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Response to Ofsted’s proposed Education Inspection Framework

Whole Education
Response to Ofsted consultation on new
Education Inspection Framework
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Response to Ofsted’s proposed Education Inspection Framework

To what extent do you agree or disagree with the proposal to introduce a ‘quality of
education’ judgement?

(Proposal 1: introduction of 'quality of education' judgement)

Strongly agree

Whole Education, following conversations with a number of our schools, welcomes this new focus on
the overall quality of education. We have been campaigning for a number of years for a focus on the
full richness and breadth of a school’s curriculum, a fully rounded (or ‘whole’) education.

We agree with the broad analysis of the framework and HMCI’s speeches that there has been an
unintended narrowing of the curriculum in some schools. Whole Education was set up to respond to
this concern; that pressures in the system led schools in some places to focus on exam results at the
expense of maintaining a fully rounded entitlement. Our schools have reported this new emphasis in
the draft framework gives them ‘confidence’ to be braver with their curriculum

Our conversations with experts at organisations like the Royal Society, the CBI and the OECD, and
with school leaders across our network has affirmed that a fully rounded education is the only way to
sustainably narrow the gap and prepare all young people for their futures. We believe a judgement
taking a view on a school’s broader quality of education is therefore extremely positive.

We are also of the belief that with such a large proportion of schools in the system good or
outstanding, it is the right time for this shift to a model that affirms the qualities of the system - rather
than a narrower deficit model. Over time Ofsted’s focus on supporting the richness and breadth of a
school’s curriculum can help create a supportive climate for schools to develop sustainable approaches
to what we would call a ‘whole education’

Quality of education is not a quick fix- it can instead give permission and direction for the system.
Crucially, it also encourages ambition in schools’ approaches, and can support the development of a
mature self-improving system.

This is to be welcomed, and we are extremely positive that Ofsted has been clear this cannot happen
overnight – and that schools who are moving in the right direction will be supported on that journey.
The fact that schools in the first year of the new framework will not suffer if they do not have their
curriculum “finished”, and that the focus will instead be on positive progress towards a quality,
sustainable curriculum, has given secondary schools that we have spoken to confidence that the new
framework will be implemented in a fair and realistic way. This should also help to mitigate workload
concerns around potential pressures of the inspection process - especially for small primary schools.

Schools in our network have however highlighted a fear that there could be perceived to be a preferred
way to design a quality curriculum - a so-called ‘Ofsted curriculum’. Ofsted’s reassurance and
challenge to this has been helpful, and further explicit acknowledgement would be welcomed. We
perceive a danger that because an approach is often implemented badly, it could become devalued or
seen as inherently flawed. We believe that, as Ofsted’s ​intent-implementation-impact​ framework
recognises, the quality of implementation is where curriculum choices succeed or fail. It is again
positive that the framework explicitly says very different curriculum approaches will be judged fairly;
this emphasis is crucial in achieving widespread buy in for this new, positive, focus on schools finding
the best ways to deliver a curriculum that is broad and balanced, deep and rich in their context.
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Response to Ofsted’s proposed Education Inspection Framework

To what extent do you agree or disagree with the proposed separation of inspection
judgements about learners’ personal development and learners’ behaviour and

(Proposal 2 : separation of judgements)

Strongly agree

We would support anything that encouraged and promoted a focus on learners’ wider development -
that highlighted the need and importance of a focus on learners’ character, and their wider attributes
like resilience. Informal conversations with school leaders from the network have reinforced this

We are delighted to see personal development explicitly mentioned, privileged and highlighted, as
Whole Education schools view it as central to their goal of a high quality education.

We note that behaviour and attitudes are more easily measured than personal development so we are
optimistic than separating the two prevents personal development simply being swallowed by, and
therefore lost within, behaviour statistics.

As the separation is clearly to some extent artificial, we see it as a validation of the vital importance of
schools focusing on learners’ personal development. By highlighting these elements it encourages and
promotes, rather than simply assessing, what is inevitability a qualitative judgement
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Response to Ofsted’s proposed Education Inspection Framework

To what extent do you agree or disagree with the proposed focus of section 8
inspections of good schools and non-exempt outstanding schools and the proposal to
increase the length of these inspections from the current one day to two days?

(With reference to proposal 4: increasing short inspections from one day to two days)

Strongly agree

We welcome this. Primary leaders in our network did caution that managing this longer process in the
smaller schools could be difficult but overall the reception has been generally very positive.

Assessing the quality of education - a school’s curriculum intent, implementation and impact - is
complex and nuanced. Longer inspections are a positive signal to us that this is being treated with
seriousness and rigour.

The proposal also gives our schools confidence and reassurance that there will be space and time for
rich conversations and for their curriculum intent, implementation and impact to be explored more

The main concern about the new framework for schools in our network is around the capacity and
consistency of judgements, and longer inspections help to mitigate this concern.
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Response to Ofsted’s proposed Education Inspection Framework

To what extent do you agree or disagree with the proposed introduction of on-site
preparation for all section 5 inspections, and for section 8 inspections of good schools,
on the afternoon prior to the inspection?

(​Proposal 5: on-site preparation)​

Strongly agree

We are positive about this proposal, as the logic of on-site preparation suggests a more collaborative
approach. Moving preparation in to the school suggests that there will be a greater emphasis on
dialogue prior to the beginning of the inspection to help refine lines of enquiry and test hypotheses

School leaders in our network say that it would help them feel like they were working in partnership
with a shared goal - helping schools offer a high-quality, rounded education to all- which is

We have spoken to our school leaders who have been through recent Ofsted inspections, and a
number have commented that they have already noticed a greater focus on positive, collaborative
conversations with HMIs. They have felt like they are having a constructive but challenging
conversation about the choices they have made, the reasons for their decisions, and how they
contribute to delivering a high-quality education in their context.

To the extent this move will support further such conversations and greater dialogue, we would
strongly support the proposal.
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Response to Ofsted’s proposed Education Inspection Framework

To what extent do you agree or disagree with our proposal not to look at non-statutory
internal progress and attainment data and our reasons why?

(​Proposal 6: non-statutory internal progress and attainment data)​

Strongly agree

We particularly welcome this move. It should have a positive impact on the workload of the education
workforce at a time when this is a system-wide priority. We also argue that it can empower schools to
focus on delivering a high-quality, rounded education, and to hold themselves to account for offering
such an education to all their learners.

We have long argued for a shift from data-driven to data-informed leadership. An overly narrow focus
on a small range of data sets tends to incentivise a standardised, one-size-fits-all approach to
curriculum design.

We believe this proposal could support greater self-accountability for leaders, and create the
conditions for them to be braver and make the right choices for their learners, in their context.

It would allow leaders to be selective, choosing the data and planning information they wish to present
to support areas of enquiry. This would help them to illustrate and demonstrate their school’s
curriculum narrative (or curriculum intent) as part of wider conversations around the kind of
education that is right for their learners, in their context.

The priority should be for schools to ensure their individual and groups of learners are on track to
make good progress in the areas that they have chosen to focus on. School leaders in the Whole
Education network have noted that this change would empower them to hold themselves and each
other to account, and help them tell the story of the choices their school has made- as they move away
from demonstrating what they believe ‘Ofsted wants to see’ and instead demonstrate how they are
offering a high-quality education to their learners, in their context.
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Response to Ofsted’s proposed Education Inspection Framework

Draft school inspection handbook. Please use this box to record any additional
comments in relation to the detail set out in the draft school inspection handbook

WE are extremely positive about the content of the draft framework. The tone and principles are
notably different from previous frameworks, with one school highlighting that there were more
references to values and values-led leadership. Combined with the quality of education judgement,
this suggests the framework will support a shift towards helping leaders to offer a curriculum that
resonates with the reasons they entered the profession.

The draft frameworks clearer language and greater length and detail suggest a more open and
transparent process. There is also a laudable focus on what Ofsted ‘does not’ do, ask for or assess,
which helps to dispel myths around inspection and support a more open and transparent process.

Our schools have told us that their main concern is the tensions between the draft handbook’s stated
intention to treat all schools fairly- even if they have chosen less mainstream or unusual curriculum
approaches- and in some cases an attempt to define what that curriculum should look like
(particularly in the language around numbers of learners on an Ebacc curriculum and in discussion
around a 3 year KS4).

We would strongly come down on the side of there being few inherently bad curriculum approaches,
and the implementation of the strategies being of far greater importance. We argue that there are not
inherently ‘bad’ answers to key curriculum questions - like that of a 2 or 3 year KS3, or number of
students on an Ebacc curriculum- only decisions implemented badly, and downsides of any change
not being taken account of.

There are many examples in the system of a rich and engaging 3 year KS4, and many examples of a 2
year KS4 where students still spend too much time doing GCSE past papers. We encourage schools in
the WE network to think instead of a 5 year curriculum, and to think in terms of clear progression -
building on knowledge, skills, and qualities. Similarly, in our network there are many examples of
schools where despite low numbers of pupils on an Ebacc curriculum, they are all receiving a
high-quality ‘whole education’, with rich parallel curricula options and engaging vocational

However we are hopeful this tension will be picked up in the conversations between inspectors and
school leaders around their intent and implementation - explaining the choices they have made, and
why they are the right ones for that school’s community. We are hopeful the framework will support
school leaders’ autonomy to make the right decisions for their context, and welcome Ofsted’s
clarification there will not be any (explicit or implicit) ‘Ofsted curriculum’.

We also broadly welcome the banding definitions, and hope they are in the public domain. They could
then lead to a holistic approach that focused on the whole child.

This is the aim of a quality education, and it is also the aim of educators in schools across and beyond
the Whole Education network. There is therefore much to welcome in the draft of the new handbook,
and each of the proposals we would be generally supportive of, and encouraged by.

The Whole Education network would welcome the opportunity to work with Ofsted on
the ongoing opportunities and potential of the new framework to support schools to
offer a fully rounded, quality education to all.
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