Challenging NAHT’s Commission on Assessment

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This post reviews the Report of the NAHT’s National Commission on Assessment, published on 13 February 2014.

pencil-145970_640Since I previously subjected the Government’s consultation document on primary assessment and accountability to a forensic examination, I thought it only fair that I should apply the same high standards to this document.

I conclude that the Report is broadly helpful, but there are several internal inconsistencies and a few serious flaws.

Impatient readers may wish to skip the detailed analysis and jump straight to the summary at the end of the post which sets out my reservations in the form of 23 recommendations addressed to the Commission and the NAHT.

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Other perspectives

Immediate reaction to the Report was almost entirely positive.

The TES included a brief Ministerial statement in its coverage, attributed to Michael Gove:

‘The NAHT’s report gives practical, helpful ideas to schools preparing for the removal of levels. It also encourages them to make the most of the freedom they now have to develop innovative approaches to assessment that meet the needs of pupils and give far more useful information to parents.’

ASCL and ATL both welcomed the Report, as did the National Governors’ Association, though there was no substantive comment from NASUWT or NUT.

The Blogosphere exhibited relatively little interest, although a smattering of posts began to expose some issues:

  • LKMco supported the key recommendations, but wondered whether the Commission might not be guilty of reinventing National Curriculum levels;
  • Mr Thomas Maths was more critical, identifying three key shortcomings, one being the proposed approach to differentiation within assessment;
  • Warwick Mansell, probably because he blogs for NAHT, confined himself largely to summarising the Report, which he found ‘impressive’, though he did raise two key points – the cost of implementing these proposals and how the recommendations relate to the as yet uncertain position of teacher assessment in the Government’s primary assessment and accountability reforms.

All of these points – and others – are fleshed out in the critique below.

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Background

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Remit, Membership and Evidence Base

The Commission was first announced in July 2013, when it was described as:

‘a commission of practitioners to shape the future of assessment in a system without levels.’

By September, Lord Sutherland had agreed to Chair the body and its broad remit had been established:

‘To:

  • establish a set of principles to underpin national approaches to assessment and create consistency;
  • identify and highlight examples of good practice; and
  • build confidence in the assessment system by securing the trust and support of officials and inspectors.’

Written evidence was requested by 16 October.

The first meeting took place on 21 October and five more were scheduled before the end of November.

Members’ names were not included at this stage (beyond the fact that NAHT’s President – a Staffordshire primary head – was involved) though membership was now described as ‘drawn from across education’.

Several members had in fact been named in an early October blog post from NAHT and a November press release from the Chartered Institute of Educational Assessors (CIEA) named all but one – NAHT’s Director of Education. This list was confirmed in the published Report.

The Commission had 14 members but only six of them – four primary heads one primary deputy and one secondary deputy – could be described as practitioners.

The others included two NAHT officials in addition to the secretariat, one being General Secretary Russell Hobby, and one from ASCL;  John Dunford, a consultant with several other strings to his bow, one of those being Chairmanship of the CIEA; Gordon Stobart an academic specialist in assessment with a long pedigree in the field; Hilary Emery, the outgoing Chief Executive of the National Children’s Bureau; and Sam Freedman of Teach First.

There were also unnamed observers from DfE, Ofqual and Ofsted.

The Report says the Commission took oral evidence from a wide range of sources. A list of 25 sources is provided but it does not indicate how much of their evidence was written and how much oral.

Three of these sources are bodies represented on the Commission, two of them schools. Overall seven are from schools. One source is Tim Oates, the former Chair of the National Curriculum Review Expert Panel.

The written evidence is not published and I could find only a handful of responses online, from:

Overall one has to say that the response to the call for evidence was rather limited. Nevertheless, it would be helpful for NAHT to publish all the evidence it received. It might be helpful for NAHT to consult formally on key provisions in its Report.

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Structure of the Report and Further Stages Proposed

The main body of the Report is sandwiched between a foreword by the Chair and a series of Annexes containing case studies, historical and international background.  This analysis concentrates almost entirely on the main body.

The 21 Recommendations are presented twice, first as a list within the Executive Summary and subsequently interspersed within a thematic commentary that summarises the evidence received and also conveys the Commission’s views.

The Executive Summary also sets out a series of Underpinning Principles for Assessment and a Design Checklist for assessment in schools, the latter accompanied by a set of five explanatory notes.

It offers a slightly different version of the Commission’s Remit:

‘In carrying out its task, the Commission was asked to achieve three distinct elements:

  • A set of agreed principles for good assessment
  • Examples of current best practice in assessment that meet these principles
  • Buy-in to the principles by those who hold schools to account.’

These are markedly less ambitious than their predecessors, having dropped the reference to ‘national approaches’ and any aspiration to secure support from officials and inspectors for anything beyond the Principles.

Significantly, the Report is presented as only the first stage in a longer process, an urgent response to schools’ need for guidance in the short term.

It recommends that further work should comprise:

  • ‘A set of model assessment criteria based on the new National Curriculum.’ (NAHT is called upon to develop and promote these. The text says that a model document is being  commissioned but doesn’t reveal the timescale or who is preparing it);
  • ‘A full model assessment policy and procedures, backed by appropriate professional development’ that would expand upon the Principles and Design Checklist. (NAHT is called upon to take the lead in this, but there is no indication that they plan to do so. No timescale is attached)
  • ‘A system-wide review of assessment’ covering ages 2-19. It is not explicitly stated, but one assumes that this recommendation is directed towards the Government. Again no timescale is attached.

The analysis below looks first at the assessment Principles, then the Design Checklist and finally the recommendations plus associated commentary. It concludes with an overall assessment of the Report as a whole.

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Assessment Principles

As noted above, it seems that national level commitment is only sought in respect of these Principles, but there is no indication in the Report – or elsewhere for that matter – that DfE, Ofsted and Ofqual have indeed signed up to them.

Certainly the Ministerial statement quoted above stops well short of doing so.

The consultation document on primary assessment and accountability also sought comments on a set of core principles to underpin schools’ curriculum and assessment frameworks. It remains to be seen whether the version set out in the consultation response will match those advanced by the Commission.

The Report recommends that schools should review their own assessment practice against the Principles and Checklist together, and that all schools should have their own clear assessment principles, presumably derived or adjusted in the light of this process.

Many of the principles are unexceptionable, but there are a few interesting features that are directly relevant to the commentary below.

For it is of course critical to the internal coherence of the Report that the Design Checklist and recommendations are entirely consistent with these Principles.

I want to highlight three in particular:

  • ‘Assessment is inclusive of all abilities…Assessment embodies, through objective criteria, a pathway of progress and development for every child…Assessment objectives set high expectations for learners’.

One assumes that ‘abilities’ is intended to stand proxy for both attainment and potential, so that there should be ‘high expectations’ and a ‘pathway of progress and development’ for the lowest and highest attainers alike.

  • ‘Assessment places achievement in context against nationally standardised criteria and expected standards’.

This begs the question whether the ‘model document’ containing assessment criteria commissioned by NAHT will be ‘nationally standardised’ and, if so, what standardisation process will be applied.

  • ‘Assessment is consistent…The results are readily understandable by third parties…A school’s results are capable of comparison with other schools, both locally and nationally’.

The implication behind these statements must be that results of assessment in each school are transparent and comparable through the accountability regime, presumably by means of the performance tables (and the data portal that we expect to be introduced to support them).

This cannot be taken as confined to statutory tests, since the text later points out that:

‘The remit did not extend to KS2 tests, floor standards and other related issues of formal accountability.’

It isn’t clear, from the Principles at least, whether the Commission believes that teacher assessment outcomes should also be comparable. Here, as elsewhere, the Report does a poor job of distinguishing between statutory teacher assessment and assessment internal to the school.

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Design Checklist.

 

Approach to Assessment and Use of Assessment

The Design Checklist is described as:

‘an evaluation checklist for schools seeking to develop or acquire an assessment system. They could also form the seed of a revised assessment policy.’

It is addressed explicitly to schools and comprises three sections covering, respectively, a school’s approach to assessment, method of assessment and use of assessment.

The middle section is by far the most significant and also the most complex, requiring five explanatory notes.

I have taken the more straightforward first and third sections first.

‘Our approach to assessment’ simply makes the point that assessment is integral to teaching and learning, while also setting expectations for regular, universal professional development and ‘a senior leader who is responsible for assessment’.

It is not clear whether this individual is the same as, or additional to, the ‘trained assessment lead’ mentioned in the Report’s recommendations.

I can find no justification in the Report for the requirement that this person must be a senior leader.

A more flexible approach would be preferable, in which the functions to be undertaken are outlined and schools are given flexibility over how those are distributed between staff. There is more on this below.

The final section ‘Our use of assessment’ refers to staff:

  • Summarising and analysing attainment and progress;
  • Planning pupils’ learning to ensure every pupil meets or exceeds expectations (Either this is a counsel of perfection, or expectations for some learners are pitched below the level required to satisfy the assessment criteria for the subject and year in question. The latter is much more likely, but this is confusing since satisfying the assessment criteria is also described in the Checklist in terms of ‘meeting…expectations’.)
  • Analysing data across the school to ensure all pupils are stretched while the vulnerable and those at risk make appropriate progress (‘appropriate’ is not defined within the Checklist itself but an explanatory note appended to the central section  – see below – glosses this phrase);
  • Communicating assessment information each term to pupils and parents through ‘a structured conversation’ and the provision of ‘rich, qualitative profiles of what has been achieved and indications of what they [ie parents as well as pupils] need to do next’; and
  • Celebrating a broad range of achievements, extending across the full school curriculum and encompassing social, emotional and behavioural development.

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Method of Assessment: Purposes

‘Our method of assessment’ is by far the longest section, containing 11 separate bullet points. It could be further subdivided for clarity’s sake.

The first three bullets are devoted principally to some purposes of assessment. Some of this material might be placed more logically in the ‘Our Use of Assessment’ section, so that the central section is shortened and restricted to methodology.

The main purpose is stipulated as ‘to help teachers, parents and pupils plan their next steps in learning’.

So the phrasing suggests that assessment should help to drive forward the learning of parents and teachers, as well as to the learning of pupils. I’m not sure if this is deliberate or accidental.

Two subsidiary purposes are mentioned: providing a check on teaching standards and support for their improvement; and providing a comparator with other schools via collaboration and the use of ‘external tests and assessments’.

It is not clear why these three purposes are singled out. There is some overlap with the Principles but also a degree of inconsistency between the two pieces of documentation. It might have been better to cross-reference them more carefully.

In short, the internal logic of the Checklist and its relationship with the Principles could both do with some attention.

The real meat of the section is incorporated in the eight remaining bullet points. The first four are about what pupils are assessed against and when that assessment takes place. The last four explain how assessment judgements are differentiated, evidenced and moderated.

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Method of Assessment: What Learners Are Assessed Against – and When

The next four bullets specify that learners are to be assessed against ‘assessment criteria which are short, discrete, qualitative and concrete descriptions of what a pupil is expected to know and be able to do.’

These are derived from the school curriculum ‘which is composed of the National Curriculum and our own local design’ (Of course that is not strictly the position in academies, as another section of the Report subsequently points out.)

The criteria ‘for periodic assessment are arranged into a hierarchy setting out what children are normally expected to have mastered by the end of each year’.

Each learner’s achievement ‘is assessed against all the relevant criteria at appropriate times of the school year’.

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The Span of the Assessment Criteria

The first explanatory note (A) clarifies that the assessment criteria are ‘discrete, tangible descriptive statements of attainment’ derived from ‘the National Curriculum (and any school curricula)’.

There is no repetition of the provision in the Principles that they should be ‘nationally standardised’ but ‘there is little room for meaningful variety’, even though academies are not obliged to follow the National Curriculum and schools have complete flexibility over the remainder of the school curriculum.

The Recommendations have a different emphasis, saying that NAHT’s model criteria should be ‘based on the new National Curriculum’ (Recommendation 6), but the clear impression here is that they will encompass the National Curriculum ‘and any school curricula’ alike.

This inconsistency needs to be resolved. NAHT might be better off confining its model criteria to the National Curriculum only – and making it clear that even these may not be relevant to academies.

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The Hierarchy of Assessment Criteria

The second explanatory note (B) relates to the arrangement of the assessment criteria

‘…into a hierarchy, setting out what children are normally expected to have mastered by the end of each year’.

This note is rather muddled.

It begins by suggesting that a hierarchy divided chronologically by school year is the most natural choice, because:

‘The curriculum is usually organised into years and terms for planned delivery’

That may be true, but only the Programmes of Study for the three core subjects are organised by year, and each clearly states that:

‘Schools are…only required to teach the relevant programme of study by the end of the key stage. Within each key stage, schools therefore have the flexibility to introduce content earlier or later than set out in the programme of study. In addition, schools can introduce key stage content during an earlier key stage if appropriate.’

All schools – academies and non-academies alike – therefore enjoy considerable flexibility over the distribution of the Programmes of Study between academic years.

(Later in the Report – in the commentary preceding the first six recommendations – the text mistakenly suggests that the entirety of ‘the revised curriculum is presented in a model of year-by-year progress’ (page 14) It does not mention the provision above).

The note goes on to suggest that the Commission has chosen a different route, not because of this flexibility, but because ‘children’s progress may not fit neatly into school years’:

‘…we have chosen the language of a hierarchy of expectations to avoid misunderstandings. Children may be working above or below their school year…’

But this is not an absolute hierarchy of expectations – in the sense that learners are free to progress entirely according to ability (or, more accurately, their prior attainment) rather than in age-related lock steps.

In a true hierarchy of expectations, learners would be able to progress as fast or as slowly as they are able to, within the boundaries set by:

  • On one hand, high expectations, commensurate challenge and progression;
  • On the other hand, protection against excessive pressure and hot-housing and a judicious blending of faster pace with more breadth and depth (of which more below).

This is no more than a hierarchy by school year with some limited flexibility at the margins.

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The timing of assessment against the criteria

The third explanatory note (C) confirms the Commission’s assumption that formal assessments will be conducted at least termly – and possibly more frequently than that.

It adds:

‘It will take time before schools develop a sense of how many criteria from each year’s expectations are normally met in the autumn, spring and summer terms, and this will also vary by subject’.

This is again unclear. It could mean that a future aspiration is to judge progress termly, by breaking down the assessment criteria still further – so that a learner who met the assessment criteria for, say, the autumn term is deemed to be meeting the criteria for the year as a whole at that point.

Without this additional layer of lock-stepping, presumably the default position for the assessments conducted in the autumn and spring terms is that learners will still be working towards the assessment criteria for the year in question.

The note also mentions in passing that:

‘For some years to come, it will be hard to make predictions from outcomes of these assessments to the results in KS2 tests. Such data may emerge over time, although there are question marks over how reliable predictions may be if schools are using incompatible approaches and applying differing standards of performance and therefore cannot pool data to form large samples.’

This is one of very few places where the Report picks up on the problems that are likely to emerge from the dissonance between internal and external statutory assessment.

But it avoids the central issue, this being that the approach to internal assessment it advocates may not be entirely compatible with predicting future achievement in the KS2 tests. If so, its value is seriously diminished, both for parents and teachers, let alone the learners themselves.  This issue also reappears below.

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Method of Assessment: How Assessment Judgements are Differentiated, Evidenced and Moderated

The four final bullet points in this section of the Design Checklist explain that all learners will be assessed as either ‘developing’, ‘meeting’, or ‘exceeding’ each relevant criterion for that year’.

Learners deemed to be exceeding the relevant criteria in a subject for a given year ‘will also be assessed against the criteria in that subject for the next year.’

Assessment judgements are supported by evidence comprising observations, records of work and test outcomes and are subject to moderation by teachers in the same school and in other schools to ensure they are fair, reliable and valid.

I will set moderation to one side until later in the post, since that too lies outside the scope of methodology.

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Differentiation against the hierarchy of assessment criteria

The fourth explanatory note (D) addresses the vexed question of differentiation.

As readers may recall, the Report by the National Curriculum Review Expert Panel failed abjectly to explain how they would provide stretch and challenge in a system that focused exclusively on universal mastery and ‘readiness to progress’, saying only that further work was required to address the issue.

Paragraph 8.21 implied that they favoured what might be termed an ‘enrichment and extension’ model:

‘There are issues regarding ‘stretch and challenge’ for those pupils who, for a particular body of content, grasp material more swiftly than others. There are different responses to this in different national settings, but frequently there is a focus on additional activities that allow greater application and practice, additional topic study within the same area of content, and engagement in demonstration and discussion with others…These systems achieve comparatively low spread at the end of primary education, a factor vital in a high proportion of pupils being well positioned to make good use of more intensive subject-based provision in secondary schooling.’

Meanwhile, something akin to the P Scales might come into play for those children with learning difficulties.

On this latter point, the primary assessment and accountability consultation document said DfE would:

‘…explore whether P-scales should be reviewed so that they align with the revised national curriculum and provide a clear route to progress to higher attainment.’

We do not yet know whether this will happen, but Explanatory Note B to the Design Checklist conveys the clear message that the P-Scales need to be retained:

‘…must ensure we value the progress of children with special needs as much as any other group. The use of P scales here is important to ensure appropriate challenge and progression for pupils with SEN.’

By contrast, for high attainers, the Commission favours what might be called a ‘mildly accelerative’ model whereby learners who ‘exceed’ the assessment criteria applying to a subject for their year group may be given work that enables them to demonstrate progress against the criteria for the year above.

I describe it as mildly accelerative because there is no provision for learners to be assessed more than one year ahead of their chronological year group. This is a fairly low ceiling to impose on such accelerative progress.

It is also unclear whether the NAHT’s model assessment criteria will cover Year 7, the first year of the KS3 Programmes of Study, to enable this provision to extend into Year 6.

The optimal approach for high attainers would combine the ‘enrichment and extension’ approach apparently favoured by the Expert Panel with an accelerative approach that provides a higher ceiling, to accommodate those learners furthest ahead of their peers.

High attaining learners could then access a customised blend of enrichment (more breadth), extension (greater depth) and acceleration (faster pace) according to their needs.

This is good curricular practice and it should be reflected in assessment practice too, otherwise the risk is that a mildly accelerative assessment process will have an undesirable wash-back effect on teaching and learning.

Elsewhere, the Report advocates the important principle that curriculum, assessment and pedagogy should be developed in parallel, otherwise there is a risk that one – typically assessment – has an undesirable effect on the others. This would be an excellent exemplar of that statement.

The judgement whether a learner is exceeding the assessment criteria for their chronological year would be evidenced by enrichment and extension activity as well as by pre-empting the assessment criteria for the year ahead. Exceeding the criteria in terms of greater breadth or more depth should be equally valued.

This more rounded approach, incorporating a higher ceiling, should also be supported by the addition of a fourth ‘far exceeded’ judgement, otherwise the ‘exceeded’ judgement has to cover far too wide a span of attainment, from those who are marginally beyond their peers to those who are streets ahead.

These concerns need urgently to be addressed, before NAHT gets much further with its model criteria.

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The aggregation of criteria

In order to make the overall judgement for each subject, learners’ performance against individual assessment criteria has to be combined to give an aggregate measure.

The note says:

‘The criteria themselves can be combined to provide the qualitative statement of a pupil’s achievements, although teachers and schools may need a quantitative summary. Few schools appear to favour a pure binary approach of yes/no. The most popular choice seems to be a three phase judgement of working towards (or emerging, developing), meeting (or mastered, confident, secure, expected) and exceeded. Where a student has exceeded a criterion, it may make sense to assess them also against the criteria for the next year.’

This, too, begs some questions. The statement above is consistent with one of the Report’s central recommendations:

‘Pupil progress and achievement should be communicated in terms of descriptive profiles rather than condensed to numerical summaries (although schools may wish to use numerical data for internal purposes).’

Frankly it seems unlikely that such ‘condensed numerical summaries’ can be kept hidden from parents. Indeed, one might argue that they have a reasonable right to know them.

These aggregations – whether qualitative or quantitative – will be differentiated at three levels, according to whether the learner best fits a ‘working towards’, ‘meeting’ or ‘exceeding’ judgement for the criteria relating to the appropriate year in each programme of study.

I have just recommended that there needs to be an additional level at the top end, to remove undesirable ceiling effects that lower expectations and are inconsistent with the Principles set out in the Report. I leave it to others to judge whether, if this was accepted, a fifth level is also required at the lower end to preserve the symmetry of the scale.

There is also a ‘chicken and egg’ issue here. It is not clear whether a learner must already be meeting some of the criteria for the succeeding year in order to show they are exceeding the criteria for their own year – or whether assessment against the criteria for the succeeding year is one potential consequence of a judgement that they are exceeding the criteria for their own year.

This confusion is reinforced by a difference of emphasis between the checklist – which says clearly that learners will be assessed against the criteria for the succeeding year if they exceeded the criteria for their own – and the explanatory note, which says only that this may happen.

Moreover, the note suggests that this applies criterion by criterion – ‘where a student has exceeded a criterion’ – rather than after the criteria have been aggregated, which is the logical assumption from the wording in the checklist – ‘exceeded the relevant criteria’.

This too needs clarifying.

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Recommendations and Commentary

I will try not to repeat in this section material already covered above.

I found that the recommendations did not always sit logically with the preceding commentary, so I have departed from the subsections used in the Report, grouping the material into four broad sections: further methodological issues; in-school and school-to school support; national support; and phased implementation.

Each section leads with the relevant Recommendations and folds in additional relevant material from different sections of the commentary. I have repeated recommendations where they are relevant to more than one section.

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Further methodological issues

Recommendation 4: Pupils should be assessed against objective criteria rather than ranked against each other

Recommendation 5: Pupil progress and achievements should be communicated in terms of descriptive profiles rather than condensed to numerical summaries (although schools may wish to use numerical data for internal purposes.

Recommendation 6: In respect of the National Curriculum, we believe it is valuable – to aid communication and comparison – for schools to be using consistent criteria for assessment. To this end, we call upon NAHT to develop and promote a set of model assessment criteria based on the new National Curriculum.

The commentary discusses the evolution of National Curriculum levels, including the use of sub-levels and their application to progress as well as achievement. In doing so, it summarises the arguments for and against the retention of levels.

In favour of retention:

  • The system of levels provides a common language used by schools to summarise attainment and progress;
  • It is argued (by some professionals) that parents have grown up with levels and have an adequate grasp of what they mean;
  • The numerical basis of levels was useful to schools in analysing and tracking the performance of large numbers of pupils;
  • The decision to remove levels was unexpected and caused concern within the profession, especially as it was also announced that being ‘secondary ready’ was to be associated with the achievement of Level 4B;
  • If levels are removed, they must be replaced by a different common language, or at least ‘an element of compatibility or common understanding’ should several different assessment systems emerge.

In favour of removal:

  • It is argued (by the Government) that levels are not understood by parents and other stakeholders;
  • The numerical basis of levels does not have the richness of a more rounded description of achievement. The important narrative behind the headline number is often lost through over-simplification.
  • There are adverse effects from labelling learners with levels.

The Commission is also clear that the Government places too great a reliance on tests, particularly for accountability purposes. This has narrowed the curriculum and resulted in ‘teaching to the test’.

It also creates other perverse incentives, including the inflation of assessment outcomes for performance management purposes or, conversely, the deflation of assessment outcomes to increase the rate of progress during the subsequent key stage.

Moreover, curriculum, assessment and pedagogy must be mutually supportive. Although the Government has not allowed the assessment tail to wag the curricular dog:

‘…curriculum and assessment should be developed in tandem.’

Self-evidently, this has not happened, since the National Curriculum was finalised way ahead of the associated assessment arrangements which, in the primary sector, are still unconfirmed.

There is a strong argument that such assessment criteria should have been developed by the Government and made integral to the National Curriculum.

Indeed, in Chapter 7 of its Report on ‘The Framework for the National Curriculum’, the National Curriculum Expert Panel proposed that attainment targets should be retained, not in the form of level descriptors but as ‘statements of specific learning outcomes related to essential knowledge’ that  would be ’both detailed and precise’. They might be presented alongside the Programmes of Study.

The Government ignored this, opting for a very broad single, standard attainment target in each programme of study:

‘By the end of each key stage, pupils are expected to know, apply and understand the matters, skills and processes specified in the relevant programme of study.’

As I pointed out in a previous post, one particularly glaring omission from the Consultation Document on Primary Assessment and Accountability was any explanation of how Key Stage Two tests and statutory teacher assessments would be developed from these singleton ‘lowest common denominator’ attainment targets, especially in a context where academies, while not obliged to follow the National Curriculum, would undertake the associated tests.

We must await the long-delayed response to the consultation to see if it throws any light on this matter.

Will it commit the Government to producing a framework, at least for statutory tests in the core subjects, or will it throw its weight behind the NAHT’s model criteria instead?

I have summarised this section of the Report in some detail as it is the nearest it gets to providing a rational justification for the approach set out in the recommendations above.

The model criteria appear confined to the National Curriculum at this point, though we have already noted that is not the case elsewhere in the Report.

I have also discussed briefly the inconsistency in permitting the translation of descriptive profiles into numerical data ‘for internal purposes’, but undertook to develop that further, for there is a wider case that the Report does not entertain.

We know that there will be scores attached to KS2 tests, since those are needed to inform parents and for accountability purposes.

The Primary Assessment and Accountability consultation document proposed a tripartite approach:

  • Scaled scores to show attainment, built around a new ‘secondary-ready’ standard, broadly comparable with the current Level 4B;
  • Allocation to a decile within the range of scaled scores achieved nationally, showing attainment compared with one’s peers; and
  • Comparison with the average scaled score of those nationally with the same prior attainment at the baseline, to show relative progress.

Crudely speaking, the first of these measures is criterion-referenced while the second and third are norm-referenced.

We do not yet know whether these proposals will proceed – there has been some suggestion that deciles at least will be dropped – but parents will undoubtedly want schools to be able to tell them what scaled scores their children are on target to achieve, and how those compare with the average for those with similar prior attainment.

It will be exceptionally difficult for schools to convey that information within the descriptive profiles, insofar as they relate to English and maths, without adopting the same numerical measures.

It might be more helpful to schools if the NAHT’s recommendations recognised that fact. For the brutal truth is that, if schools’ internal assessment processes do not respond to this need, they will have to set up parallel processes that do so.

In order to derive descriptive profiles, there must be objective assessment criteria that supply the building blocks, hence the first part of Recommendation 4. But I can find nothing in the Report that explains explicitly why pupils cannot also be ranked against each other. This can only be a veiled and unsubstantiated objection to deciles.

Of course it would be quite possible to rank pupils at school level and, in effect, that is what schools will do when they condense the descriptive profiles into numerical summaries.

The real position here is that such rankings would exist, but would not be communicated to parents, for fear of ‘labelling’. But the labelling has already occurred, so the resistance is attributable solely to communicating these numerical outcomes to parents. That is not a sustainable position.

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In-school and school-to-school support

Recommendation 1: Schools should review their assessment practice against the principles and checklist set out in this report. Staff should be involved in the evaluation of existing practice and the development of a new, rigorous assessment system and procedures to enable the school to promote high quality teaching and learning.

Recommendation 2: All schools should have clear assessment principles and practices to which all staff are committed and which are implemented. These principles should be supported by school governors and accessible to parents, other stakeholders and the wider school community.

Recommendation 3: Assessment should be part of all school development plans and should be reviewed regularly. This review process should involve every school identifying its own learning and development needs for assessment. Schools should allocate specific time and resources for professional development in this area and should monitor how the identified needs are being met.

Recommendation 7 (part): Schools should work in collaboration, for example in clusters, to ensure a consistent approach to assessment. Furthermore, excellent practice in assessment should be identified and publicised…

Recommendation 9: Schools should identify a trained assessment lead, who will work with other local leads and nationally accredited assessment experts on moderation activities.

Recommendation 16: All those responsible for children’s learning should undertake rigorous training in formative, diagnostic and summative assessment, which covers how assessment can be used to support teaching and learning for all pupils, including those with special educational needs. The government should provide support and resources for accredited training for school assessment leads and schools should make assessment training a priority.

Recommendation 20: Schools should be asked to publish their principles of assessment from September 2014, rather than being required to publish a detailed assessment framework, which instead should be published by 2016. The development of the full framework should be outlined in the school development plan with appropriate milestones that allow the school sufficient time to develop an effective model.

All these recommendations are perfectly reasonable in themselves, but it is worth reflecting for a while on the likely cost and workload implications, particularly for smaller primary schools:

Each school must have a ‘trained assessment lead’ who may or may not be the same as the ‘senior leader who is responsible for assessment’ mentioned in the Design Checklist. There is no list of responsibilities for that person, but it would presumably include:

  • Leading the review of assessment practice and developing a new assessment system;
  • Leading the definition of the school’s assessment principles and practices and communicating these to governors, parents, stakeholders and the wider community;
  • Lead responsibility for the coverage of assessment within the school’s development plan and the regular review of that coverage;
  • Leading the identification and monitoring of the school’s learning and development needs for assessment;
  • Ensuring that all staff receive appropriate professional development – including ‘rigorous training in formative diagnostic and summative assessment’;
  • Leading the provision of in-school and school-to-school professional development relating to assessment;
  • Allocating time and resources for all assessment-related professional development and monitoring its impact;
  • Leading collaborative work with other schools to ensure a consistent approach to assessment;
  • Dissemination of effective practice;
  • Working with other local assessment leads and external assessment experts on moderation activities.

And, on top of this, there is a range of unspecified additional responsibilities associated with the statutory tests.

It is highly unlikely that this range of responsibilities could be undertaken effectively by a single person in less than half a day a week, as a bare minimum. There will also be periods of more intense pressure when a substantially larger time allocation is essential.

The corresponding salary cost for a ‘senior leader’ might be £3,000-£4,000 per year, not to mention the cost of undertaking the other responsibilities displaced.

There will also need to be a sizeable school budget and time allocation for staff to undertake reviews, professional development and moderation activities.

Moderation itself will bear a significant cost. Internal moderation may have a bigger opportunity cost but external moderation will otherwise be more expensive.

Explanatory note (E), attached to the Design Checklist, says:

‘The exact form of moderation will vary from school to school and from subject to subject. The majority of moderation (in schools large enough to support it) will be internal but all schools should undertake a proportion of external moderation each year, working with partner schools and local agencies.’

Hence the cost of external moderation will fall disproportionately on smaller schools with smaller budgets.

It would be wrong to suggest that this workload is completely new. To some extent these various responsibilities will be undertaken already, but the Commission’s recommendations are effectively a ratcheting up of the demand on schools.

Rather than insisting on these responsibilities being allocated to a single individual with other senior management responsibilities, it might be preferable to set out the responsibilities in more detail and give schools greater flexibility over how they should be distributed between staff.

Some of these tasks might require senior management input, but others could be handled by other staff, including paraprofessionals.

.

National support

Recommendation 7 (part): Furthermore, excellent practice in assessment should be identified and publicised, with the Department for Education responsible for ensuring that this is undertaken.

Recommendation 8 (part): Schools should be prepared to submit their assessment to external moderators, who should have the right to provide a written report to the head teacher and governors setting out a judgement on the quality and reliability of assessment in the school, on which the school should act. The Commission is of the view that at least some external moderation should be undertaken by moderators with no vested interest in the outcomes of the school’s assessment. This will avoid any conflicts of interest and provide objective scrutiny and broader alignment of standards across schools.

Recommendation 9: Schools should identify a trained assessment lead, who will work with other local leads and nationally accredited assessment experts on moderation activities.

Recommendation 11: The Ofsted school inspection framework should explore whether schools have effective assessment systems in place and consider how effectively schools are using pupil assessment information and data to improve learning in the classroom and at key points of transition between key stages and schools.

Recommendation 14: Further work should be undertaken to improve training for assessment within initial teacher training (ITT), the newly qualified teacher (NQT) induction year and on-going professional development. This will help to build assessment capacity and support a process of continual strengthening of practice within the school system.

Recommendation 15: The Universities’ Council for the Education of Teachers (UCET) should build provision in initial teacher training for delivery of the essential assessment knowledge.

Recommendation 16: All those responsible for children’s learning should undertake rigorous training in formative, diagnostic and summative assessment, which covers how assessment can be used to support teaching and learning for all pupils, including those with special educational needs. The government should provide support and resources for accredited training for school assessment leads and schools should make assessment training a priority.

Recommendation 17: A number of pilot studies should be undertaken to look at the use of information technology (IT) to support and broaden understanding and application of assessment practice.

Recommendation 19: To assist schools in developing a robust framework and language for assessment, we call upon the NAHT to take the lead in expanding the principles and design checklist contained in this report into a full model assessment policy and procedures, backed by appropriate professional development.

There are also several additional proposals in the commentary that do not make it into the formal recommendations:

  • Schools should be held accountable for the quality of their assessment practice as well as their assessment results, with headteachers also appraising teachers on their use of assessment. (The first part of this formulation appears in Recommendation 11 but not the second.) (p17);
  • It could be useful for the teaching standards to reflect further assessment knowledge, skills and understanding (p17);
  • A national standard in assessment practice for teachers would be a useful addition (p18);
  • The Commission also favoured the approach of having a lead assessor to work with each school or possibly a group of schools, helping to embed good practice across the profession (p18).

We need to take stock of the sheer scale of the infrastructure that is being proposed and its likely cost.

In respect of moderation alone, the Report is calling for sufficient external moderators, ‘nationally accredited assessment experts’ and possibly lead assessors to service some 17,000 primary schools.

Even if we assume that these roles are combined in the same person and that each person can service, say, 25 schools, that still demands something approaching a cadre of 700 people who also need to be supported, managed and trained.

If they are serving teachers there is an obvious opportunity cost. Providing a service of this scale would cost tens of millions of pounds a year.

Turning to training and professional development, the Commission is proposing:

  • Accredited training for some 17,000 school assessment leads (with an ongoing requirement to train new appointees and refresh the training of those who undertook it too far in the past);
  • ‘Rigorous training in formative, diagnostic and summative assessment, which covers how assessment can be used to support teaching and learning for all pupils, including those with special educational needs’ for everyone deemed responsible for children’s learning, so not just teachers. This will include hundreds of thousands of people in the primary sector alone.
  • Revitalised coverage of assessment in ITE and induction, on top of the requisite professional development package.

The Report says nothing of the cost of developing, providing and managing this huge training programme, which would cost some more tens of millions of pounds a year.

I am plucking a figure out of the air, but it would be reasonable to suggest that moderation and training costs combined might require an annual budget of some £50 million – and quite possibly double that. 

Unless one argues that the testing regime should be replaced by a national sampling process – and while the Report says some of the Commission’s members supported that, it stops short of recommending it – there are no obvious offsetting savings.

It is disappointing that the Commission made no effort at all to quantify the cost of its proposals.

These recommendations provide an excellent marketing opportunity for some of the bodies represented on the Commission.

For example, the CIEA press release welcoming the Report says:

‘One of the challenges, and one that schools will need to meet, is in working together, and with local and national assessment experts, to moderate their judgements and ensure they are working to common standards across the country. The CIEA has an important role to play in training these experts.’

Responsibility for undertaking pilot studies on the role of IT in assessment is not allocated, but one assumes it would be overseen by central government and also funded by the taxpayer.

Any rollout from the pilots would have additional costs attached and would more than likely create additional demand for professional development.

The reference to DfE taking responsibility for sharing excellent practice is already a commitment in the consultation document:

‘…we will provide examples of good practice which schools may wish to follow. We will work with professional associations, subject experts, education publishers and external test developers to signpost schools to a range of potential approaches.’ (paragraph 3.8).

Revision of the School Inspection Framework will require schools to give due priority to the quality of their assessment practice, though Ofsted might reasonably argue that it is already there.

Paragraph 116 of the School Inspection Handbook says:

‘Evidence gathered by inspectors during the course of the inspection should include… the quality and rigour of assessment, particularly in nursery, reception and Key Stage 1.’

We do not yet know whether NAHT will respond positively to the recommendation that it should go beyond the model assessment criteria it has already commissioned by leading work to expand the Principles and Design Checklist into ‘a full model assessment policy and procedures backed by appropriate professional development’.

There was no reference to such plans in the press release accompanying the Report.

Maybe the decision could not be ratified in time by the Association’s decision-making machinery – but this did not prevent the immediate commissioning of the model criteria.

.

Phased Implementation

Recommendation 10: Ofsted should articulate clearly how inspectors will take account of assessment practice in making judgements and ensure both guidance and training for inspectors is consistent with this.

Recommendation 12: The Department for Education should make a clear and unambiguous statement on the teacher assessment data that schools will be required to report to parents and submit to the Department for Education. Local authorities and other employers should provide similar clarity about requirements in their area of accountability.

Recommendation 13: The education system is entering a period of significant change in curriculum and assessment, where schools will be creating, testing and revising their policies and procedures. The government should make clear how they will take this into consideration when reviewing the way they hold schools accountable as new national assessment arrangements are introduced during 2014/15. Conclusions about trends in performance may not be robust.

Recommendation 18: The use by schools of suitably modified National Curriculum levels as an interim measure in 2014 should be supported by the government. However, schools need to be clear that any use of levels in relation to the new curriculum can only be a temporary arrangement to enable them to develop, implement and embed a robust new framework for assessment. Schools need to be conscious that the new curriculum is not in alignment with the old National Curriculum levels.

Recommendation 20: Schools should be asked to publish their principles of assessment from September 2014, rather than being required to publish a detailed assessment framework, which instead should be published by 2016. The development of the full framework should be outlined in the school development plan with appropriate milestones that allow the school sufficient time to develop an effective model.

Recommendation 21: A system wide review of assessment should be undertaken. This would help to repair the disjointed nature of assessment through all ages, 2-19.

The Commission quite rightly identifies a number of issues caused by the implementation timetable, combined with continuing uncertainty over aspects of the Government’s plans.

At the time of writing, the response to the consultation document has still not been published (though it was due in autumn 2013) yet schools will be implementing the new National Curriculum from this September.

The Report says:

‘There was strong concern expressed about the requirement for schools to publish their detailed curriculum and assessment framework in September 2014.’

This is repeated in Recommendation 20, together with the suggestion that this timeline should be amended so that only a school’s principles for assessment need be published by this September.

I have been trying to pin down the source of this requirement.

Schedule 4 of The School Information (England) (Amendment) Regulations 2012 do not require the publication of a detailed assessment framework, referring only to

‘The following information about the school curriculum—

(a)  in relation to each academic year, the content of the curriculum followed by the school for each subject and details as to how additional information relating to the curriculum may be obtained;

(b)  in relation to key stage 1, the names of any phonics or reading schemes in operation; and

(c)  in relation to key stage 4—

(i)            a list of the courses provided which lead to a GCSE qualification,

(ii)          a list of other courses offered at key stage 4 and the qualifications that may be acquired.’

I could find no Government guidance stating unequivocally that this requires schools to carve up all the National Curriculum programmes of study into year-by-year chunks.  (Though there is no additional burden attached to publication if they have already undertaken this task for planning purposes.)

There are references to the publication of Key Stage 2 results (which will presumably need updating to reflect the removal of levels), but nothing on the assessment framework.

Moreover, the DfE mandatory timeline says that from the Spring Term of 2014:

‘All schools must publish their school curriculum by subject and academic year, including their provision of personal, social, health and economic education (PSHE).’

(The hyperlink returns one to the Regulations quoted above.)

There is no requirement for publication of further information in September.

I wonder therefore if this is a misunderstanding. I stand to be corrected if readers can point me to the source.

It may arise from the primary assessment and accountability consultation document, which discusses publication of curricular details and then proceeds immediately to discuss the relationship between curriculum and assessment:

‘Schools are required to publish this curriculum on their website…In turn schools will be free to design their approaches to assessment, to support pupil attainment and progression. The assessment framework must be built into the school curriculum, so that schools can check what pupils have learned and whether they are on track to meet expectations at the end of the key stage, and so that they can report regularly to parents.’ (paras 3.4-3.5)

But this conflation isn’t supported by the evidence above and, anyway, these are merely proposals.

That said, it must be assumed that the Commission consulted its DfE observer on this point before basing recommendations on this interpretation.

If the observer’s response was consistent with the Commission’s interpretation, then it is apparently inconsistent with all the material so far published by the Department!

It may be necessary for NAHT to obtain clarification of this point given the evidence cited above.

That aside, there are issues associated with the transition from the current system to the future system.

The DfE’s January 2014 ‘myths and facts’ publication says:

‘As part of our reforms to the national curriculum, the current system of “levels” used to report children’s attainment and progress will be removed from September 2014. Levels are not being banned, but will not be updated to reflect the new national curriculum and will not be used to report the results of national curriculum tests. Key Stage 1 and Key Stage KS2 [sic] tests taken in the 2014 to 2015 academic year will be against the previous national curriculum, and will continue to use levels for reporting purposes

Schools will be expected to have in place approaches to formative assessment that support pupil attainment and progression. The assessment framework should be built into the school curriculum, so that schools can check what pupils have learned and whether they are on track to meet expectations at the end of the key stage, and so that they can report regularly to parents. Schools will have the flexibility to use approaches that work for their pupils and circumstances, without being constrained by a single national approach.’

The reference here to having approaches in place – rather than the publication of a ‘detailed curriculum and assessment framework’ – would not seem wildly inconsistent with the Commission’s idea that schools should establish their principles by September 2014, and develop their detailed assessment frameworks iteratively over the two succeeding years. However, the Government needs to clarify the position.

Since Key Stage 2 tests will not dispense with levels until May 2016 (and they will be published in the December 2015 Performance Tables), there will be an extended interregnum in which National Curriculum Levels will continue to have official currency.

Moreover, levels may still be used in schools – they are not being banned – though they will not be aligned to the new National Curriculum.

The Report says:

‘…it is important to recognise that, even if schools decide to continue with some form of levels, the new National Curriculum does not align to the existing levels and level descriptors and this alignment is a piece of work that needs to be undertaken now.’ (p19).

However, the undertaking of this work does not feature in the Recommendations, unless it is implicit in the production by NAHT of ‘a full model assessment policy and procedures’, which seems unlikely.

One suspects that the Government would be unwilling to endorse such a process, even as a temporary arrangement, since what is to stop schools from continuing to use this new improved levels structure more permanently?

The Commission would appear to be on stronger ground in asking Ofsted to make allowances during the interregnum (which is what I think Recommendation 10 is about) especially given that, as Recommendation 13 points out, evidence of ‘trends in performance may not be robust’.

The point about clarity over teacher assessment is well made – and one hopes it will form part of the response to the primary assessment and accountability consultation document when that is eventually published.

The Report itself could have made progress in this direction by establishing and maintaining a clearer distinction between statutory and internal teacher assessment.

The consultation document itself made clear that KS2 writing would continue to be assessed via teacher assessment rather than a test, and, moreover:

‘At the end of each key stage schools are required to report teacher assessment judgements in all national curriculum subjects to parents. Teachers will judge whether each pupil has met the expectations set out in the new national curriculum. We propose to continue publishing this teacher assessment in English, mathematics and science, as Lord Bew recommended.’ (para 3.9)

But what it does not say is what requirements will be imposed to ensure consistency across this data. Aside from KS2 writing, will they also be subject to the new scaled scores, and potentially deciles too?

Until schools have answers to that question, they cannot consider the overall shape of their assessment processes.

The final recommendation, for a system-wide review of assessment from 2-19 is whistling in the wind, especially given the level of disruption already caused by the decision to remove levels.

Neither this Government nor the next is likely to act upon it.

 

Conclusion

The Commission’s Report moves us forward in broadly the right direction.

The Principles, Design Checklist and wider recommendations help to fill some of the void created by the decision to remove National Curriculum levels, the limited nature of the primary assessment and accountability consultation document and the inordinate delay in the Government’s response to that consultation.

We are in a significantly better place as a consequence of this work being undertaken.

But there are some worrying inconsistencies in the Report as well as some significant shortcomings to the proposals it contains. There are also several unanswered questions.

Not to be outdone, I have bound these up into a series of recommendations directed at NAHT and its Commission. There are 23 in all and I have given mine letters rather than numerals, to distinguish them from the Commission’s own recommendations.

  • Recommendation A: The Commission should publish all the written evidence it received.
  • Recommendation B: The Commission should consult on key provisions within the Report, seeking explicit commitment to the Principles from DfE, Ofqual and Ofsted.
  •  Recommendation C: The Commission should ensure that its Design Checklist is fully consistent with the Principles in all respects. It should also revisit the internal logic of the Design Checklist.
  • Recommendation D: So far as possible, ahead of the primary assessment and accountability consultation response, the Commission should distinguish clearly how its proposals relate to statutory teacher assessment, alongside schools’ internal assessment processes.
  • Recommendation E: NAHT should confirm who it has commissioned to produce model assessment criteria and to what timetable. It should also explain how these criteria will be ‘nationally standardised’.
  • Recommendation F: The Commission should clarify whether the trained assessment lead mentioned in Recommendation 9 is the same or different to the ‘senior leader who is responsible for assessment’ mentioned in the Design Checklist.
  • Recommendation G: The Commission should set out more fully the responsibilities allocated to this role or roles and clarify that schools have flexibility over how they distribute those responsibilities between staff.
  • Recommendation H:  NAHT should clarify how the model criteria under development apply – if at all – to the wider school curriculum in all schools and to academies not following the National Curriculum.
  • Recommendation I: NAHT should clarify how the model criteria under development will allow for the fact that in all subjects all schools enjoy flexibility over the positioning of content in different years within the same key stage – and can also anticipate parts of the subsequent key stage.
  • Recommendation J: NAHT should clarify whether the intention is that the model criteria should reflect the allocation of content to specific terms as well as to specific years.
  • Recommendation K: The Commission should explain how its approach to internal assessment will help predict future performance in end of Key Stage tests.
  • Recommendation L: The Commission should shift from its narrow and ‘mildly accelerative’ view of high attainment to accommodate a richer concept that combines enrichment (breadth), extension (depth) and acceleration (faster pace) according to learners’ individual needs.
  • Recommendation M: The Commission should incorporate a fourth ‘far exceeded’ assessment judgement, since the ‘exceeded’ judgement covers too wide a span of attainment.
  • Recommendation N: NAHT should clarify whether its model criteria will extend into KS3, to accommodate assessment against the criteria for at least year 7, and ideally beyond.
  • Recommendation O: The Commission should clarify whether anticipating criteria for a subsequent year is a cause or a consequence of being judged to be ‘exceeding’ expectations in the learner’s own chronological year.
  • Recommendation P: The Commission should confirm that numerical summaries of assessment criteria – as well as any associated ranking positions – should be made available to parents who request them.
  • Recommendation Q: The Commission should explain why schools should be forbidden from ranking learners against each other (or allocating them to deciles).
  • Recommendation R: The Commission should assess the financial impact of its proposals on schools of different sizes.
  • Recommendation S: The Commission should cost its proposals for training and moderation, identifying the burden on the taxpayer and any offsetting savings.
  • Recommendation T: NAHT should clarify its response to Recommendation 19, that it should lead the development of a full model assessment policy and procedures.
  • Recommendation U: The Commission should clarify with DfE its understanding that schools are required to publish a detailed curriculum and assessment framework by September 2014.
  • Recommendation V: The Commission should clarify with DfE the expectation that it should have in place ‘approaches to formative assessment’ and whether the proposed assessment principles satisfy this requirement.
  • Recommendation W: The commission should clarify whether it is proposing that work is undertaken to align National Curriculum levels with the new National Curriculum and, if so, who it proposes should undertake this.

So – good overall – subject to these 23 reservations!

Some are more significant than others. Given my area of specialism, I feel particularly strongly about those that relate directly to high attainers, especially L and M above.

Those are the two I would nail to the door of 1 Heath Square.

.

GP

March 2014

2 thoughts on “Challenging NAHT’s Commission on Assessment

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