| 4.1 |
The Framework itself:
 | starts with definitions of terms (‘provider, learner, teacher/trainer, learning
goals, personal and learning skills’). |
| is intended to apply to the inspection of education and training in a wide range of
settings. |
| reminds readers of the Act and the three key requirements on Ofsted and ALI to
report on
| the quality of education and training; |
| standards achieved by learners; and |
| resources managed efficiently and used to provide value for money. |
|
| reminds readers of the purpose of inspection which is:
| to give an independent public account of the quality of education and training |
| identify strengths and weaknesses and highlight good and poor practice |
| inform the secretary of state, the Learning and Skills Council (LSC) and the Employment
Service (ES) |
|
|
|
NIACE
comment: The ‘terms explained’ is helpful. The broad definition of
‘teacher’ is useful, to indicate that it includes all those with a teaching
function regardless of job description. ‘Learning goals’ ought to indicate that
they include what the learner and provider wishes them to include which may not be
anything to do with a qualification. We suggest that the list starts without
qualifications and moves on to qualifications so that it does not move in and out of
qualifications or parts of qualifications. As it includes ‘milestones towards’
this helps with readers’ understanding of the broader achievement goals which
learners can work towards as well as the need to find evidence to support such goals.
NIACE would hope that one of the purposes of inspection which could be stated is to
help providers to improve their provision. |
| 4.2 |
The Framework states that the focus will
be on ‘the experiences and expectations of individual learners’ through
evaluating:
| achievements |
| quality of teaching, training and learning |
| the programme, resources and support |
| quality and value for money |
| social and educational inclusion, equality of access, provision for learners with
learning difficulties or disabilities. |
Inspectors are to be:
| accredited, trained and well prepared for inspection. |
Providers are to be:
| briefed before inspection (both the process and their role). |
Inspection must:
| engage providers’ staff and keep them informed of emerging issues and findings. |
| keep demands for information to a ‘realistic’ minimum. |
| seek the views of learners as part of the evidence. |
|
|
NIACE
comment: Methods of hearing the experiences and expectations of learners
need to be identified and the voice of learners fully used in all inspections of adult
learning. The current systems for hearing from learners are ad hoc and rather ineffective;
we need better methods. Accreditation, training and preparation of inspectors is welcomed
but it would be helpful to have more detail of what is intended. We welcome the process of
briefing providers before inspection, which is well tried and tested in current inspection
arrangements. The principles set out are welcome, too. In particular, the intention to
keep providers’ staff well informed of emerging issues and findings. NIACE expects
this to lead to full involvement of the provider’s nominee in each inspection.
Openness is a crucial principle. |
| 4.3 |
The conduct of inspectors is set out as part of
the document for consultation. In order to hold ‘high professional standards’
inspectors must:
| be impartial and objective. |
| report honestly and fairly. |
| be open and transparent and provide as much feedback as possible. |
| carry out the work with integrity, and with courtesy and sensitivity. |
| ‘act with the best interests of learners as a priority’. |
The quality of inspection has to:
| be well supported by evidence from observations, documentation, learners, staff and
others. |
| ensure match between evidence and judgement; match between overall findings and the
balance of evidence overall; and ensure that the judgements reflect the collective view of
the inspection team. |
| include clear and well-argued judgements based convincingly on evidence. |
The follow-up to inspections will allow for
| full and open feedback of findings from the lead inspector, and discussion. |
| varied composition of feedback between inspections, but usually including:
| senior managers responsible for the provision. |
| governing bodies where appropriate. |
|
| feedback from providers about the inspection. |
| factually accurate inspection reports, with providers offered an opportunity to check
the factual accuracy before it is published. |
Post-inspection action plans will be expected following an inspection where issues for
improvement will be identified by the inspection report. The action plan will be prepared
by providers or others responsible for the provision, to address weaknesses and to build
on strengths.
A complaints procedure will be published and will be made known to providers in advance
of inspections.. |
|
NIACE
comment: We recognise that the model of quality, follow-up and action
planning is similar to the existing TSC and FEFC inspection model which has worked
satisfactorily in recent years, and we welcome this. In particular we welcome the
statements on the conduct of inspection, inspection quality, follow-up to inspection and
the safeguards for providers. However, NIACE would like to see
| safeguards for inspectors too, against any unprofessional behaviour on the part of
providers; we suggest that the interests of learners are not best served where inspectors
feel intimidated and we would like to see a joint declaration on the conduct of
inspection, between inspectorates and providers’ organisations. |
| guidance on what is a fair sample of observation or a reasonable sample of learners
and staff, from which to secure evidence that is sufficient. |
| a fuller mention of the role of the self assessment report and its importance in
relation to inspection judgements. |
| a clearer statement on how providers can be assured that oral findings match with
those given later in writing. |
| a clearer statement of what format of feedback is expected for each inspection; it
does not seem reasonable to leave this to each lead inspector. |
| a clearer statement about the role of governors in respect of feedback on inspection.
|
| some indication of timescale between inspection, feedback, written report for
checking, and publication. |
| clearer information on timescale in respect of post-inspection action plan: length of
time between publication of report and issuing of action plan. |
| links between post-inspection action plan, provider’s strategic plan and self
assessment report. |
| some indication of how learners can feedback on the conduct of inspection, and some
statement that learners will also have recourse to the complaints procedure. |
|
| 4.4 |
The remainder of the Framework document
sets out the seven headings of the evaluation requirements demanded of the inspection
process. The requirements apply to the provider as a whole, or whichever part is being
inspected in the case of a large provider, where the sections apply to occupational areas. |
|
NIACE
comment: A lot will depend on which occupational areas providers will be
inspected against. We have particular concerns about those aspects which are generic and
fall in to several occupational areas. Other problematic areas include provision for
learners with disabilities; here the Framework will need to reflect the comments in
‘Inspection focus’ about the particular requirements of learners with
disabilities. What steps will be taken to have particular regard to these learners: will
this be an ‘occupational area’ or inspected as part of a cross-provision area.
The same applies to other groups of learners and to subjects like basic skills and English
for speakers of other languages (ESOL). The proper reporting of quality in relation to
these groups of learners continues to be a national concern.
It would be helpful to know exactly what was to be graded: all seven areas, the three
broad areas, or combinations of occupational areas? In particular, NIACE is concerned that
smaller organisations will receive grades that properly reflect their structure and the Framework
ought to set out more clearly how this will be done. |
| 4.5 |
The Framework sets out three broad
headings of inspection (achievement and standards, quality of education/training, and
leadership and management), under two over-arching inspection questions: ‘How
effective and efficient is the provision of education and training in meeting the needs of
learners, and why?’ The seven sections of the Framework follow seven
questions: Achievement and standards
1. How well do learners achieve?
The quality of education and training
2. How effective are teaching, training and learning?
3. How are achievement and learning affected by resources?
4. How effective are the assessment and monitoring of learning?
5. How well do the programmes and courses meet the needs and interests of learners?
6. How well are learners guided and supported?
Leadership and management
7. How effective are leadership and management in raising achievement and supporting
all learners?
Each of the seven questions is set out in two parts: what will be evaluated in relation
to each question and the evidence that might contribute to the judgement. For example,
under ‘How are achievement and learning affected by resources?’ (section
3) one of the two areas to be evaluated is ‘the adequacy and suitability of
staff’ and inspectors are asked to consider, where applicable, ‘the extent to
which:
| there are enough qualified and experienced teaching, training and support staff
matching the demands of programmes and the range of learners’.
|
|
|
NIACE
comment: The Framework has improved considerably since the first
version published in Inspecting Post-16 Education and Training in May, 2000. |
| 4.6 |
Section 1 covers achievement and standards, asks
for an evaluation of success in achieving targets, standards of learners’ work,
learners’ progress, and the development of personal and learning skills. |
|
NIACE
comment: It is unclear why success in achieving challenging targets includes
‘qualifications and learning goals’ when ‘learning goals’ is defined
under ‘terms’ at the beginning of the document as qualifications. This seems not
only tautologous but over-emphasises qualifications, when successful achievements should
be evaluated more broadly.
For some short courses it is difficult to evaluate prior attainment and potential of
learners; perhaps ‘learners’ progress’ (bullet point 3) should read,
‘where applicable’.
It would be helpful to see ‘achievement of challenging learning goals’ at the
start of the list of evidence, instead of following retention, trends in performance, and
analysis of added value, given that this is the most important item for learners.
It is unclear what ‘standards are consistently high across the provider’s
work’ actually means. |
| 4.7 |
Section 2 covers effectiveness of teaching,
training and learning. The key items to be evaluated are how well teaching meets
individuals’ needs and course requirements, and how well learners learn and make
progress. The evidence asked for is about the knowledge of staff, planning of programmes,
methods of teaching, challenge to learners, use of assignments, individual learning plans,
relationships, and sensitivity to equal opportunities. |
|
NIACE
comment: In addition to acquiring knowledge and skills, knowing how they are
progressing, applying effort and using time effectively, learners also need to enjoy their
studies. Some mention of finding learning inspiring or stimulating would help to remind
providers of the broader Government vision set out at the start of the Learning Age, leading
to the development of individual confidence and the wider benefits of learning. |
| 4.8 |
Section 3 covers the effect of resources on
achievement and learning and evaluates suitability of staff and specialist equipment,
resources and accommodation. |
|
NIACE
comment: It is unclear why learners with learning difficulties or
disabilities are singled out. The document states that learning resources and
accommodation should allow these learners in particular to participate fully. This applies
to all learners. In fact the word ‘allow’ appears patronising when applied to
just this group of learners and we suggest this should read, ‘allow all learners to
participate fully’ or ‘encourage all learners to participate fully’. |
| 4.9 |
Section 4 is about the effective assessment and
monitoring of learners’ progress. The rigour of assessment and use of assessment to
plan and monitor learning is the main focus. |
|
NIACE
comment: It is surprising that monitoring of learners’ progress is not
a key evaluation bullet point in its own right. It is not just the use of assessment in
relation to monitoring progress that matters but monitoring progress of individuals itself
is vital.
It might be helpful to differentiate between initial assessment and other forms of
assessment, to distinguish assessment from achievement. In fact ‘assessment’
might be defined helpfully under ‘terms’ at the start of the document.
We suggest that monitoring individual progress and informing learners clearly about
their progress are two distinct things and should be separated. It is odd to see that
parents and employers should be ‘clearly and regularly informed about learners’
progress’ but individual learners themselves are only ‘informed’.
It would be helpful to state that initial assessment should pay due regard to the
learner’s prior experience. |
| 4.10 |
Section 5 is about how well programmes and
courses meet the needs and interests of learners. Inspectors are asked to evaluate the
match between programmes and learners’ aspirations, and how far programmes meet
external requirements and local circumstances. |
|
NIACE
comment: It would be helpful to include under the evidence for making
judgements that learners should have the opportunity to study ‘an appropriate range
of courses or individual learning programmes’, which would be helpful for
those learning in less traditional settings, such as learning workshops.
Some explanation of what is meant by curriculum or programmes of work being
‘socially inclusive’ would be helpful.
Some explanation of what is meant by ‘courses or programme
of work’ and ‘enrichment activities’ would be useful under ‘terms
explained’ at the start of the document. |
| 4.11 |
Section 6 is about guidance and support.
Evaluation questions focus on the quality of information, advice and guidance to learners
and career progression; the diagnosis and provision of individual learning needs; and the
access to support on personal issues. |
|
NIACE
comment: It would be helpful in the Framework to refer to the work of
the Guidance Council Accreditation Board and its responsibilities.
There is a need to recognise the importance of guidance and advice in relation to
non-standard provision such as that made by learndirect.
Some clarity about expectations on part-time as well as full-time provision would be
helpful.
It would be useful to add the phrase ‘learning’ so that learners received
‘effective additional learning support’.
’. |
| 4.12 |
Section 7 appears the longest section because it
incorporates management, governance, quality assurance, and value for money. The key
questions are about how well managers set a clear direction, the effectiveness of quality
assurance including self assessment, promotion of equality of opportunity, how well
governors or boards meet their responsibilities, and the effectiveness and efficiency of
deployment of resources to achieve value for money. |
|
NIACE
comment: It may be helpful to define the term ‘supervisory board’
or use the phrase ‘management board’ as opposed to ‘supervisory’ since
in most voluntary organisations a board of directors or management board is responsible
for the strategic direction of the provider.
The ‘best value’ concept may need explanation, especially to those not in
local authorities. |