The Common Inspection Framework: For Inspection, Education and Training

1. Introduction

NIACE welcomes the review of the Common Inspection Framework and shares the view that the Framework has come to be seen as a success in all parts of the Learning and Skills Sector. In our response NIACE identifies a number of strengths in the changes but some concerns too. In addition, NIACE has a concern about how the two inspectorates will operate the Common Inspection Framework. Although this is not requested, we consider that the earlier consultation on changing the methods of inspection was not as robust as it might have been and have made a specific comment on this at the end.

2. About NIACE

The National Institute of Adult Continuing Education (NIACE) works to encourage more and different adults to engage in learning of all kinds. Its functions include research, development, publishing and consultancy; advocacy to inform and influence public policy; information services, conferences and dissemination; campaigning for and celebrating the achievements of, adult learners. Established in 1921 NIACE is an independent non-governmental organisation, a registered charity and company limited by guarantee. Its corporate and individual members come from all sectors concerned with adult learning: colleges; local authorities; universities; voluntary and community organisations; churches and faith communities; broadcasters, employers and unions.

3. Key points

There are several strengths in the revised Common Inspection Framework:

NIACE has several causes for concern:

4. Strengths and weaknesses

1. The limited nature of the changes should make it possible to undertake broad comparisons of the performance of providers and the sector as a whole in successive inspection cycles. This is particularly important where new providers have not yet been inspected.

2. The inclusion in each inspection report of a clear judgement about overall effectiveness will be welcomed by the general public, policy makers and stakeholders. However, the wording of the overarching question is clumsy and the language used is unlikely to be accessible to all learners and sections of the community.

If the question is so complex and requires two questions, it is probably not the right question. In addition, the second question in relation to overall effectiveness is not matched by the explanation which follows. The first is about the steps which need to be taken to improve the provision while the evaluation seems to be about the organisation’s capacity to make improvements.

3. The tripartite emphasis on inspectors’ judgements of provision is welcomed. Judgements are to be made by observation, on provider capacity for self assessment, and on evidence that the provider has the ability to make improvements. The relative weighting given to these three elements in making overall judgements of effectiveness and efficiency will need to be explicit and consistently applied across the sector and over time.

4. The reduction of the seven questions in the current framework to five is welcomed. Also welcomed is the inclusion of assessment matters within the question about the effectiveness of teaching, training and learning. This is a sensible move since assessment ought to support learning.

5. Making more explicit the impact of resource management as it affects learning is an important change. The way in which resource management connects to the quality of leadership and management is important and so merging the previous question 3 in the new question 5 is welcomed. However, it would be helpful if inspectors were to take account of relative and comparative levels of funding for different types of provision, and the overall quantum of funding available to the provider as a result of these differences, when making judgements about value for money.

6. NIACE welcomes some of the broader “where appropriate” elements under each section. Several of these will enable inspectors to report on the wider benefits of learning which will be valued by providers and learners alike. Although intended for children and young people, in many cases they are equally applicable to adult learners. If providers use these and the “five outcomes” too, in their self assessment, it will offer a richer view of provision. It might be helpful if inspectors could evaluate effects about the level of the individual: whether the provision makes an impact on the community as well as “whether learners make a positive contribution to the community”.

7. The effectiveness of teaching, training and learning includes the intention that inspectors evaluate the “suitability and rigour” of assessment. It would be helpful to evaluate the effectiveness of assessment too, given the vital importance of formative assessment in some programmes, for instance in provision for adults with learning difficulties.

8. The value of making the Common Inspection Framework more relevant in a pre-16 context is recognised. However, the outcomes for children and young people which will be evaluated as part of joint area reviews will not be evaluated in the case of providers who cater exclusively for adults. As the current definition of “adults” in the Learning and Skills Sector context includes young people who are employed as apprentices, and some local authority providers may make provision for small numbers of young adults, it will be important to clarify at an early stage when liaising with providers due for inspection whether these outcomes will be evaluated.

The impact of judgements about services for children will be substantial. It will also be important to clarify how providers with only a small proportion of their provision accessed by young adults should take account of these wider outcomes when undertaking self assessment.

9. The removal of the guidance material currently shown in italics in the Framework makes the Framework more relevant to all ages of learners but it also serves to make the altering needs and expectations of adults less immediately visible. The change from mandatory guidance as provided by the material in italics currently to non-statutory guidance as proposed also runs the risk that the particular needs of adults, and factors relevant to provision for adults, may be overlooked when the new Framework is applied. This means that more detailed guidance will need to be available elsewhere. It will be important to ensure that the new non-statutory guidance is sufficiently differentiated to reflect the varied purposes that adults have when accessing learning. NIACE strongly recommends that draft guidance is shared with providers at an early stage to ensure its appropriateness and that it is agreed between inspectorates. Adults in colleges deserve the same consideration as adults learning in community settings: inspection should be the same kind of experience for both.

10. The use of a common grading scale on the part of both inspectorates and for the observation of teaching and learning, for areas of learning, for overall judgements about leadership and management and for overall effectiveness is welcomed. However, if there is to be only one grade for “unsatisfactory”, a clear indication in the text as to how unsatisfactory the provision might be, is needed in order for providers, stakeholders and learners, to have a better idea of how far the journey to “satisfactory” might be. To help providers in identifying areas for improvement, and to monitor and evaluate progress towards improvement, NIACE suggests that advice from inspectors must be based on a clearly written judgement as to what the distance of the journey might be.

11. NIACE accepts that in the context of the Skills Strategy it is appropriate and necessary for inspectors to evaluate the extent to which employment needs (as distinct from employers’) needs are met, where this is appropriate. Employers may not always be clear about what they might need; many providers work in a national environment and what matters to the economy is meeting not only present but future employment needs. In addition, it will be important that the non-statutory guidance to inspectors about how they are to apply the framework particularly with regard to matters of appropriateness makes it clear that many adults choose to participate in learning for reasons not directly related to employability or specific employment needs. Provision is therefore not always, and should not always, be designed to meet “employers’ needs”.

12. NIACE reiterates these concerns about the methodology of inspection. Our key concerns are mainly with Ofsted’s intended approach announced earlier in the year, and include

i) Too little time to prepare
Changes mean the scope for inspection may be narrowed to the “easy to inspect” and ignore part-time provision. Why Ofsted offer 3 weeks and ALI far longer is not understood. Adults in colleges and in community provision deserve to be treated fairly across both forms of provision.

ii) Ofsted and ALI wish to vary the intensity of inspection
Quite properly the inspectorates will vary intensity according to need. This may mean too much variation which could be inequitable.

iii) Ofsted wish to do less classroom observation
Effective teaching and learning in a college’s core business. Adult learners expect this scrutiny and teachers value it. Indeed, it may be the only truly independent feedback they receive in their careers. Performance data can only be a proxy for the effectiveness of teaching and learning and there is no external accreditation in some programmes or for some learners.

iv) “College inspector” role
It is unclear what value an Ofsted inspector visit once a year will have. It is too long a gap; colleges are too complex for an inspector to see anything useful in one day; and it is unclear how effective this “assessment” will be. If one in ten colleges are being judged “inadequate” the public deserves an inspectorate that provides more monitoring and support, not less.

v) The self assessment report
Although inspectors will not “validate” the self assessment report, it is unclear what place the report will have and how it will be validated. If it is to be published it is unclear how the public and learners can trust its judgements. If there is to be less observation of teaching and learning it is hard to see on what basis the inspectorates’ judgements will assess the process of self assessment.

vi) At no point have the inspectorates set out how they wish to see the value for money and effectiveness of inspection independently evaluated across the country. With two inspectorates working in different ways and a slimmer Framework there is more need for independent evaluation than before.

Note for readers

The Common Inspection Framework is to be reviewed. The two inspectorates, Adult Learning Inspectorate and Ofsted, have set out during 2004 their approaches to inspection. These approaches differ. The revised Common Inspection Framework (CIF) has been offered for consultation to which the above is NIACE’s final response.

In addition to the response on the CIF a comment on concerns about methodology is added, even though this has not been requested. This is because very few national organisations or providers were aware of the consultation on methods since it took place in the summer holiday period.

I am grateful to the work of Kate Watters who contributed much to the attached document, and to the NIACE consultation conference held in November at which many attendees supported the comments attached. The response was agreed at NIACE’s Policy Committee in December 2004.

Any further clarification may be obtained from Peter Lavender at NIACE.

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