On 16 January 2019 Ofsted published a draft of its new Education Inspection Framework (EIF) which is due to come into effect in September 2019. This will replace the current Common Inspection Framework (CIF) which was published in 2015.
Like the CIF, the EIF is a fairly high level document, as it needs to cover all types of education settings from early years, through to schools and further education settings. What is important for our sector is the detail of how the EIF will work in practice, and this is set out in a new version of the Early Years Inspection Handbook. The draft of the EIF and the new Handbook are out for consultation with feedback closing on 5 April 2019.
Why participate in the consultation?
The proposed changes to the EIF and the Handbook will come into effect from this September and will affect how your club is inspected. This is your opportunity to influence the inspection criteria, so it's worth taking a few minutes to send in your feedback.
You can submit your feedback using an online form, or you can download the questionnaire as a Word document and return it to the consultation team via email. There are only a couple of questions which apply to early years settings so it doesn't take too long to complete the questionnaire.
We have reproduced our own responses to the questionnaire below to highlight our main areas of concern. You are welcome to re-use these points in your own feedback if you wish.
Key issues for out of school clubs
The EIF introduces five new judgements which are similar to those in the CIF, but not identical. Most notably the old 'Outcomes' judgement has disappeared, and has been replaced by a new 'Quality of education' judgement. This is relevant to out of school clubs because under the current Early Years Inspection Handbook, out of school clubs are explicitly exempted from the 'Outcomes' judgement. However the new Handbook does not contain an equivalent exemption for the 'Quality of education' judgement.
In the consultation questionnaire, our response to Proposal 1, which relates to the 'Quality of education' judgement, was:
"This new judgement appears appropriate for educational settings, however this judgement will be irrelevant to settings which are not educational in form, specifically breakfast, after-school and holiday clubs.
If this judgement is retained in the final version of the EIF, there should be an explicit exemption for non-educational settings such as those outlined above.
In the current version of the Early Years Inspection Handbook, the ‘Outcomes’ judgement is explicitly excluded for wraparound settings and we would wish to see a similar exclusion continued in the new version of the Handbook. This is to ensure clarity and consistency across inspections, and to remove any doubt about what is expected in terms of ‘education’ from wraparound settings."
We had no particular objection to Proposal 2 in the questionnaire, regarding the division of judgements into separate 'Personal development' and 'Behaviour and attitudes' judgements.
Proposal 3 in the questionnaire is the most important for out of school settings, as this covers the use of the 'Quality of education' judgement in the inspection of Early Years settings. Interestingly the questionnaire separates out responses to this particular issue by the type of childcare setting. This enables out of school clubs to declare that they 'strongly disagree' (if indeed they do so) that the new judgements will work well for their type of setting.
With regards to this proposal we commented:
"The ‘Quality of education’ judgement is totally inappropriate for wraparound settings as they exist to provide childcare before and after a day at school. They are not there to provide more education beyond the school day.
The remaining four judgements would in the most part be applicable to wraparound settings, although whether such a level of detail is required for short-term, sessional, play-based provision is debatable. A simpler set of criteria, such as those used to evaluate settings on the Childcare Register, would be more appropriate."
We then went on to provide more detailed feedback on specific sections of the new version of the Handbook:
"Para 114. The current version of the Handbook contains clear guidance for inspectors (set out in paragraphs 120-123) on how to judge before, after-school and holiday provision. It states clearly that inspectors should not make a judgement on ‘Outcomes’ and that they should not seek evidence that relates to learning and development goals, nor set any actions relating to these.
These paragraphs have been compressed into a single paragraph (para 114) in the new version of the Handbook, thereby reintroducing ambiguity which is not helpful for either settings or inspectors.
We would like to see the explicitly worded exemptions for wraparound settings being retained in the new version of the Handbook, so that there is never any doubt that inspectors should not be making judgements based on the learning and development requirements, nor on planning or assessment.
Page 31 As mentioned earlier in this response, the entire Quality of education judgement is not relevant to wraparound settings. This judgement should be excluded from the overall inspection result, just as the ‘Outcomes’ judgement is currently ignored.
Para 97. The introduction of the last two sentences means that a setting can be judged as ‘requiring improvement’ even if there are no breaches of statutory requirements. Is it fair that a setting that is meeting statutory requirements is labelled as ‘requiring improvement’? This label has such a negative connotation to parents, and therefore has the potential to affect the financial viability of a childcare setting even though it may in fact be meeting all statutory requirements."
Proposals 4 to 10
These relate to educational settings other than early years settings, on which we are not qualified to comment.
Ofsted is proposing to extend the timescale within which they reinspect providers judged 'requires improvement' from 12 -24 months, to 12 - 30 months. We disagreed with this proposal as it will leave settings stigmatised with a 'requires improvement' label for longer than necessary. For PVI settings such as out of school clubs, this risks affecting their financial viability. Also as we noted above, a setting can be judged 'requires improvement' even if they are meeting all the statutory requirements. We commented:
"The original time frame is more than sufficient to allow improvements to be made.
More importantly, extending the time period would leave children receiving poor or substandard education or care for an extended period of time. Thirty months is a significant proportion of a child’s school career."