UCET's response to the Ofsted consultation
Summary
A copy of UCET's response to the Ofsted consultation in March 2025.
A copy of the response is below.
27 March 2025
Sir Martyn Oliver HMCI Office For Standards in Education Petit France London SW1H 9EX
Dear Sir Martyn,
UCET response to Ofsted consultation
We are very grateful to have the opportunity to comment on the proposals relating to ITE inspections as set out in the documents published on 3 February 2025. Some of the key points we would like to make are outlined in this letter, with further details at Annex A. A copy of our full consultation response, as submitted on-line, is attached at Annex B.
We welcome the statement in the Developing Teaching section of the school’s toolkit that: ‘Leaders engage with initial teacher training, the early career framework and national professional qualifications to provide a coherent development pathway for all staff’. This will encourage high-quality schools to participate in ITE and offer placements to student teachers and, in doing so, enhance the experience of student teachers and help with recruitment. The same expectations should also apply to toolkits for the early years and FE settings. Other proposals that we welcome include: the proposed ‘Done with’ rather than ‘done to’ approach to inspections; the fact that account will now be taken of local contexts and the needs of local communities; the emphasis on inclusion and the needs of disadvantaged learners; the SEND focus; that in the toolkit ‘compliance and safeguarding’ should be judged on a ‘met’ and ‘not met’ basis; and the commitment to minimising the workload involved with inspections. We are however concerned about some aspects of the proposals, particularly in regard to the toolkit for ITE (which we think might be more helpfully conceptualised as an ‘assessment descriptor’).
We do not think that the proposed 5-point scale for grading is appropriate for ITE and could, we fear, lead to some ITE providers reverting to the grading of student teachers’ work. We think that the ‘met/not met’ judgment to be used in respect of safeguarding would be far more appropriate to ITE. While we recognise the preference amongst parents for a simple scale of rankings for schools, this does not apply to ITE, where prospective student teachers (and partner schools and colleges) can refer to full inspection reports if they want to get detailed information about the quality of ITE provision. There is no reason why the same 5-point scale should be used for all sectors of education, and a ‘met/not met ‘approach would still allow for exemplary practice to be identified and promulgated. Consistency across the different sectors of education does not necessarily imply a uniform approach. If grading is to be used, we would much prefer a 3-point scale which is less subject to qualitative ‘grey area’ judgements and would help to ensure consistency in how grades are awarded to different providers.
The use of crude numerical output measures as metrics for quality would be a retrograde step which could have unintended consequences and could inadvertently lead to many providers being placed in the ‘attention needed’ category in some areas. There are also tensions between different aspects of what is being asked of providers, for example regarding maximising completion rates and being inclusive in respect of recruitment and retention.
Some of the metrics relating to completion will, contrary to the direction set by ministers and DfE, make ITE providers think twice before taking a chance on potentially marginal applicants, particularly in shortage subjects, thus harming recruitment and undermining the government’s policy objective to increase the size of the teaching workforce by 6,500. Conversely, it might make some ITE providers reluctant to counsel students for whom it becomes apparent, maybe after their first teaching practice, that teaching is not the right career choice for them, thus leading to unsuitable people entering the profession. References to ‘in a timely way’ could make providers reluctant to allow SEND students a break in their training, even though this can make it easier for them to finish their courses.
We do however recognise the intention behind these metrics, and we certainly agree that ITE providers should collect, reflect on and act on such data. We think Ofsted’s intentions could be met, without the negative consequences, by using the following measures instead:
‘Attention needed - leaders do not fully understand the reasons why some trainees have not been successful' or 'leaders cannot explain, and justify, why some trainees have withdrawn from the course' or 'robust processes are not in place to work with trainees when they are not making sufficient progress towards meeting the relevant teacher standards’.
The proposed metric regarding employability is also problematic, and we were pleased when it was removed as a measure when the current inspection framework was introduced. ITE providers should not be held to account for the employment of their former students when employment rates are dependent on a range of factors, including regional demand, school budgets and the balance of subjects they offer. New teachers, especially younger ones qualifying from HEI routes, often take time out, or work abroad, before taking a full-time teaching post in a publicly funded school in England. Some HEIs (for example those in border regions) recruit students from other jurisdictions and who go on to teach in those jurisdictions. Are such providers to be penalised? An alternative would be to draft a metric along the lines of: ‘ITE providers have a good understanding of local and regional employment contexts and their own employment outcomes and are able to advise and support their student teachers accordingly.’
References to SEND seem to have been transposed from those relating to school pupils with limited regard to the ITE context or to the fact that that student teachers must be able to demonstrate the capacity to meet the Teacher Standards and to teach effectively in the relevant phase or subject. The responsibilities of ITE providers to adult student teachers with SEND are different to those schools have for pupils with SEND.
References to ‘governance’ seem to assume that the governance of ITE is the same as for school governance, which it is not. The internal and institution-wide processes for university governance are of no direct relevance to ITE provision, where programmes are developed and overseen by partnership committees and structures involving colleagues from within ITE programmes and those from partner schools and colleges.
We would be happy to work with your colleagues to redraft the toolkit for ITE. As well as the concerns expressed above, and in the attached annex, it does appear that parts of the toolkit have been cut and pasted from other toolkits with limited account taken of the ITE context (for example, the use of ‘teacher’ rather than ‘teacher educator’) and there is too much fragmentation and repetition. The contexts of EYITT and FE & Skills provision also need to be reflected more explicitly and clarification is needed on whether separate report cards will be issued for QTS, FE & Skills and EYITT programmes.
We look forward to discussing these issues with you in greater detail.
Yours sincerely,
James Noble-Rogers
Executive Director
Annex A: Detailed UCET comments on proposed inspection toolkit for ITE
- The: ‘Attention needed – Some trainees, including those with SEND, do not achieve their qualifications/ professional status or complete their programme in a timely way or do not complete the course’; and -‘ Strong - Trainees achieve their qualifications/professional status or complete their ITE programme in a timely way’ descriptors are problematic It is entirely right that, for example after being on placement, some students decide that teaching is not for them or are counselled off programmes by their providers. The current proposals could either lead to providers being over-cautious about who they accept on to ITE programmes (and so impacting negatively on recruitment) or be reluctant to advise students to withdraw or transfer to another programme, even though concerns about their likely performance as teachers exist, which would be detrimental for their future pupils. ITE providers should not, be given perverse incentives to either reject potentially good teachers or to retain those who might not make good teachers. There would also appear to be an apparent tension between the ‘achievement' and 'inclusion' metrics, as providers are less likely to accept students from diverse backgrounds if those students being unsuccessful, or requiring a pause in their ITE, will result in a 'needing attention' grade. That said, we do recognise the intent behind the proposals and would suggest the following alternative formulation which should meet the same objectives: ‘Attention needed - leaders do not fully understand the reasons why some trainees have not been successful' or 'leaders cannot explain, and justify, why some trainees have withdrawn from the course' or 'robust processes are not in place to work with trainees when they are not making sufficient progress towards meeting the relevant teacher standards’.
- In a similar vein, the statement in the ‘trainee recruitment&
Downloads