs and local communities including parents.

Structural Intervention

Structural intervention is DfE code for academisation or for moving an existing academy to a new trust. It is proposed that structural intervention is automatic when a school is judged by Ofsted to need special measures. In other categories it will happen if improvement doesn’t happen quickly.

There is, however, no reliable evidence that structural intervention alone leads to improvement. School improvement is a much more complex process than just imposing new governance arrangements. Simply playing pass the parcel with schools is not a useful way forward.

The threat of structural intervention is an important reason why the inspection process has become toxic in the eyes of much of the teaching profession. Staff, and in particular leaders, know that careers are at stake, and this creates an unacceptably pressured and unhealthy environment. Both ministers and HMCI have committed to making inspection a less pressured and more collegiate activity. This focus on structural intervention is a complete contradiction of that pledge.

The legalistic process of structural intervention is wasteful of resources and often actually delays remedial action. It is also a process which is carried through without any consideration of the views of local communities. It encourages a crude and simplistic approach by MAT leaders designed to demonstrate quick results, often by the excessive use of exclusions or off-rolling.

The DfE proposal ignores the fact that the definition of a school requiring significant improvement includes the finding that the existing leadership may have the capacity to address the issues facing the school. It would therefore seem perverse to assume that in those circumstances there is an immediate recourse to structural change.

The commitment to structural intervention assumes that the reason a school is in difficulty is that its leadership and/or governance have been weak and changing them will make everything ok. The reasons are usually far more complex. Improving performance needs to be about properly understanding those issues and designing support that is appropriate to the school. A “one size fits all” national approach to school improvement may be all that the DfE is capable of organising but this will not in practice meet the needs of many schools.

In this context it should be noted that:

• 85% of schools in special measures are academies
• 86% of schools that would be identified as “stuck” are already academies.

This would suggest that the previous government’s faith in academisation as a magic bullet left much to be desired (questions 17 and 18).

Regional Improvement for Standards and Excellence (RISE) Teams

There are nine RISE teams, one based in each English region. They are to be responsible for supporting:

• schools requiring significant improvement
• Stuck schools
• Schools where attainment is considered too low.

In addition, the “RISE teams will work with all schools to signpost them to the most effective practice, including DfE hubs; encourage peer-to-peer support; and bring schools together to share their knowledge and innovation” (page 20).

This means each team will be responsible on average for 2500 schools. Nationally there are 630 schools defined as “stuck” and over 1000 additionally that Ofsted considers require improvement. Then there is an unknown number deemed to have low attainment. All these will be priorities for support. The advisers appointed so far all have day jobs so the time they will have to dedicate to RISE activity will be limited.

The consultation paper provides no information about the size, nature and cost of RISE teams. It is difficult therefore to make an informed judgement about the extent to which they will have the capacity to make a useful contribution to improving these schools.

It will be inevitable that these teams, covering as they do so many schools, will not have the insight into individual schools that would enable them to identify where there are genuine problems. Whether they can make a useful contribution will depend on whether they can mobilise resources that are able to provide effective support. The risk is that identification will be based on a crude reading of inspection reports and national data and that engagement will be spasmodic and superficial (Question 19).

Stuck Schools

The term “stuck schools” is insulting and offensive. Many schools that meet the proposed definition will have been striving to provide a quality education in challenging circumstances. They need support, not blame.

The proposed definition of as stuck school is one that has received two consecutive “requires improvement” judgements or the equivalent under the revised (September 2024) Ofsted arrangements. This is crude and simplistic. Ofsted inspections are not frequent enough or reliable enough to be used for this purpose. It could be anything between 4 and 8 years before sufficient Ofsted evidence is available.

There can be many reasons why a school might fall into this proposed category. It is highly likely that many of them will be schools where poverty is endemic, employment opportunities are limited, and staff recruitment is particularly difficult. All our experience of putting schools into categories like this suggests that the judgement will have as much to do with the school’s socio-economic context as with the way the school is run.

Schools with low attainment

It is concerning that the draft Ofsted toolkit starts its analysis of pupil attainment by dividing schools according to whether their results are at, above or below national averages. This is clearly inappropriate in that it completely ignores context and will constitute a dangerous incentive for some schools to resist taking pupils who might otherwise put their results at risk.

It will be obvious that schools with very favoured intakes achieving at the national average would be far from satisfactory. It is equally obvious that every school can’t be above average so this measure is setting many up to fail regardless of what their actual performance might be.

Judging whether results are a cause for concern is not simple. Reading data off a national spreadsheet is not adequate. The current measures – both raw data and constructs such as progress 8 have been widely and rightly criticised and the Francis review is charged with reviewing assessment and how it is recorded. What is important is whether a school has a capacity to improve. If a school’s self-evaluation demonstrates convincing strategies to address weaknesses showing a capacity to improve that should be recognised and celebrated and be a reason why a school should not ‘receive’ structural intervention. It would also indicate DfE’s view of the nonsense that a school can be ’turned around’ in 5 minutes.

The test clearly is whether attainment is above, in line or below what could be reasonably expected given the prior attainment and background of the pupils. Both of these factors may vary, so looking at year-to-year changes is complex. Attempts to find a simple measure that will fairly judge pupil attainment levels have comprehensively failed over many years now. The only reasonable approach is the scrutiny of results against all kinds of comparative data by someone familiar with the school, its context and its changing circumstances (questions 22 & 23).

Impact on workload and wellbeing

The focus on structural intervention as an outcome from inspection will continue all the damaging effects on workload and wellbeing that have been so widely recognised to date. It will mean that inspection continues to be a high stakes affair and will drive schools into spending excessive time on preparation.

The proliferation of grades in the proposed report card will make this even worse.

It will continue to put unacceptable pressure on school leaders, in particular. It will do nothing to address the wellbeing issues that have been so widely documented, notably but by no means exclusively in the Ruth Perry case. These proposals fundamentally contradict the hope that inspection could become a process based on dialogue and collaboration. It will remain confrontational and a source of excessive pressure and anxiety. The outcomes of inspection should be supportive and collaborative but what is proposed will be seen as simply judgemental and frequently punitive.

Moreover, the reliance on occasional short notice but high stakes inspection is in itself a source of pressure. Having to perform at your best with minimal notice and with only two or three days to show what your school can do is damaging in terms both of workload and wellbeing and is also unlikely to generate consistent and reliable outcomes (Question 26).

An Alternative Model

The monitoring of schools should be a continuing dialogue with informed professionals and peers rather than an occasional high stakes intrusion. There is no substitute for the regular gathering of local intelligence. Engagement with schools should be frequent but low key.

There have been a number of models developed that could be used. One was the introduction – albeit with an absurd level of centralised bureaucracy – of school improvement partners by the last Labour government. Then there are peer review programmes such as Challenge Partners and the Schools Partnership Programme. In many areas too, local area school partnerships have built ongoing school review into their frameworks utilising both peer review and external scrutiny.

One way forward would be to expect all schools to participate in some kind of structured, externally validated and continuing self-evaluation. The outcomes could be reported to governors and parents on a much more regular basis than is possible with Ofsted inspections. The role of inspection could then change radically. Ofsted’s task would be to sample and validate school level evaluation systems – some kind of kite mark system may be appropriate.

The quality of information available would be greatly enhanced and the pressure on schools would be greatly reduced. Support and, if necessary, intervention could be planned as a response to the particular needs of individual schools rather than being a crude exercise in slotting schools into simplistic categories.

At the heart of the problem is the DfE’s insistence on trying to manage the whole school system centrally. A more appropriate approach to monitoring and intervention would be to make use of the government’s commitment in other fields to devolution. Some 30 to 40 mayoral combined authorities, if properly resourced, would be much more likely to be able to identify issues and to provide support for a more manageable number of schools.