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THE NUT’S RESPONSE TO
THE DEPARTMENT FOR
EDUCATION CONSULTATION
ON SECONDARY SCHOOL
ACCOUNTABILITY
APRIL 2013
Introduction
1. The NUT would welcome a broad debate including professionals, service users and
the general public on the accountability of public sector service organisations. The
consultation on secondary school accountability does not invite that broader debate.
A problem with public sector accountability measures is that they often create a
target-driven culture which may at times be at odds with the best interests of service
users – in the case of secondary schools, learners and their parents or carers.
2. The NUT has consistently opposed accountability measures which translate into
crude performance tables which rank schools in a ‘league table’ order. It is
immensely damaging to schools, teachers and other school staff, and learners
themselves where schools are ‘ranked’ lower than others in their area and are
labelled as ‘failing’ or ‘inadequate’.
3. ‘League tables’ of performance based on particular targets can also create perverse
incentives to adjust practice to meet the demands of achieving targets as an end in
itself, over and above the interests of learners, parents and carers ad the wider
community. While the consultation acknowledges some of the perverse incentives
that have applied in the past, the fact that there is no departure from a league table
and target culture overall runs the risk that a revised system of accountability which
merely alters the detail of targets to be achieved will simply introduce its own
unintended consequences.
4. Accountability described in terms of a rank order of performance are also
misleadingly presented to the public as enabling parental choices. Many people live
in more remote or rural areas which lack the transport infrastructure to make a
‘choice’ of school meaningful. Even in more metropolitan areas with a larger density
of school provision and availability of transport, parents and carers might more
accurately be described as being able to express a preference for a particular school
or schools, rather than exercising a choice, as many learners fail to gain admission
to their first choice of school. Within the context of the myth of school ‘choice’, rank
orders based on performance against specific targets serve only to demonise
particular schools and fuel an unhealthy competition between institutions rather than
facilitating improvements to provision overall, or, for example, encouraging
collaboration between institutions for mutual benefit.
5. Schools must collaborate on a wide number of issues in order to meet the best
interests of learners, their parents and carers, and the wider community. These
include the provision of the broadest range of 14-19 curriculum and qualification
choices within an area, working appropriately and effectively on pupil behaviour,
meeting appropriately the needs of hard to place pupils, and managing moves for
children at risk of exclusion, to name a few. The use of performance tables as an
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accountability measure has the consequence of placing institutions in competition
with each other, and directly undermines a spirit of collaboration and cohesion which
could help improve individual, local and national secondary school provision.
6. The NUT therefore puts forward its observations on the consultation questions as set
out within the overall context of opposition to a culture of performance tables and
targets.
7. In making its observations, the NUT notes also the findings of its poll of over 2000
parents, commissioned from YouGov plc in March 2013, which found that when
asked who they most trusted to deliver their child’s education other than themselves,
58 per cent of parents trusted teachers, and 59 per cent per cent head teachers,
while only 6 per cent trusted the Secretary of State. The NUT believes that the
interests of parents and carers, learners, and schools themselves are best met
through a dialogue and relationship between schools and homes and families, rather
than through the use of crude and potentially misleading ‘accountability’ measures
expressed in terms of performance tables. The NUT does not argue that schools
should not be held accountable, but it believes that the most effective form of
accountability is a direct and democratic accountability to the communities schools
serve.
Question 1: Do you agree with the proposals for the headline accountability
measures?
8. The NUT agrees that progress in 8 subjects represents an improvement to some
previously existing models, but retains the problems of public sector targets. The
decision to broaden attainment measures in such a way as to include subjects
outside the EBacc, including vocational qualifications, is however a step in the right
direction.
9. It is not clear why the DfE and Government maintain their opposition to the use of
contextual value added data. Without the use of contextual data, it is unlikely that
schools with particular intakes that militate against a high proportion of students
achieving high results, as the result of socio economic circumstances outside the
control of the school, will receive the appropriate credit and recognition for their work.
10. The proposed progress measure between Key Stages 2 and 4 ignores the fact that
pupils’ progress does not follow a simple, linear route in every case. There are a
number of factors affecting pupil progress and attainment, many of which are outside
the scope and influence of the school itself.
11. Simplistic statistical information is too crude a measure of institutional effectiveness.
However, more detailed information which could contextualise the type of information
the DfE is proposing to put forward to parents, carers and the public becomes too
complex for individuals to readily make sense of. This is one of the reasons that the
NUT continues to believe that performance tables of schools are inappropriate.
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Question 2: Is there any further information which we should provide about the
performance of disadvantaged pupils?
12. The NUT agrees strongly that it is “unacceptable” that “poverty remains strongly
associated with poor performance” in terms of educational attainment. This needs to
be tackled by setting clear aims to reduce child poverty rather than by placing the
onus on schools to ameliorate societal problems through a system of ‘naming and
shaming’ through league tables.
13. Disadvantage also needs to be tackled by ensuring that families and parents have
access to appropriate services, particularly services for disabled children, for
example, as having a disabled child places families at a higher risk of poverty.
14. The NUT believes that the allocation and use of the Pupil Premium is not
transparent, and its support for the restoration of an Education Maintenance
Allowance payable directly to learners themselves is well documented.
Question 3: Should we look to use a relative measure as the floor standard in the
first year of new exams?
15. The NUT is opposed to the use of floor standard measures. The consultation
recognises that reformed GCSEs will by definition have a new ‘standard’ and that
benchmarking data will not be available for the setting of floor standards. The
correct response to this should simply to be to eradicate the use of floor standard
measures rather than damaging the reputations of schools and learners who are “the
worst performing”. In any rank order of performance by definition there must always
be a group that are “the worst performing”. Rather than using a ‘relative measure’ in
the first year of new exams, the use of floor standards should at the very least be
suspended until new qualifications and examinations can be demonstrated to have
become established.
Question 4: Are there any other measures we should consider publishing?
16. The NUT would welcome any encouragement from the DfE and Government for
prospective pupils and their parents or carers to visit schools in their locality while
making decisions about secondary school places, rather than relying on crude
numerical information which is hard to interpret without knowing all the
contextualising information about the school and the community it serves.
17. The NUT continues to believe that the EBacc measure is too narrow and continues
to urge its removal. The NUT does not agree that the EBacc represents “the full
range of academic subjects”.
18. The NUT believes also that schools, when serving learners well, do far more than
simply deliver a menu of ‘academic subjects’. The NUT would welcome any moves
from the DfE, in taking forward its proposals, to emphasise to the public the
important work that schools do in terms of preparing pupils for adult life and active
citizenship, further study, employment, and in terms of social education and the
development of life skills, much of which cannot be readily measured within a league
table format.
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Question 5: Do you think that we should collect and publish test data from internal
assessment through the Data Warehouse?
19. The NUT disagrees strongly that internal assessment should be collected in this way,
as it will run the risk of distorting the nature and practice of such assessment. Firstly,
it may lead to an unhelpful ‘standardisation’ of internal assessment to meet the
needs of data collection rather than the interests of learning and teaching. Secondly,
any data provided in this way would need to be robustly moderated to ensure a
consistency of standard of assessment throughout the country.
20. It is important for schools to provide feedback from assessment to learners and to
their parents and carers. This is best done through a dialogue between teachers,
their pupils, and the pupils’ parents and carers. To publish such information, even in
an anonymised way, risks altering the relationship between schools and the
communities they serve.
21. Parents and carers seeking information about their child’s progress should be
encouraged to maintain a constructive dialogue with schools, for example through
attendance at parents’ evenings, rather than being encouraged simply to log onto a
website to seek numerical information which they may not fully understand without
the context that can be explained through meaningful dialogue between the school
and homes.
22. It is unclear to the NUT where the specific benefit would be at key stage 3, as stated
in the consultation document. As the document itself states, there is statutory
teacher assessment at key stage 3 and this is already reported to parents.
Question 6: What other data could be published to create the right incentives for
schools, including special schools, to ensure the best progress and attainment for
all their pupils?
23. The NUT agrees that the achievements of all pupils should be recognised, and that
there should be high, but appropriate, expectations of all learners. The NUT believes
that incentives to achieve the best for all pupils may be better achieved by the
publishing of less, rather than more, numerical data about attainment and
achievement, especially where, for example, achievement for a small number of
learners may be most meaningful in terms of skills for independent living rather than
the attainment of specific qualifications such as GCSE. Such progress is hard to
measure numerically, and the individual circumstances of some learners are such
that it may not be meaningful to use national averages of attainment or achievement
as a comparator for their own progress and achievement.
Question 7: Do you agree that the Department should stop the collection of key
stage 3 teacher assessment results?
24. The NUT agrees that if the DfE proceeds with proposals to remove level descriptors
from the National Curriculum – and given the fact that academies and free schools
are in any case exempt from the statutory use of the National Curriculum – it would
no longer be meaningful to collect attainment data at key stage 3 since there will be
no single, national system.
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Question 8: How should we ensure that achievement beyond formal qualifications
is recognised?
25. Schools have a variety of methods of communicating to parents the full range of
experiences and opportunities made available to learners, including through their
own regular communications with learners’ homes, through their websites, through
parents’ evenings, through school prospectuses and through school events. The
NUT does not believe that such opportunities can or should be reduced to numerical
information which can be set out in a table alongside, for example, results achieved
through qualifications.
26. Additionally, the reporting of such information distorts the nature of the opportunities
being made available to young people. For example, there could be a perverse
incentive for ‘opportunities’ to become more a compulsion than a choice.
Additionally, many learners themselves might consider that their activities in school
beyond the minimum statutory requirements are private rather than something which
needs to be publicly reported.
Question 9: How can national sample tests best be introduced?
27. The NUT has strong reservations about the proposal to introduce the sample test.
28. It is important that any such test, if introduced, remains separate from school
accountability measures as otherwise they will become simply another ‘high stakes’
test. If introduced, it is likely that schools will need to be given clear guidance on the
use of the test in order to avoid any teaching to the test.
29. More clarity would be welcome on the question of why, when ‘respected’
international comparators such as PISA, PIRLS and TIMMS already exist, the DfE
considers it necessary to develop an additional test.
30. The DFE may be aware that in Wales, the Minister for Education has faced criticism
that he misuses PISA data and has become unhelpfully focused on seeking to raise
Wales’ ranking in future rounds of the study. The Welsh Government has been
criticised also for issuing guidance around PISA which has been interpreted as
advocating a teaching to the PISA test.
31. Similarly the DfE and Government need to be clear that the purpose of tests is to
measure performance. Much of the richness of the OECD PISA study is that it
enables an assessment of the features of successful education models
internationally. It was never intended to be treated as a ‘league table’ ranking of
national performance, and a focus on improving national ‘rank order’ would be to
misunderstand the fact that it is genuine improvements in provision, including
narrowing attainment gaps caused by socio economic inequalities which will improve
educational outcomes rather than a narrow focus on improving test scores through
practice, coaching, or teaching to the test.
32. It is important also that any such test is not used cynically as a ‘preparation’ of pupils
for studies such as PISA which are intended to give international comparisons, in
order to seek to boost a national ‘league table’ ranking in such comparisons.
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33. The NUT has in the past suggested a national sampling model of testing to track the
effectiveness of the education service overall rather than retaining whole cohort
testing such as that which exists at the end of Key Stage 2. It is likely that the
introduction of any new sampling tests will be more welcomed by teachers if they are
within the context of lowering the overall burden of assessment. However teachers
in key stage 4 will be likely to wish to be assured that any key stage 4 sampling test
is not disruptive of teaching and learning, especially where it relates to pupils’
qualifications.
34. Greater clarity would be welcome also in establishing what means, if any, the DfE
will use to ensure that learners are not over assessed. In addition to national
sampling tests, some learners may be included also in international samples, and
may be required within their schools to sit various internal assessments.
35. There is little detail on the test provided in the consultation – for example what its
content will be, what subjects or areas will be included in the test, how long it will
take, or who will mark tests. If teachers are expected to mark tests they will be likely
to see it as an additional workload burden.
36. If a decision is taken to introduce a sampling model, it is vital to include the teaching
profession in any detailed discussion around the tests, the purposes for which they
are used, and the timing of their administration in order to ensure professional
confidence in them.
37. Since the test will be used to measure educational standards over time it is vital that
the Department for Education is able to demonstrate its ability to maintain standards
in the sample test itself over time. The public will also need to be reassured that any
reporting on national standards in education through the use of such a test is based
genuinely on an objective measure and not through the result of the political
manipulation of the test or its outcomes.
38. For these reasons the DfE, if it proceeds with proposals, should introduce a robust
procedure to trial and evaluate independently any proposed system of test.
39. More detail is needed also on the reporting of outcomes. Where pupils are included
in the sample, it is likely that they or their parents will wish to know their individual
outcome and, potentially that for the school cohort as a whole. It is likely to be
difficult to explain to learners and their parents why they may not be aware of their
test outcome. Schools, local authorities, academy chains and others may also wish
to know the outcomes for individual schools in comparison with others. However,
any reporting of individual or school outcomes is likely to undermine the intention of
the test being separate from accountability measures aimed at individual schools.
40. If it is proposed that reporting to the press and public will be at a national level only,
consideration needs to be given also to ensuring that the data remains secure and
can not be obtained – for example through an FoI request – by the media or others in
order to devise a ‘league table’ of performance of individual schools, categories of
school, or areas and regions. Were it possible for individuals or organisations to
have access to information in order to compile such data, the purpose of the test
would be undermined and it would become in reality, if not in intention, a ‘high
stakes’ test.
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