Ofsted: The framework for the inspection of initial teacher education 2012 A response on behalf of the Institute for Learning.

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Ofsted: The framework for the inspection of initial teacher education 2012 A response on behalf of the Institute for Learning January 2012 Page 1 of 14

CONTENTS Section Title Page 1.0 Who we are 3 2.0 Survey Introduction 4 Question 1 Overall Effectiveness 5 Question 2 Quality of Outcomes for Trainees 6 Question 3 Quality of Training Across the Partnership 7 Question 4 The Effectiveness of Leadership and 8 Management Question 5 Risk Assessment 8 Question 6 Outstanding and Good Partnerships 9 Question 7 Inspection of Satisfactory Partnerships 10 Question 8 Gathering Inspection Planning Information 10 Question 9 Preliminary Telephone Discussions 11 Question 10 Reduction of Notice Period 12 Question 11 Inspection Activities 13 Question 12 Awarding Body Provision 13 Page 2 of 14

1.0 Who we are The Institute for Learning (IfL) is the professional body for teaching professionals in further education and skills. IfL welcomes the opportunity to contribute to this important consultation on proposals for the inspection framework for initial teacher education. We are keen to ensure that the voices of teaching professionals in the sector is heard in this process as entry to the profession and initial training is a central issue. Furthermore, we see the quality of initial teacher education as a crucial element in the FE and skills sector attracting the very best new teachers and trainers and in securing the sustainability of a professional workforce; something that, as a professional and regulatory body, we take very seriously. We believe that initial teacher education in the further education and skills sector, the vast majority of which is delivered as in-service training, should be the first step in a journey of continuing professional development. Making the decision to give something back to your specialist field, e.g. engineering or hospitality and catering by becoming a teacher or trainer should be an accessible and attractive career progression route for those in industry so that learners, and the industry professionals of the future, can benefit from the very best in teaching and learning. Teachers and trainers are also embedded in their communities, both professionally and locally. They enrich the lives of a hugely diverse range of individuals through an equally diverse offer of formal and informal learning opportunities. Every learner should have the right to a teacher or trainer that has received top quality initial teacher training and for a teacher or trainer to be fully supported in their own professional development as a dual professional; ensuring that those instilling a desire for young people and adults to be lifelong learners, also have the opportunities to be lifelong learners themselves. The inspection process plays a critical role in meeting these ambitions. We recognise that, for individual practitioners and their institutions, the balance between development opportunities and administrative duties is often weighted towards the latter. It is therefore important that inspection and the various other quality assurance and improvement mechanisms exist and are seen to be supporting teachers and trainers, rather than being seen to be working against them. We are grateful for the time given to us by Angela Milner HMI, Principal Inspector for ITE at Ofsted for meeting with IfL staff to discuss the proposals and surrounding issues. The views of IfL members have directly shaped this response and the recommendations we will make throughout; and we are grateful for the time and effort they put in contributing. Page 3 of 14

2.0 Survey Introduction Using online software, IfL has conducted a survey seeking the views of professional teachers and trainers on the new ITE inspection framework proposals. In order to ensure that our members were as informed as possible before submitting their views, we created a briefing outlining the key changes and included a link to the full consultation document. We made outline comparisons between the current framework and the proposed new framework so members could see clearly the key differences. We received a total of 296 responses from across our membership. The table below represents the breakdown of responses and the environments in which they teach or train. Type of institution Percentage of respondents Further education college 36.0% Work based learning 23.8% Adult and community learning 21.7% Other 9.4% Emergency and public services 4.6% Armed services 2.5% Offender learning 1.4% Specialist college for people with learning 1.0% difficulties and / or disabilities The top types of provider listed as other included higher education and school sixth forms. In order to gain a perspective of respondents experiences with initial teacher education, we then asked members whether or not they were a teacher trainer. Of those who completed this survey, 75% said that they were a teacher trainer compared with 25% who said that they were not. Whilst, when compared to IfL s membership figures, this is not a reflective sample because the number of teacher trainers are over-represented, this was intentional and due to the specific communications tools utilise to target teacher trainers as we believed they had extensive specialist knowledge and expert perspectives to bring. Page 4 of 14

Question 1 Overall Effectiveness To what extent do you agree or with our proposed approach to judging overall effectiveness? We agree with the new approach taken by Ofsted to have a single grade for overall effectiveness; and the approach taken to reduce the number of contributory grades from nine to three. Members commented that, whilst the framework itself is not necessarily simplified, the proposals placing a focus on successful outcomes, quality of training and quality of leadership and management provide a useful structure for other internal and external quality assurance and improvement mechanisms. It should be pointed at this stage, though this argument will develop later throughout the consultation, that the proposals do not sufficiently recognise the position that in-service teacher trainees are in when it comes to the proposed definitions of successful outcomes. The primary definition, how well trainees can teach by the end of their training is clearly the most important one and we are reasonably satisfied in the approach to be taken by Ofsted under the new framework for measuring and reporting on this. Measuring and reporting on other set definitions of successful outcomes including timely and successful completion, employment rates and retention in the profession will present Ofsted, and teacher training partnerships, with particular challenges in relation to in-service ITE Ofsted must consider closely how it will define and benchmark what is a timely completion rate in relation to further education teacher trainees. The significant majority of FE teacher trainees complete their training in-service so, by definition, are already employed. Ofsted are correct to therefore define employability as progressing to achieve licensed practitioner status. This status, ATLS (Associate Teacher in Lifelong Learning and Skills) and QTLS (Qualified Teacher in Learning and Skills) are conferred by the Institute for Learning after the required level of initial qualification has been reached and a successful period of professional formation has taken place so that teachers can demonstrate their experience in applying good teaching practice in the working context. The very diverse nature of our sector allows for a variety of employment and working opportunities and patterns for teacher trainees and qualified teachers. There will be many teacher trainees who may take several years to complete the process. The current regulatory requirements are that teachers and trainers in the FE and skills sector employed since 2007 should gain licensed practitioner status within 5 years. We would suggest that Ofsted take this into account when developing guidance for teacher training partnerships and Her Majesty s Inspectors. Page 5 of 14

Question 2 Quality of Outcomes for Trainees To what extend do you agree or with our proposed approach to judging quality of outcomes for trainees? Our survey demonstrated clear support for a single grade to judge the quality of outcomes for trainees. It is right that the quality of trainees practice is fundamental criteria in this category, a point raised by many respondents from our survey. We have chosen to overall with the proposed approach however because of our concerns about how some of the contributing criteria can be measured, and we hope to see these concerns addressed in later developments of the framework and in subsequent guidance for inspectors and teacher training partnerships. For example, there is an extent to which there is a systematic disconnect in the way that that trainees are selected between employers and teacher training providers. Further education teacher trainees often come from industry, and so teaching and training is a second profession. As such, the majority of teacher trainees start and complete their training once already in employment and, to that end, have been selected under the recruitment policies and practices of the employer rather than the teacher training provider. Therefore, as the impact of selection of trainees on attainment, completion and employment is a contributory factor to the overall grade of quality of outcomes; it is important that teacher training providers do not find themselves in a position where they could be penalised for selection processes that they, in practice, have had no participation. This will particularly be the case as Ofsted develop their inspection practices within awarding body provision. This point makes further measurement of attainment trends between identifiable groups of trainees difficult to measure. Drawing reference to the points we raised in question 1 with regards to our general problems with parts of Ofsted s definition of quality outcomes, we believe that the economic context, and the extent to which this is influencing and will continue to influence teaching and training contracts and ultimately trainees ability to complete their training in a timely fashion should be taken into consideration. It would be unfair for teacher training partnerships to be penalised because trainees are taking longer to achieve licensed practitioner status because of reduced teaching hours, or even redundancy, for example. Page 6 of 14

Question 3 The Quality of Training Across the Partnership To what extent do you agree or with our proposed approach to judging the quality of training across the partnership? There was general agreement that the proposed approach to judging the quality of training contributed sufficiently and robustly to the inspection process. Respondents from our survey commented specifically about the contributory factor of ensuring a consistent high standard of teacher education across the partnership by looking at the quality of training and its impact on outcomes by all trainers. There is continuous debate about the extent to which measuring quality against the acquisition of qualifications is effective. Some argue that this pushes grade inflation while others will argue that it is the only tangible way to monitor quality on the scale that is required. In this case however, it can be argued that because the licence to practise is achieved through the process of professional formation and gaining the professional status of QTLS or ATLS, and maintaining the licence through CPD which follows the acquisition of the teaching qualification that it is even more important that there is confidence in internal and external quality assurance and improvement processes. One area where there is a clear link between the judgements in this category and the effectiveness of leadership and management is related to the contributory criteria, trainees are supported to develop effectively their pedagogical subject knowledge. One of IfL s key functions as the professional body is ensuring that all teachers and trainers have the opportunity to continually develop their practice. We believe that teacher training should instil a culture in teacher trainees themselves maintaining their standing as lifelong learners so we would argue that this should be made more explicit in the inspection framework. Initial teacher education has to set in a very robust way the expectation that every teacher or trainer in FE skills will be expected to keep up to date in their subject and their teaching methods throughout the rest of their career in teaching. Of the three inspection activities listed in the description of this category, it would seem that the majority of contributory criteria must include interviews or face-to-face activities with teacher trainers and trainees. This is particularly welcome given that the views and experiences of both parties must be interpreted as a measure of the quality of training, arguably more so than completion and attainment rates. We would welcome also the emphasis placed on employers to demonstrate that teacher trainees gain sufficient highquality practical experience to develop their teaching for the full range of learners. A good breadth of teaching practice is essential in ITE. Page 7 of 14

Question 4 The Effectiveness of Leadership and Management To what extent do you agree or with our proposed approach to inspecting the leadership and management of the partnership? A significant majority of respondents to our survey agreed with the approach to inspection of the leadership and management of the partnership. As we have stated previously, embedding a culture of continuing professional development is crucial in developing a dynamic teaching and training workforce, responsive to both developments in teaching and training pedagogy and in advances in the vocational area(s) in which they specialise. We would urge Ofsted to include in this category, an expectation that the partnership will provide the ethos and commitment to CPD with its own teacher training workforce as well as amongst its teacher trainees. Question 5 Risk Assessment To what extent do you agree or with our proposed approach to risk assessment? A significant majority of respondents agreed with the proposed approach to risk assessment. In particular, we believe, as already described, greater engagement with teacher trainers and trainees will add value to the inspection process. Members did raise the difficulties that they believe would be faced by individual providers in being able to effectively track former trainees because it is not uncommon for further education teachers and trainers to work in multiple institutions, on sessional contracts or a combination of both. One area in which we believe that this part of the framework could improve would be to reconsider the line about new partnerships being unlikely to be inspected in their first year. Page 8 of 14

This raised questions amongst our survey respondents particularly in relation to awarding body provision in the context of the likelihood that this type of initial teacher education may become more common in our sector as a result of changes to higher education funding. As awarding bodies potentially move in to fill a gap where a University no longer offers FE ITE, it would be opportunities like this for Ofsted to ensure that the accreditation frameworks and quality processes within awarding bodies are operating effectively and from the outset of new awarding body provision. Question 6 Outstanding and Good Partnerships To what extent do you agree or with our proposals to inspect outstanding and good partnerships? When consulting members on the FE Common Inspection Framework proposals, and on these proposals, a more proportionate approach to inspection was supported in both cases. Respondents pointed out that resources must be placed where improvement will have the most impact, and with a caveat in relation to the inspection of outstanding providers. Under the Common Inspection Framework 2012 proposals, outstanding providers of further education and skills provision would be exempt from the Ofsted inspection cycle altogether. It has since become the case that a sample of outstanding providers will be inspected, as it the case in these proposals for initial teacher education provision. Fundamentally, our members are clear that at least a sample of outstanding providers should be inspected in an inspection cycle. Page 9 of 14

Question 7 Inspection of Satisfactory Partnerships To what extent do you agree or that our inspection of satisfactory partnerships should be based on the factors set out? The position of IfL members surveyed, as with the previous question, is generally supportive of the proportional approach being proposed as to the frequency, size and nature of inspections. This is repeated in responses to this question whereby a clear majority of respondents agreed with the proposals. We believe that when the new inspection framework is published, it is important that strengthened mechanisms to support satisfactory performing providers come alongside to compliment the more rigorous approach being implemented. Question 8 Gathering Inspection Planning Information To what extent do you agree or with our proposed approach to gathering inspection planning information? Whilst respondents reported that there was general agreement with the proposals on gathering inspection planning information, IfL believes that there are ways that others in the sector can work together to help reduce the administrative pressures on initial teacher education partnerships by co-operating to remove any duplication of data returns. IfL has taken on the work of Standards Verification UK in terms of maintaining the Register of Approved ITT Providers for the further education and skills sector. We are aware that a similar procedure exists in the schools sector and that there is a stronger link between the TDA and Ofsted which we believe should also exist in our sector. Not only will this ensure Page 10 of 14

that IfL and Ofsted will work together to reduce the duplication of data return, it can mean that data sharing can ensure dedicated support for improvement and better targeted strategies for development. Other partners can include Ofqual who maintain a register of approved further education initial teacher training awarding bodies. Question 9 Preliminary Telephone Discussions To what extent do you agree or with our proposed approach to replacing the preliminary on-site visit with telephone discussions? Even though a majority of members agreed with the proposals to change the preliminary discussions from a visit to a telephone call, of all the pre-inspection activities this was the one that received the highest number of and strongly responses. The comments left by respondents to this question highlight that the preliminary visit is an important part of effective planning and preparation and demonstrate that, whilst as a headline proposal it can appear appealing, many believe that the visit is the most effective way of ensuring that the right preparations can be made as it is often easy to over-prepare, putting unnecessary pressure on staff. IfL would recommend that the new framework retains the provision for a pre-inspection visit for providers previously judged satisfactory or inadequate. Ofsted should consider whether or not a telephone call can effectively prepare inspectors given some FE initial teacher education partnerships are large and complex networks. Some members suggested that Ofsted should take a phased approach to this change particularly in light of the reduced notice period also being proposed. Page 11 of 14

Question 10 Reduction of Notice Period To what extent do you agree or with our proposal to reduce the eight-week notice period to three weeks? The results of our survey show that there was a majority opinion in support of reducing the notice period for inspections from eight weeks to three. Respondents reported that a reduced notice period would remove a prolonged period of stress and anxiety, would put legitimate expectations on preparation activities and would provide more accurate judgements. We would expect that, with the greater focus on quality, outcomes and leadership and management, a period whereby initial teacher education partnerships could ensure that they have adapted their own internal quality policies and procedures to reflect the new framework before the time when they are likely to be inspected. It is vital that sufficient emphasis is placed on the process of direct observation and other related activities are seen to be supportive of teacher trainers and trainees and not as part of a system that works against them. We would emphasise therefore the need for inspectors who are expert in initial teacher education in the FE and Skills sector, and the need for feedback from every observation is crucial so that the teachers of ITE can learn from this feedback and further improve practice. Page 12 of 14

Question 11 Inspection Activities To what extent do you agree or with our proposed approach to inspection activities? Respondents to our survey, when asked about the proposed approach to inspection activities, were generally in agreement. The proposals provide a breadth of inspection activities which will provide Ofsted with a sound base to provide overall judgements. Concerns have been raised however over the extent to which the teaching experience of trainees can be accurately assessed in comparison with the likely scenarios they will experience as practicing teachers. Further education teachers and trainers often find themselves teaching at different levels and will be under varying expectations under different types of contracts. It is important therefore that the new inspection framework for initial teacher education recognises that the needs and experiences of a part time trainer, compared to someone teaching full time in a college. Question 12 Awarding Body Provision To what extent do you agree or with our proposed approach to inspecting awarding body provision? Whilst we can welcome the proposal for Ofsted to begin to inspect initial teacher training accredited through the awarding body route, we do not believe that the proposals go far enough. Respondents to our survey confirms IfL s long standing principle that initial teacher training qualifications in further education and skills should be subject to consistent standards and therefore the same level of public scrutiny and quality assurance. This is currently not the case as the system, as a whole is fragmented with teacher training partnerships having to Page 13 of 14

maintain different relationships with different organisations, largely not in the public domain. For example, awarding bodies are required to demonstrate that they conform to their Conditions of Recognition in order to be sanctioned by Ofqual, partnerships then need to conduct processes to demonstrate compliance with the awarding body s own quality procedures. On the face of it this should be sufficient, but these processes are no-where near as transparent as the Ofsted inspection framework and, in a small number of cases, have led to teacher trainees being unable to be certified because of, for example, unaccredited delivery centres. Teacher training qualifications are, we would argue, the most important qualifications awarding bodies offer. We believe it is in the interest of teacher trainees, and indeed the public therefore, that there is a consistent and transparent approach to quality assurance which would mean that awarding body provision should be integrated further in to the Ofsted inspection framework than is currently being proposed. Page 14 of 14