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PACEY’s submission to Ofsted’s inspection consultation

From September 2019, Ofsted will change the way it inspects schools, colleges, further education institutions and early years settings in England when the common inspection framework (CIF) is replaced by the education inspection framework (EIF). 

Ofsted has published a draft EIF, along with a draft early years inspection handbook. To find out more about the proposals, read PACEY’s guide.

PACEY has responded to the consultation based on feedback from members. It closes just before midnight on 5th April 2019.

The key points made in our submission are:

  • PACEY cautiously supports the proposal to introduce a ‘quality of education’ judgement in early years inspections. The majority of practitioners we have spoken to welcome the opportunity for inspections to focus on what they perceive to the heart of their job: how they are helping children to learn and develop.
  • Ofsted’s plans to reduce its focus on data, particularly internal progress data, is positive. However, an increase in support for training and qualifications is essential to give practitioners the confidence to cut down on unnecessary tracking and assessment, and develop their expertise around effective curriculum planning, design and implementation, which has not been a key focus of their training to date.
  • It is vital that Ofsted ensures the new framework is supportive of a wide range of flexible approaches to planning, leading and reviewing purposeful play opportunities. We are concerned that the language used in the draft framework materials implies a formality that does not exist in many early years settings, particularly very small ones.
  • PACEY strongly disagrees with the inclusion of ‘cultural capital’ in the framework for early years inspections. There continues to be a widespread confusion about what it means in practice, and ‘culture’ itself is highly contestable. Inclusion of ‘cultural capital’ could serve to lead to some children, families and practitioners being labelled culturally deficient, and to advance a predominantly white, middle class model of ‘culture’.
  • PACEY strongly disagrees with the proposal to separate inspection judgements about children’s personal development and children’s behaviour and attitudes. In our view, these two areas are inseparable in the early years. Behaviour and attitudes are a vital component of personal development. In addition, many of the grade descriptors under the ‘behaviour and attitudes’ judgement are not supported by child development.
  • Settings should not be penalised by Ofsted for children’s attendance, or for not offering the early years entitlements, both of which are voluntary. There are a number of legitimate reasons why settings may not be able to offer the entitlements, for example due to the low hourly rate or administrative barriers.  
  • The ‘leadership and management” judgement still requires further refinement to be relevant to childminders without any staff. The new framework provides Ofsted with the opportunity to provide greater clarity about what leadership and management looks like in a small childminding setting.
  • One of PACEY’s most pressing concerns relates to the significant discrepancy between the early years handbook and the early years section of the schools inspection handbook. The two sets of grade descriptors effectively create a two-tier early years system with different requirements based on the type of setting a child attends. We call on Ofsted to revert to the status quo and use the same grade descriptors in both handbooks.
  • Inspectors should not be required to consider how well staff read aloud or sing songs. It is legitimate to ask practitioners about the extent to which these activities take place in the setting, and the impact this has on children’s learning. However, they should not be required to be on display during the inspection (though they often will be).
  • Ofsted should reinstate the requirement for inspectors to familiarise themselves with the setting’s educational and/or philosophical approach before the inspection, and note it in the report. Given the framework’s renewed emphasis on curriculum planning, design and implementation,  an inspector’s understanding of the setting’s educational and/or philosophical approach will be crucial to understanding why certain decisions about the curriculum have been made.