Concerns over Ofsted’s Education Inspection Framework

NDNA has responded to Ofsted’s consultation on the Education Inspection Framework. The changes are due to be implemented from September 2019. 

Among our concerns are the use of vague language which is difficult to interpret, the framework’s focus on good and bad behaviour and a lack of emphasis on child-centred learning.  Stella Ziolkowski, NDNA's Director of Quality and Training

Stella Ziolkowski, NDNA’s Director of Quality and Training said: “NDNA has responded to the Ofsted Education Inspection Framework consultation.  We have recently completed our north of England member events and have had a representative from Ofsted presenting the changes to the framework. Our members have had the opportunity to raise questions to Ofsted representatives at these events and we have encouraged members to respond too.

“Our main concerns are around the language of the new EIF which doesn’t reflect the language used in the level 2 and level 3 qualifications. Due to this there is a risk that practitioners will not interpret the EIF in the way that Ofsted intends. This could have negative unintended consequences as it is a very vague framework and its language is open to interpretation. 

“The focus should be on play and child-led learning rather than a sequenced curriculum which could leave children behind or more advanced children disenfranchised.

“We also are unclear why Ofsted’s emphasis is on good or bad behaviour – children exhibit behaviours for a number of reasons. Practitioners are well versed in understanding these behaviours and using them in a positive way to develop children and move them along their learning journey.  To label it as bad is too simplistic, has a potential to change the way practitioners work with children and undermines practitioners’ knowledge and experience.

“We also feel that settings could be penalised if they are unable to take on children with SEND for 
their funded entitlement because they don’t have the funded resources to meet their needs – or they do offer them all of their funded entitlement places but are not receiving full funding to support the child’s needs. We hope Ofsted look at our concerns and adapt the EIF accordingly for the benefit of children and their practitioners.

“NDNA is running training events in all major cities across England about understanding the new EIF which start in May and continue until July.”

The main points of our response are: 

  • Use of language is inappropriate for children at the age of 0 – 5 and it is not clear how babies are represented in this framework
  • Vocabulary – does not support children who communicate non verbally and does not consider strategies for supporting development through vocabulary
  • Cultural Capital – what does this mean in practice? This could be interpreted in various ways
  • What is meant by the term cumulatively sufficient knowledge and skills?
  • Subject matter being taught –  there is no reference to the EYFS and the importance of a holistic approach to learning where children acquire wide ranging experiences, skills and knowledge across a broad range of subjects.  This language suggests a more formal approach to learning
  • Coherently planned and sequenced curriculum – the EYFS is not a sequenced approach to learning and development.  The EIF fails to recognise that the EYFS is a holistic approach to individual children’s current stage of development.  Gifted children could be held back and those that need more support might not have their learning embedded.  This statement could see practitioners delivering a linear approach/topical approach to developing children
  • The focus appears to have shifted to older children when evidence tells us that the most rapid period of development is birth to two
  • The miss-match of what is taught in qualifications and the language that is proposed to be used is hugely different and has the potential to put practitioners at a disadvantage
  • At the youngest age, behaviour and attitudes form part of children’s personal development. Children need to explore a range of behaviours in a safe environment with trusted adults to help them build their emotional resilience. Good and bad behaviour is not an approach appropriate for early years - for example, a one-year-old teething or a two-year-old with biting issues cannot be boxed into ‘bad behaviour’. We know positive behaviour management is the best experience a child can have
  • There is no mention of attachment in “outstanding” or “good” judgements yet this is critical for children in early years and the EYFS still states, even in the Schools’ Pilot for 2018, that “Children learn best when they are healthy, safe and secure, when their individual needs are met, and when they have positive relationships with the adults caring for them.”
  • Requires improvement judgement says “children’s behaviour and attitudes” are not good – what is good? What is not good? See point above about positive behaviour management
  • The start of on-site inspection has new requirements for the quality of support for any children with SEND and reasons why children may not receive their full entitlement – we do not feel exclusion is the role of inspection
  • Within maintained settings 2-year-old children are to be inspected under the school inspectorate (a separate framework) - children’s experience of the EYFS should be the same regardless of the type of setting they are in. Inspectors may not be early years’ specialists and this could lead to poor decisions being made by inspectors
  • All practitioners should know all children: this conflicts with the description of the key person role. In the draft Inspection handbook, it states that “the evidence collected must refer to… the discussions held with each child’s key person and how they decide what to teach. The EYFS states that the key person “must help ensure that every child’s learning and care is tailored to meet their individual needs”. For all practitioners to know all children, they must declare at what level and to what purpose. ‘Next steps’, summative assessments etc. are useful paperwork options that non key persons can refer to when children in a group activity are not key children. To show that a child’s development is strong and gaps have closed during their time in the setting is proof that all staff know children.