Inspecting Post-16
Education and Training

The Common Inspection Framework
A NIACE response to the informal consultation

Published: May 2000

General comments

NIACE welcomes the opportunity to make preliminary comments on the Common Inspection Framework. Although there will be a further consultation stage from this Summer, we are pleased to participate in both processes.

Inspection needs to serve the interests of learners, teachers and organisers, as well as those who fund provision. Inspection is vitally important to the interests of adult learners. It safeguards the quality of what they experience across the country and offers the reassurance of independent judgement. To teachers and education providers inspection can offer benchmarks and feedback towards improvement in quality. Without it self assessment might be less rigorous. For policy makers inspection provides a means of monitoring the effectiveness of funding and the quality of provision overall. In these different interests NIACE sees it as fundamental to a good inspection framework that the process should offer guidance, development and support, as well as rigorous audit of provision. For those inspected the process has to be open, transparent and fair. For adult learners and potential learners there has to be reassurance that inspection leads to real improvement in the quality of what they experience.

Overall, NIACE welcomes this Framework. We would like to see the next document including specific reference to:

We recommend the drafters of the next consultation document should consider the provisions in the 1994 Ofsted Inspection Framework for Adult, Youth and Community education in framing advice.

NIACE reminds the Department of our response to the Learning and Skills Bill in which we reject the principle of having two inspectorates whose duties split at the age of 19. Our views take further NIACE’s evidence to the Education and Employment Select Committee in 1998. In this we argued that Ofsted needed to invest more in inspecting local authority adult education programmes, required more expertise in the inspection teams and needed a framework that encompassed adult learning more effectively. The interests of adult learners were also not initially well served by the FEFC inspection process. For example, the lack of distinction between basic skills and learning difficulties and/or disabilities issues in inspection evidence meant that there were avoidable difficulties in making accessible transparent data to contribute to the Moser Report on basic skills. Both inspectorates have a wealth of experience but lack a clear central focus on adults. Almost all LEA provision has missed out from support by FEFC and most LEA and voluntary sector provision has missed out on Ofsted’s inspection.

This response gives some detailed comments on what is a clear Framework which has the potential to protect and promote the interests of adult learners. The extent to which that potential is realised does depend upon getting the detail right. The following response is made on the assumption that the arrangements proposed in the Bill are not significantly amended.

Draft framework

Question 1: Principles

There is no mention of the concept of inspection being ‘open’. It would be helpful if one of the key principles of the new Framework was ‘openness’ on both sides – between provider and inspection team and vice versa. The ‘provider nominee’ role will contribute to this concept but further evidence of openness would be welcome.

To broaden access to education for the many who do not participate is a key Government objective. The new Framework must include access agendas and cover prospective students, pre-enrolment processes and the effectiveness of educational guidance. This is why NIACE among others has argued for area inspections carried out by the Adult Learning Inspectorate too.

Paragraph 3

NIACE would welcome a focus on the collective experiences of learners and not just on the experiences of ‘individual learners’. In some cases, such as in family learning or community education, it is the group which is the focus of the teaching. In these situations learning from each other is sometimes the primary focus or learning collectively for the common good is a central objective. Such an approach is necessary to deliver the vision of the Policy Action team on Skills as articulated in Skills for Neighbourhood Renewal (DfEE, 2000).

We welcome the explicit mention of ‘provision for learners with learning difficulties and/or disabilities’ in relation to social and educational inclusion, and promotion of equality of access. However, NIACE argues that other groups of learners also need to feature as exemplars – such as those with poor basic skills, refugees, older people, and those who are in poverty.

NIACE questions whether the phrase ‘and/or’ adds anything to the meaning of the sentence in bullet point 5. Some people have no disability but they do have a learning difficulty. Others have both a learning difficulty and a disability, or a disability and no learning difficulty. All these could be covered by the phrase: ‘learning difficulty or disability’ and make for plainer English. It would also be helpful to return to the principles of both the Warnock and Tomlinson reports and not define students in terms of their disability, but in terms of the learning difficulty they are up against.

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A clearer statement on what is meant by all inspectors being ‘trained’ and ‘accredited’ will be necessary.

NIACE supports the concept of briefing providers in advance on the inspection process and recommends that this apply to all providers, irrespective of size.

It would be helpful to have fuller information on what is meant by ‘staff working for the provider’ being involved in the inspection process and kept informed of emerging issues. If this refers to the ‘provider’s nominee’ then it should be about more than being kept informed about emerging issues. Nominees in FEFC inspections have frequently been able to make invaluable contributions to the overall judgement.

NIACE notes the comment that feedback should be provided of inspection judgements and evidence to support the judgement. This is important. No inspection work, including one-off visits, should take place without feedback. Feedback should be given only when judgements and evidence are clear. Rarely is this immediately after or during an inspection. Individual feedback to teachers regrettably has to be given immediately. More recently, teachers have received feedback on their teaching face to face through internal quality assurance systems, but this is not yet common practice in community-based provision or in training situations. Inspection is distinct from advice but we believe that the process should aim to leave teachers with a clear picture of how they could improve their effectiveness and reassurance where necessary.

If a grade is to be allocated to a teaching session then it would seem fair to recognise that the grade should be for the whole picture and not just the teacher’s performance. A grade can be assigned which covers areas that might be beyond an individual teacher’s control. For this reason NIACE urges that grades are not given to individual teachers in their feedback and institutional or organisational managers are not offered a detailed report on which teachers received which grade.

Paragraph 5

NIACE supports the points in this paragraph which relate to inspectors’ conduct (impartial; honest; fair; co-operative and act in the best interest of learners) . NIACE would welcome some comment on how providers should conduct themselves in return.

Paragraphs 6 and 7

NIACE supports these principles about the quality of judgements and communication.

Question 2: Seven key questions

NIACE is unclear why one of the key questions does not cover quality assurance. It could possibly be covered by the question on leadership and management. However, this is an oblique way and it would be helpful to have a separate question about how well the institution assures the quality for future learners. This is a surprising omission given that the evaluation requirements are meant to focus on three aspects, one of which is ‘the quality of education and training’ (Part B paragraph 1, page 13).

Question 3: Evaluation requirements and Question 4: the criteria

Section 1: achievements

NIACE supports the key evaluation criteria but there are difficulties where there are no qualifications or national standards, as in some of the ground-breaking work done to widen participation in learning among people who found school intimidating. Regrettably, for these courses the words, ‘results’, ‘local and national averages’, ‘trends in performance over time’, and ‘standards’ are not appropriate. It would be helpful if the concepts of learning as ‘stimulating’, ‘exciting’, ‘confidence-building,’ ‘life enhancing’ and ‘enjoyment’ could also be included in the language of judgement. Adult learners respond and return to learning where programmes are both enjoyable and effective. ‘Progress towards fulfilling their goals and their potential’ would encourage broader approaches to inspection if inspectors checked to see that individuals’ personal learning goals were achieved. NIACE recognises the Government’s commitment to identifying the ‘wider benefits of learning’ through commissioning the new Research Centre and would have expected this Framework document to have reflected some of these ‘wider benefits’.

Section 2: effectiveness of teaching, training and learning

NIACE supports these comments but adds that in making judgements one of the criteria should be the extent to which teachers and trainers use the language and the experience of the learners. For adult learners this is important, whether in the workplace or in community-based settings.

Section 3: resources

NIACE supports these comments about staffing, specialist equipment, learning resources and accommodation. It is helpful that resources only appears in this one section rather than being divided between ‘specialist’ and ‘generic’ resources. NIACE would like to see added a reference to ‘staffing’ including volunteers, technicians and mentors. It will be necessary for the framework to recognise the range of commercial, industrial and community settings within which effective adult learning can occur.

Section 4: assessment and monitoring of learners’ progress

NIACE cautions that the words ‘where applicable’ be highlighted so that not everyone is expected to make a judgement on ‘achievements towards learning goals and qualifications are recorded and accredited’.

Section 5:

It might be helpful to insert the concept of ‘teaching style’ and ‘learning style’ into the text. The first evaluation point does not include the notion of a match between teaching style and learning style.

NIACE is delighted to see the phrase ‘learning outcomes and qualifications’ and would want to see this repeated wherever qualifications are mentioned.

Section 6: guidance and support

NIACE supports these comments. However, the Framework needs a section on the connection between the inspectorate’s responsibility for guidance as part of a learning programme and the Guidance Council Accreditation Board’s responsibility for discrete guidance. Adult learners would best be served, in our view, if quality assurance for guidance came under the duties of the Adult Learning Inspectorate so that guidance is not marginalised.

NIACE believes that the Adult Learning Inspectorate and the Guidance Council Accreditation Board should co-operate to include guidance for all ages when area inspections for 16-19s are undertaken in order to give a fuller picture of the quality of provision across more than one provider. This would, in our view, strengthen the Framework given the importance of guidance for adults in securing wider participation.

There is little mention of guidance and advice in relation to non-standard provision such as that to be made by Ufi.

Section 7: Leadership and management

NIACE believes that quality assurance arrangements are too important to be subsumed into this section and should stand alone as a section, recognising the relationship between inspection and the quality assurance role of the LSC and its local arms.

Where ‘demanding targets’ are mentioned (at bullet 2 page 21) inspectors and providers would need to have robust targets for the achievement of primary learning goals if a learning outcomes model is in use.

Where ‘best value’ principles are mentioned in section 7, NIACE believes that this concept will require extensive advice in order to transfer it beyond its current use in local authorities. Some providers will not have met this concept before.

Question 5: The proposed report structure

It is not at all clear in the document what the report structure will be like when it comes to small providers who may provide only one course, programme or occupational area. NIACE would recommend that all reports are broadly similar and that there is full consultation on any modification intended for smaller organisations.

Similarly, data provided about the provider must be consistent but must allow for providers who may

For example, NIACE would not want to see in the data such unrepresentative information as the ages of students grouped as they are now in FEFC inspection reports: under 16; 16-18, 19-25 and 25+. NIACE recommends the adoption of age groupings for 16-18, 19-24, 25-34, 35-44, 45-54, 55-64, 65-74, 75+.

NIACE also recommends that inspection reports include data on the profile of the community in which the provider operates, or a profile of the workforce in the industry in the case of training in employers’ premises.

Question 6: the preferred grading scale

NIACE has never been convinced that the grading arrangements have been satisfactory. There has been a marked reluctance to use grade 1 or grade 5 in the 5 point scale and increasing the scale to 7 will not address this. NIACE recommends that if a numerical scale has to be used then 5 points is better than 7. What constitutes ‘satisfactory’ is crucial. We cannot be in a position again where inspectors describe as ‘satisfactory’ provision that has an equal balance of weaknesses and strengths. Similarly, we do not want to see the word ‘outstanding’ being used to describe rare provision. The full range of grades and grade descriptions must be used and be seen to be used.

The seven point grading system is, we believe, unnecessary, particularly for small providers.

Question 7: an appropriate basis for self-assessment?

NIACE believes that the strongest basis for any self assessment criteria will be what the Learning and Skills Council expects of providers in relation to quality improvement, and not what the inspectorate decrees. However, it will be important to align the Framework with the quality improvement expectations on providers and this is an urgent task.

NIACE will expect either the LSC or the inspectorates (or perhaps both) to issue guidance on self assessment for all providers. This will set out the expectations of the LSC and inspectorates, explain the grading criteria with illustrative examples, and advise on achievement, progression, retention and attendance data required and benchmarks (especially where there is no national data available).

Question 8: the ‘provider’s nominee’

NIACE believes strongly that a ‘provider’s nominee’ should attend all meetings where collective judgements are shared. It is crucial for the inspection process to be fair, but also to be seen to be fair. NIACE believes any inspection should be as open as possible. In fact, we argue that openness should be one of the key principles for the new inspection Framework.

Other issues to be resolved

NIACE considers the areas still unresolved to be of crucial importance and hopes to see full consultation on these and related matters in due course. In advance of their resolution, NIACE offers these comments.

i) the principles governing how work is sampled

One of the principles should relate to the size of the organisation in relation to learner numbers, and another on whether it has been inspected before, and a third on the effectiveness of the self assessment report. Choice of provision to sample should never be inhibited by the experience and expertise of existing inspectors.

ii) aspects to be graded

Each of the seven areas should be graded, irrespective of the size of the organisation. All providers need to work to the same LSC quality improvement criteria. For some to have only one grade or two as proxies for quality makes it difficult to match the quality of their provision with that of other providers locally.

iii) grade descriptions

Unhappy as NIACE is with the concept of grades, the current FEFC arrangements are at least generally understood, with the proviso that full use is made of the range of descriptors and that words like ‘excellent’, ‘outstanding’ and ‘poor’ are best avoided since this prevents the broad range being used.

iv) the extent to which grades are published

Broadly, if grades are to be allocated then they should be published. Grades allocated to individual teaching sessions should not be shared with anyone but should form part of the overall view of the quality of teaching, learning and quality. Providers should be aware of the profile of grades allocated and what these mean in relation to the quality of their overall provision. However, no teacher/tutor deserves to be publicly humiliated. In the case of a weak teacher the individual feedback should be clear and direct although the weaknesses should be picked up through self assessment arrangements and staff development. Inspection should be focused on the quality of teaching provided generally for learners and not on that provided in what might be a weak one-off individual session.

v) what to do about provision that is not ‘adequate’

This is a matter for the LSC and not the inspectorate, in the main. There should be a re-inspection followed by a report which should be published quickly. For the LSC, arrangements will need to be put in place to support providers who are found to be weaker. Where there is little or no improvement after 6-12 months then provision should cease to be funded except in exceptional circumstances (such as where there are no other providers). Initially, particularly where providers are new to making provision, there should be a proper chance for inadequate provision to be rectified before re-inspection.

vi) operational management of inspection, including team composition, duration, notice

Peter Lavender
NIACE

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