Extracts from reports under the new ISI framework

  • 8th May 2024

Durell Barnes reports on what school leaders and governors can learn from the first term of the Independent Schools Inspectorate’s reports under the new framework


Schools which were inspected during the autumn term have largely been concerned about the delays in publication of reports arising, the ISI tells us, from the enhanced quality assurance (QA) undertaken to ensure that all the reports made sense and that the judgements in reports are supported by evidence.

The logjam is clearing and at the time of writing the ISI is nearing a 90% target for publishing reports on time. Discussion continues about what that enhanced QA consists of, and late report publication has meant that feedback on the whole inspection process has been delayed, but the reports speak for themselves. We can all learn from those published from the first term’s routine inspections and this is particularly helpful for schools preparing to be inspected imminently or in the longer term. (This article does not take account of non-routine inspections, that is, material change inspections, progress monitoring visits or additional inspections required by the Department for Education).

Failings and strengths
Some stakeholders had been concerned about a perceived shift in emphasis on the part of the inspectorate to finding fault with schools rather than highlighting their strengths. So far, 14.5% of schools inspected have been judged not to have complied with aspects of the Independent School Standards and related requirements (the National Minimum Standards for boarding schools and the Early Years Foundation Stage requirements). This is an increase on the 11.3% of schools identified from a much larger sample in 2022-3. The number is too small to allow for the identification of trends, but it will come as no surprise that most failings are around welfare, health and safety, including issues relating to safeguarding policy and procedures, safer recruitment and risk assessment (including supervision arrangements). All but one of the schools deemed to have failed one or more of the other Standards was judged not to have met Standard 8 (the quality of leadership in and management of schools).

Alongside these stark statistics, it’s clear from reports that inspectors have been applying the ISI inspection principle of proportionality (that where ‘some relative weaknesses or minor errors that can be easily rectified’ and are not ‘indicative of systemic failings’ these will be recorded in the report but not lead to a judgement of non-compliance [ISI Framework paragraph 9]). Instances have related to fire assessment recommendations, recruitment checks, attendance registers, risk assessments and out-of-date policies. Schools are not let off the hook, as these extracts show – but each of these was deemed compliant.

“An administrative error in one pre-employment check was rectified swiftly during the inspection.”

“However, with regard to the outcomes of the fire risk assessment there was a delayed response to addressing the recommendations.”

“A small number of maintenance issues relating to the school site were identified during the inspection. These were promptly addressed by the school.”

A controversial element of the new framework is the identification in some reports of significant strengths which are regarded as in some way exceptional – although that word is never used (and the ISI doesn’t want this element of reporting to become fodder for any kind of league table). So far, 11.6% of schools have been identified as having a significant strength, leaving some of what have been described as the finest schools in the world somewhat aggrieved. The significant strengths identified have covered behaviour, teaching, pupils’ technological skills, pastoral provision, provision for SEND, a challenging curriculum and also more nebulous elements, like “an atmosphere and culture which promotes self-knowledge, self-esteem and self-confidence”, “nurturing relationships” and a “customised approach to every pupil’s progress”. There is guidance on what constitutes a significant strength in paragraph 103 of the Inspection Framework. And in the following paragraph there is guidance which is proving controversial on the ground.

“Significant strengths in provision should be apparent to the inspection team as part of their ongoing inspection activity without signposting from school leaders. Inspectors should be mindful that school leaders may want to bring to the inspection team’s attention aspects of school provision that leaders consider are significant strengths. If any such signposting dominates the inspection discourse or interferes with the ability of inspectors to inspect provision against this framework, the reporting inspector should respectfully remind school leaders that the primary purpose of inspection is to evaluate the totality of provision against this framework. The reporting inspector may also wish to remind school leaders that evaluation of significant strengths lies with the inspection team and request that any excessive signposting ceases.”

Schools are not afforded the opportunity to detail to inspectors what they feel their significant strengths might be and this has caused some discontent. Representations about this are being made to the inspectorate.

Culture and risk
In all the training provided by the ISI about the new inspection framework, the focus on school culture has been emphasised and recent webinars have given insight into how the ISI views the guidance; it has referred schools to the Harvard article ‘What makes a good school culture’ [see the webinar ‘Self evaluation guidance (1/2) – 4 March 2024’ on the ISI website: isi.net/inspection-explained/support/webinar-recordings]. Extracts from reports demonstrate how this is viewed by inspectors.

“Leaders have created a calm and supportive culture in the school.”

“Leaders have established a listening culture where pupils’ views and ideas for improvement are sought, and any issues acted upon.”

“Pupils of all ages appreciate right from wrong and the role they play in forming a cohesive and positive school culture. Kindness to others is clear throughout the school and a positive contributing factor to this is role modelling from staff who interact with the children with warmth and gentleness.”

It is evident that pupil voice is an important source of evidence about school culture, but inspectors recognise the role of governors and leaders in creating it.

There had been some concerns about how inspectors would report when they encountered ‘Level 3’ of school culture, where “some members of the school community (and this may be a small number) are impacted by negative and damaging behaviours such as racism, misogyny and bullying.” [Inspection Handbook paragraph 16]. We can now see how this is handled, as in the following extracts.

“Leaders are aware that a small minority of pupils and parents feel that the issue of racist behaviour has not been dealt with effectively by the school.”

“Leaders recognise that positive feedback from a majority of pupils may not represent the view or concerns of some pupils, so leaders provide a variety of opportunities for listening to pupils’ views.”

These highlight the importance of effective self-evaluation as well as pupil voice. Inspectors want to know that schools are aware of minority views about specific issues, or how those could emerge where they are not known.

Risk appears in reports both at the level of risk assessments, which are frequently referred to with a particular interest in how risks are mitigated and assessments followed up, and at a more strategic level in terms of self-evaluation and development planning. These extracts give an insight into how this is viewed, both as a strength and where it causes concerns.

“Leaders’ plans carefully consider any associated risks and unintended consequences.”

“Any risks, including those of unintended consequences, are recognised and mitigated.”

“Teachers manage behaviour inconsistently because they are not trained to deal with some behaviour effectively… The risks associated with this are not recognised and mitigated.”

“There is no risk assessment policy and the proprietor and leaders have a limited understanding of risk management. This includes the contextual risk of a new leadership structure which does not have clearly understood responsibilities.”

Risk assessment therefore forms a key part of school culture, and there is no aspect of school life to which it should not be applied.

Health, safety and safeguarding
It is unsurprising that health and safety issues feature large in inspection reports. Those responsible for this area of school life can productively comb reports to find features which have been commended (for example, regular meetings of governors with health and safety and HR leaders to check the effective implementation of appropriate policies, governors reviewing accident and incident reports, the commissioning of external reviews or co-opting of experts to boards) and their concern about when actions from these are not followed up properly.

Safeguarding is the last section of the report. A risk-based approach to this is frequently referred to. One report describes a school’s approach and gives something of a blueprint which others might like to use as a checklist.

“There is a strong culture of safeguarding in the school. Leaders ensure that robust systems are in place for responding to, reporting and tracking any concerns about pupils’ welfare. Staff and proprietors take part in regular safeguarding training. They have a secure understanding of safeguarding procedures. Staff know how to refer any concerns they may have. Leaders ensure that all appropriate checks are made to ensure the suitability of staff. The proprietors maintain an effective oversight of the safeguarding policy and procedures and ensure that monitoring and filtering of the internet is in place.”

Teaching, learning and behaviour
Fears that what happens in the classroom might not receive the attention it deserves have been dispelled by the consideration which it receives in reports. The terms ‘health and safety’ and ‘safeguarding’ feature on average 18 times in each report. Again, combing reports allows readers to identify elements which inspectors commend. Examples of good practice include teaching which focuses on all individuals’ needs, shows understanding of pupils’ learning styles, exemplifies consistently high expectations, features lessons which are well (but not over-) structured, where pupils learn from their failures, engage with marking (including peer marking), is based on planning informed by assessment data, is evaluated through lesson observation (including peer observation) and learning walks, and is characterised by consistent application of clear behaviour policies and procedures (and record-keeping). Reporting focuses on how these features arise from effective leadership (or otherwise), as these extracts demonstrate.

“Initiatives put in place by senior and middle leaders, such as peer observations, inter-departmental sharing of practice and pupil surveys are developing teaching practice. As a result, much teaching challenges pupils’ thinking, allows collaborative and discursive approaches to learning that is carried out in a spirit of discovery together. Consequently, pupils of all ages are typically highly engaged in their learning. They show resilience and understanding that small failures are often the route to long-term success.”

“However, some teaching is less effective in ensuring that pupils’ individual needs are met… Many subject leaders monitor the quality of lessons closely, to see when individual pupils may be falling behind. They then intervene promptly to ensure teachers provide support or greater challenge for pupils. Some leaders do not look out for uneven progress in the same way.”

Some readers may be surprised by the prominent place given to behaviour in reports. It is one of the areas where reporting is frank and sometimes stark, but again focused on how leadership influences it, as we see in extracts below.

“In the senior school, pupils’ behaviour has previously been identified by school leaders as occasionally boisterous. Leaders have taken positive and successful steps to address this.”

“Most pupils behave well, but some poor behaviour goes unnoticed and unchallenged. Leaders are considering how best to ensure their high expectations for behaviour are more fully understood by pupils. There is a lack of cohesion in the monitoring of behaviour by middle and senior leaders.”

It is evident that behaviour needs to feature as strongly in school self-evaluation as teaching and learning.

Leadership and management, and governance
This is the area where the new framework differs most from the previous one. Under the last inspection regime, leadership and governance featured only if they were contributory factors in terms of outcomes for pupils’ achievements and personal development. Now, all aspects of the school are seen through the lens of governance, leadership and management. This can be seen from the fact that ‘leaders’ (or ‘leadership’) feature on average 62 times in reports – the record is 78 times, and ‘governors’ (or governance’) 14 times. We have seen that self-evaluation, influenced by stakeholder voice, is a key feature of school governance and leadership. It is assumed that governors will thus be well informed about life at the school, which they will visit frequently and in a focused manner. This is where Part 8 of the Independent Schools Standards Regulations comes into play.

“The standard about the quality of leadership and management is met if the proprietor ensures that persons with leadership and management responsibilities at the school – (a) demonstrate good skills and knowledge appropriate to their role so that the independent school standards are met consistently; (b) fulfil their responsibilities effectively so that the independent school standards are met consistently; and (c) actively promote the wellbeing of pupils.”

Inspectors seek assurance that the proprietor (usually the governors) oversee and monitor the work of the school leadership both in terms of their assurance of compliance with regulatory requirements and the active promotion of the wellbeing of pupils. An example of how this is reported gives schools an idea of what is expected.

“Governors are successful in fulfilling their responsibilities to monitor and support the work of leaders. They use a range of focused committees to provide informed oversight of particular areas, such as safeguarding. They are supported by advice from external professionals… Governors ensure that senior leaders carry out their role effectively and any risks to pupils’ wellbeing are identified and mitigated.

Leaders fulfil their responsibilities effectively so that the Standards are met. They have a clear vision for what they seek to achieve, reflected in their detailed development planning. Both governors and leaders are proactive in monitoring the implementation of their strategies.”

It is neither possible nor appropriate to provide a checklist for governors in this context. But analysis of reports indicates that these are recognised as features of good governance: that governors can articulate how they know Standard 8 is being met; strategy is based on first-hand knowledge of the school; there is a cycle of self-evaluation, development planning and action plans; governors have oversight of all aspects of the life of the school; pupil voice is key; governors scrutinise policies and their implementation; safeguarding is a key priority.

What’s missing?
This article has not discussed what has been learnt about the conduct of inspections on the ground, which awaits the availability of more systematic feedback on the whole process (watch this space). The ISI is providing guidance to schools as issues emerge in the Frequently Asked Questions section on its website, where stakeholders can also find helpful webinars on inspection update, the consultation on the complaints procedure, and on self-evaluation.

Some important elements of school life, which feature in inspection reports, have not been included in this article. Schools will be aware that important elements feature strongly in reports: personal, social and health education; relationships and sex education; careers; boarding; and the early years foundations stage. Future articles may explore these further.

There is, quite rightly, no blueprint of how to prepare for inspections, which are a live review of schools as they are at the time of inspection. But much can be learnt from the reports published from the first term of inspections under the new framework about how inspectors observe and experience school life, not with a view to following a blueprint, but in order to identify the best way to put forward to inspectors the best face of the school.

Durell Barnes is a governance specialist at consultancy RSAcademics.

Durell Barnes

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