Respond to the Ofsted Consultation!

20 March 2019

Ofsted is currently consulting on a new framework for the assessment of schools, early years and further education institutions. This could potentially have a number of implications for arts and cultural learning. This post gives you some of our initial thoughts and tells you how to make yours known.

This new framework aims to be less data-driven and more light-touch. It states that it will focus Inspectors and, correspondingly, schools on outcomes and the quality of education. So far there has been a cautiously positive response to the proposed framework from the sector. Concerns seem to be centred on the implications for teacher workload and the subjectivity that is necessarily involved in making value judgements. 

We've seen evidence of colleagues in schools immediately adopting the new questions around the intent, implementation and impact of the curriculum, and we believe there is a lot of potential for arts and cultural colleagues to work to support schools in incorporating creative cultural learning into each of these categories.

The CLA has put together the following set of draft notes representing our initial thinking around the consultation framework. We’d be extremely grateful if partners could feed back on whether they think we’re on the right track and sent through any thoughts on what we may have missed or misunderstood. We’re particularly interested in any evidence you may have on the value and impact of arts and cultural learning in school at Key Stage 1.

It’s extremely important for everyone concerned with this agenda to respond to the consultation and make your views known. The questions themselves are quite technical, but there are several places where it’s possible to make the case. As always, we’re very happy for anyone to use these notes as a jumping-off point for their own submission – though do remember that you will have a greater impact if you redraft your document using your own words.

You can respond online here, and read the consultation and the draft handbooks here. The consultation closes on the 5thof April.

Quality of Education

We are strongly in support of the introduction of a ‘quality of education’ judgement.

We agree with Ofsted that a curriculum cannot be considered broad and rich if it is designed solely for achievement of qualifications, and we believe that the new Intent/Implementation/Impact framework articulated in this draft will help to ensure that education providers develop a more holistic and rounded approach to curriculum.

A quality education should enable each and every pupil to create and express their understanding of the world. It should introduce them to a range of extraordinary and excellent tools, techniques, concepts, frameworks, works and resources, helping them to comprehend and challenge existing ideas, and to generate their own.

However, there are a number of elements within this judgement which will need to be carefully considered in order for it to be effective.


  • Cultural capital

We are very pleased that this framework acknowledges that cultural capital is central to young people’s success and life chances, and we welcome the inclusion of this language into the framework.

However, we are concerned that the definition of cultural capital that is put forward here (and which is mapped to the aims of the national curriculum), is much too passive and too narrow. We would want this definition to reflect much of the language running through the rest of the Ofsted framework and to be amended along these lines:

‘Ofsted’s understanding of this knowledge and cultural capital is a follows: it is the essential knowledge, skills and understanding that pupils need to be educated, active citizens, introducing them to the best that has been thought and said and helping to engender an appreciation of develop human creativity, empathy, resilience, potential and achievement.'

We are also surprised that there is no mention of cultural capital in the draft Further Education and Skills inspection handbook, as it features in the other three (Early Years, Schools and Non-association Independent Schools). Whilst we understand that the curricula in FE institutions is likely to be different to that in schools, we believe that students in FE settings need access to cultural capital alongside other skills and knowledge in order to fully address social disadvantage. We would recommend that a section on cultural capital is developed for FE settings to bring them into line with the over-arching Ofsted framework and the other providers.

  • Future Learning and Employment
    We agree with Ofsted that it is extremely important for providers to plan a curriculum towards future learning and employment.

In the Schools handbook we are very pleased to note the focus on the power of curriculum in addressing social disadvantage.

  • Curriculum Narrowing
    We are pleased to see that the proposed School handbook strongly cautions against curriculum narrowing and highlights that this disproportionately affects the most disadvantaged pupils.

The Cultural Learning Alliance is concerned that there is significant narrowing of the curriculum taking place at Key Stage 3 as schools prioritise EBacc subjects. We would want Inspectors to specifically ensure the quality provision of a range of arts subjects at Key Stage 3, and for this to be written into the guidance. We recommend that the language in paragraph 37 of the January Schools Inspection Update is adopted into the handbook:

‘From key stage 2 onwards and in secondary education, however, inspectors will expect to see a broad, rich curriculum. That includes languages and the humanities, along with the arts and other creative subjects. Inspectors will be particularly alert to signs of narrowing in key stages 2 and 3 curriculums’.

The CLA is also concerned that Ofsted proposes that Inspectors assess schools on their plans and preparedness to deliver against the government’s current EBacc targets:

‘The large majority of pupils should be expected to study the EBacc. It is therefore the government’s ambition that 75% of Year 10 pupils in state-funded mainstream schools should be starting to study EBacc GCSE courses nationally by 2022 (taking their examinations in 2024), rising to 90% by 2025 (taking their examinations in 2027).’

Page 42, para 162

We believe that this emphasis is in direct contradiction to Ofsted’s stated intention - of ensuring schools offer a broad and rich curriculum for as long as possible. We also feel that this directive is redundant; schools are already judged on their EBacc data through a range of national accountability measures. Although we are glad to see that no particular numerical targets have been set for Ofsted, we recommend that this EBacc section is removed from the handbook altogether.

We believe strongly that it is never acceptable to narrow a curriculum at Key Stage 1, and we feel that the current wording in the document tacitly gives schools permission to do so:

It is appropriate that, in key stage 1, teachers focus on ensuring that pupils are able to read, write and use mathematical knowledge, ideas and operations’

We recommend that this statement is reworded. It is essential that children in the early years are given access to a broad, rich and balanced curriculum, and one which helps develop their cultural capital and creativity at the earliest stage. This will help to ensure that Ofsted’s ambitions for a ‘planned and sequenced’ curriculum will be achieved.


  • Teacher training and expertise

We are pleased to see that the draft School handbook acknowledges that:

Teachers have expert knowledge of the subjects that they teach and, where they do not, they are supported to address these gaps so that pupils are not disadvantaged by ineffective teaching.’

Page 43, para 168

We believe that this statement could potentially encourage schools to prioritise the recruitment and retention of arts subject specialists, reversing the significant decline in recent years.


  • Potential use of destination data

We note the inclusion of destination data as a potential source of evidence of curriculum impact in the draft schools handbook, and would like further assurances that a range of data will be used to make this judgement. For example, current graduate destination data relies on the Longitudinal Employment Outcomes (LEO) data which has many critical gaps, including:

  • leaving out factors that have a significant influence on earnings and employment, such as many personal and family details, and details about where you are working in the UK and in what industry. New analysis by London Economics for Guild HE shows that without this information, the effect of specific qualifications on both the earnings and employment of graduates is significantly exaggerated;
  • leaving out students who did not go to secondary school in England; 
  • the fact that LEO data only covers graduates’ earnings and employment in the early stages of their careers;
  • the fact that LEO data provides incomplete and potentially inaccurate data on earnings from self-employment. The most recent industry data from the Creative Industries Federation shows 47% of workers in the creative industries are freelance.


Whilst we understand that Inspectors will make a graded judgement on the quality of education across all areas of Intent, Implementation and Impact, we believe that no school should be judged outstanding without having excellent, quality, creative, arts and cultural learning in place. We would welcome language strengthening this within the framework.

Spiritual, moral, social and cultural development

We are pleased to see that it is proposed that Inspectors will be required to evaluate the effectiveness of the school’s provision for developing:

  • use of imagination and creativity in learning.
  • willingness to participate in and respond positively to artistic, musical, sporting and cultural opportunities.

We would suggest a change in language to the bullet related to cultural opportunities to read:

  • Knowledge, skills and ability to participate in and respond positively to artistic, musical, sporting and cultural opportunities

We suggest that ‘quality and range of partnerships’ is added to the sources of evidence used to make these judgements.

Linked issues that will be critical to the successful implementation of this Ofsted Framework

Use of data: DfE and Ofsted
We welcome the statements in the framework and in the January 2019 School Inspection Update that indicate that it will be Ofsted’s role to complement, rather than intensify, the focus on performance data and measures. However, the Department of Education has not indicated that it will similarly change its focus. Schools are currently judged on and required to publish data in more than 100 different categories, and we strongly believe that this requirement will shape and influence their decisions in designing and delivering their curricula, and will prevent them from being broad and rich.

We are pleased to see the continuing reliance on data provided by parents in Parent View, and would like to recommend that the questions asked in this survey reflect this new framework and that they specifically ask parents for their view of the arts and cultural provision in the school.

Training of her Majesty’s Inspectors
In order for the proposed approach to be effective it is essential that Inspectors are trained to recognise and effectively assess the quality of the arts provision within the intent/implementation/impact framework. Inspectors will need to be able to understand the different categories of curriculum design that are most appropriate for the arts and creative subjects, and the skills, knowledge and experiences associated with them.

The CLA would want to see specialist HMIs in post for all arts subjects, with these individuals then responsible for training cohorts of other inspectors until all are appropriately skilled. We welcome the plans for a subject curriculum group for Art & Design to support the training of inspectors in making judgements about delivery of arts subjects. We would like to see subject curriculum groups for all arts subjects.

We would also want to ensure that Inspectors are effectively trained to assess the effectiveness of careers advice, experience and contact with employers in the arts and creative industries. We believe that there is currently very little understanding of this aspect of our sector in the school or inspection system.



Photo credit: Into Film, School leader observes film and literacy work in the classroom


One Reply to "Respond to the Ofsted Consultation!"

  1. Excellent response ! Thank you.
    I spent a long time responding myself , only to get ” cut off ” near the end so I am delighted to find all that I wanted to say in your response.

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