Letter to Rt. Hon. Kit Malthouse, MP: Market Review appeals' process

24 November 2022

12 October 2022

Rt. Hon Kit Malthouse MP
Secretary of State for Education
Sanctuary Buildings
Great Smith Street
London SW1P 3BT

Dear Secretary of State,
I am writing to you to request reassurance and clarification about aspects of the appeals process against
the outcome of ITE Market Review accreditation decisions. As the current 20 October deadline for the
submission of appeals is imminent, the matter is pressing. These issues have already been raised with
your officials, alongside some more detailed questions.

We would like to request that the 500-word limit for appeals be increased for all providers, and that the
‘extenuating circumstances’ section that allows providers to make contextual points that extend beyond
the narrow remit of the formal appeals’ process are excluded from the word count. We would also like to
request that providers who are appealing against decisions in relation to more than one question are
allowed additional words, on the obvious grounds that they have more things to appeal against. We would
suggest a word limit of 1,000 (excluding extenuating circumstances) and a further 250 words for each
additional question. The deadline for submitting appeals should be extended. Any providers who have
already appealed at the time this change is made should be given the opportunity to resubmit.

An analysis of feedback received from Market Review assessors has led to a number of recurring points
being raised. These include: providers being marked down for failure to provide information not actually
requested; providers failing for not providing information despite it clearly being included, and indeed
signposted; inconsistencies in feedback provided during rounds 1 and 2, with round 1 feedback indicating
that the Quality Requirements had been met in particular areas, only for them to be raised as issues in
round 2; and the use of feedback that, because of its subjective nature, means that there is no evidence
offered as to why judgements have been reached.

We would welcome reassurances that these and other issues we have raised will be given proper
consideration by those responsible for assessing appeals, and that those individuals will have access to,
and take account of, information contained in round 1 and round 2 submissions in their entirety.

Yours sincerely,
James Noble-Rogers,

Executive Director, UCET