4 November 2005
Department for Education & Skills
Inspection Reform Team
3rd Floor, Sanctuary Buildings
Great Smith St
London
SW1P 3BT
Dear Sir/Madam
A single inspectorate for children and learners: response from Sense
Sense welcomes the opportunity to respond to this consultation.
Sense is a national charity that supports and campaigns for children and adults who are deafblind. We provide specialist information, advice and services to deafblind people, their families, carers and the professionals who work with them. In addition, we support people who have sensory impairments with additional disabilities.
Deafblindness is a distinct disability that is more than simply vision loss and hearing loss. The combined effects of not seeing or hearing clearly are experienced uniquely by each deafblind person. Their lives are profoundly affected, particularly by difficulties in communication, mobility, and access to information.
Sense responded to the 2003 Green Paper Every Child Matters, welcoming the five outcomes for children that it listed. However, we pointed out that without specific intervention, deafblind children would not be able to achieve these outcomes. If the desired outcomes described in Every Child Matters are to be a reality for deafblind children, they need a package of services that enables them to participate in education and leisure activities.
The changes that are being proposed
The consultation document puts forward the view that a single inspectorate will benefit users by focusing inspections on their needs and experiences regardless of organisational boundaries, and will reduce duplication. It is true that the boundaries between the remits of the current inspectorates do not match the current pattern of provision. This has led to separate statutory arrangements for joint working - for example, Joint Area Reviews of children’s services are led by Ofsted and involve CSCI and the Adult Learning Inspectorate as well as six other inspectorates.
However, Joint Area Reviews are a new initiative: the first of them only took place in September 2005. We are concerned that frequent changes to the inspection framework for children’s services could risk causing instability and lack of continuity.
We also note the Government’s separate plans to merge CSCI with the Healthcare Commission into a new inspectorate for social care and health.
The main issue for Sense
Under Government guidance issued in 2001[1], deafblind children are entitled to an assessment by their social services department, and to receive the services they are assessed as needing. However, research by Sense[2] demonstrates that deafblind children are not currently receiving the services they need. When Sense surveyed local authorities about their services for deafblind children, only 60 of 171 social services departments in England and Wales answered a question about support for children to take part in activities outside education. Of the 60 who did respond, only 11 were providing trained support workers to deafblind children outside education.
What is needed is for the inspectorate, whether CSCI or an enlarged Ofsted, to examine how well local authorities are implementing the deafblind guidance in relation to children. We believe that this has the potential to bring about a profound improvement in the quality of life of these children.
Sense is concerned that there is no reference to the needs of disabled children in the document. If inspection of children’s social services is transferred to Ofsted as the Government proposes, it is vital that the needs of disabled children remain a high priority, and that the expertise of people qualified to inspect services to disabled children is not lost.
There may be benefits for disabled children in inspection focusing on their needs and experience, regardless of organisational boundaries. However, Sense’s research shows that deafblind children are not currently receiving services to which they are entitled under government guidance. We would welcome an assurance from the DfES that the new inspectorate will hold local authorities to account in the way in which they deliver services to deafblind children, both in and out of education.
Sense believes it is essential that the children’s inspectorate contains staff who are able to specialise in the needs of children with low incidence disabilities such as deafblindness. Only in this way will it be possible to make an assessment of whether local authorities are fulfilling their duties.
Disabled children are more likely to suffer abuse and neglect than other children and this was recognised in the recent joint report, Safeguarding Children. Deafblind children are among the most vulnerable children in society - because of their communication needs, they are often less likely to be able to object to abusive behaviour and to speak out. Services for these children need to be of the highest quality, and whatever the framework for inspection, their needs must be at the centre of the process.
Answers to specific consultation questions
We have responded to questions 2, 3, 6, 7, 8 and 9.
Q2. We would welcome views on whether there should be, in legislation, a single overarching statement to capture the core purpose of the inspectorate and characterise its overall ethos.
Sense does not think that the overarching statement necessarily needs to be in primary legislation. However, we believe that the core purpose of the inspectorate must include the inspection of services to disabled children.
Q3. Paragraph 29 of the consultation document lists other possible high level duties of an enlarged Ofsted. Do you think the list is a fair representation of the duties of a new enlarged inspectorate? We would welcome views on their relative merits as general duties beneath the single, core statutory purpose.
We think that the new inspectorate should be given a general function of encouraging improvement in children’s services. This is mentioned elsewhere in the consultation document, but not in the list of proposed high level duties.
Attention needs to be given to the needs of young people who are making the difficult transition from children’s to adult services. The years between school and adult life are stressful for most young people, but for those with complex disabilities such as deafblindness, even more so. Currently, transition planning and the transition process for deafblind young people are rarely managed effectively, despite the fact that all young people with a statement of educational needs are entitled to a Transition Plan following their Year 9 annual review. Transition should start at 13+, and this early start is particularly important for those with complex and multiple needs, where co-ordinating many services will require time. Services need to develop knowledge of the individual young person and their needs. Specialist input will be needed to ensure adult services are appropriate. The new inspectorate should be given specific responsibility for inspecting the “bridge” between adult and children’s services to ensure that adult services can play an active role in transition planning can commit resources at an early enough stage.
The new inspectorate should be given a statutory duty to co-operate with CSCI, and in due course the new health and social care inspection commission, to ensure that transition services are inspected effectively.
We also believe that the new inspectorate should report to Parliament, not to Ministers.
Q6. Should the separate functions of the Children’s Rights Director be retained under the new arrangements, and if so should they be given to the single inspectorate for children and learners, to the Children’s Commissioner or split between the two?
We do not believe that there is any case for splitting responsibilities between the Children’s Commissioner and the Children’s Rights Director. This would be contrary to the aim of the Government’s proposal to bring responsibility for inspection of children’s services together in one place. It would appear sensible to give the existing functions of the Children’s Rights Director to the new inspectorate.
Q7. The enlarged Ofsted would probably need a new statutory title to match and reflect its wider remit. One idea is the Inspectorate for Children and Learners. We would welcome views on this name.
We would be happy with the proposed statutory title, “Inspectorate for Children and Learners”.
Q8. The question of how it is generally known is also important, but not for statute. Ofsted started as a compression of a longer name - the Office for Standards in Education - but the latter title is no longer in common usage. We would welcome views on how an enlarged Ofsted might be generally known.
We would be much less happy with the new inspectorate to continue to be known commonly as ‘Ofsted’. As the consultation document states, this name is in common use and has widespread recognition. However, changing the statutory title but not the title by which the inspectorate is commonly known would work against the DfES’s sated aim of ensuring that staff that transfer into the new inspectorate have their disciplines and expertise recognised and highly valued within Ofsted’s significantly enlarged remit. We very much welcome this aim and would like to see it emphasised further.
We therefore believe that it will be necessary to change the common, as well as the statutory, name of the inspectorate in order to demonstrate that the new inspectorate will be concerned with a wide range of services to children, not just education.
Q9. Do you support the suggested change in Ofsted’s governance to reflect its enlarged remit? We welcome comments on this proposal.
We would support a model of governance in which the Chief Inspector would be accountable to the new inspectorate rather than one in which he or she would have personal responsibility for some of the inspectorate’s statutory responsibilities.
Thank you again for the opportunity to respond to this consultation. If you would like further information, please contact me on 020 7561 3404 (direct line) or by email at katie.hanson@sense.org.uk.
Yours sincerely
Katie Hanson
Parliamentary and Public Policy Officer
[1] Social Care for Deafblind Children and Adults [LAC (2001) 8]: guidance issued under Section 7 of the Local Authority Social Services Act 1970. Department of Health 2001
[2] Sense Local Authority Survey Results 2004. Sense 2004
