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					DEPARTMENT FOR EDUCATION AND SKILLS

RESPONSE TO STRB WORKLOAD REPORT

This response is organised into four sections.

In the first, the Department gives DfES Ministers’ overall response to the Review
Body’s May 2002 Special Review of Approaches to Reducing Teacher Workload,
taking account of the consultation the Department initiated on the report.

The second section responds to the principles advocated in the report.

The third section responds to a number of particular additional recommendations in
the report where the response would not already be clear from section two.

Finally, section four summarises DfES Ministers’ formal proposals for consultation in
response to the report. Comments on these should be with the Department by
Tuesday 26 November 2002 – the short consultation period has been determined
after informal discussions with national partners. Comments should be sent to the
following address:

       Clive Rayner
       Department for Education and Skills
       Sanctuary Buildings (Area 4D15)
       Great Smith Street
       LONDON SW1P 3BT

       or

       STRB.workload@dfes.gsi.gov.uk

SECTION ONE – OVERALL RESPONSE

DfES Ministers welcome the report produced by the Review Body and are grateful to
members for the additional work that went into it, over and above the normal STRB
cycle. They consider that the report represents a constructive response to the issues
raised in the Secretary of State’s Social Market Foundation pamphlet –
Professionalism and Trust – of November 2001; and the independent study by
PricewaterhouseCoopers (PwC) giving evidence of teachers’ workload of December
2001.

The workload issues are crucial to the task of raising standards of achievement for
our pupils. We must free teachers to teach, and to spend more time preparing high
quality lessons that are differentiated according to the needs and abilities of their
pupils. This is vital to the aim of significantly narrowing the pupil achievement gap.

The Department has conducted extensive consultations with its partners on the
principles in the report. In parallel with this formal public response, it is also
publishing today:

      Time for Standards. This updates the policy framework in England on school
       workforce remodelling and provides an overview both of the present
       document and those listed below;

      Developing the Role of Support Staff. This consultation paper covers


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       England only and will have the standard period for comments. The closing
       date is 22 January 2003;

      Draft Regulations to be made by the Department in England under Section
       133 of the Education Act – this consultation paper, which bears on respective
       teacher and support staff roles and the requirement for supervision, has a
       closing date for comments of 22 January 2003;

      Guidance on planning for primary teachers in England. This is part of the
       attack on bureaucracy, and has been developed with Ofsted and the QCA to
       help teachers reduce unnecessary documentation when planning.

SECTION TWO - PRINCIPLES

STRB proposed that there should be downward pressure on non-teaching work by

      Delegation of appropriate work to support staff

      Strict management of initiatives and reporting requirements

The Department endorses the importance of these principles.

Support staff

The investment the Department is making over the next three years in schools in
England, building on record investment since 1997, should allow for further rapid
build up of support staff in schools. But it will be critical for schools to use the new
budget freedoms we are giving them to allocate resources in a prudent way,
including by remodelling some of their existing baseline expenditure.

Support staff can, with appropriate induction and training, and appropriate
management and supervision, make a powerful contribution to the life of our schools
and the core task of raising standards of achievement. In doing so, they can also
relieve teachers and headteachers of many burdens.

Indeed, we shall not be able to deliver in England any of the contractual
changes set out in this document unless schools here carry forward the
reforms in our support staff consultation paper: this is what will release the
extra time for teachers and reduce their workloads. It will not be possible to
make or deliver contractual changes unless we can reach an agreement with
our partners on reforming the teaching profession and restructuring the school
workforce.

In general terms, there are four main areas of work in which different types of support
staff can contribute. The following are only examples:

       A.       Administrative and other ancillary roles

                      Admin support to teachers / Heads
                      Health and safety / site managers
                      Attendance Clerks
                      Timetabling officers
                      Exam officers
                      ICT technicians.



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          B.      Roles involving contact with pupils and parents, but not involving
                  teaching activity

                         Invigilators
                         Behaviour managers
                         Careers advisers
                         Learning mentors/advice and guidance
                         Cover supervisors.

          C.      Roles involving fuller contact with pupils and parents, involving
                  teaching activity, subject to supervision by a qualified teacher

                         High-level Teaching Assistants
                         Sports coaches
                         Music and Drama specialists
                         Language assistants.

          D.      Senior staff roles of a managerial kind

                         Business managers/bursars
                         HR/personnel managers
                         Lead behaviour managers
                         Facilities managers.

Support staff numbers now stand at over 216,000 (full-time equivalent) in our 23,000
schools in England. The Department’s recent and planned investment means that,
during this Parliament alone, support staff numbers in England will have grown by at
least 50,000. And this growth has not been at the expense of teacher numbers,
which have also been rising and where there is a commitment to an extra 10,000 or
more teachers in England during this Parliament.

It is inconceivable that such an unprecedented growth in the number of adults in our
schools could fail to ease teacher workloads. This quiet revolution is making schools
in England unrecognisable compared to the staffing picture even of ten years ago.
But, to reap the full benefits, schools will need to sharpen their practice in how
support staff are best deployed. This issue is explored further in the Department’s
consultation paper published today on the roles of support staff in England1.

Bureaucracy

The STRB and PwC have made plain the importance of streamlining paperwork and
other requirements stemming not just from Government but from other national
bodies, and from local authorities. In the next phase of reform, we must make a
concerted attack on all unnecessary burdens placed on teachers and heads, to help
schools raise standards still further.

This will require a change of culture right across the education service, with the
Department leading by example. And it will require some formal structures and
mechanisms which can sort out what is necessary from what is unnecessary and
refine systems as far as possible to make them less burdensome. This will also meet
concerns remaining from the Haskins report on red tape.

1
    “Developing the role of school support staff” – DfES, October 2002


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We have already begun to make strides ourselves. A 50% cut has been achieved in
what the Department sends to schools. Moreover, DfES, Ofsted, QCA, TTA and the
Learning and Skills Council are committed to a joint programme. Action has started
with advice endorsed by DfES, Ofsted and QCA on cutting unnecessary
documentation associated with lesson planning in primary schools2 – a major
concern raised by the PWC workload study. Other areas being tackled are
communications, funding streams, school and LEA level planning, and eliminating
duplicate data collection. More details will be published as part of a joint report with
Cabinet Office on cutting red tape in schools.

The priority is scrutiny of systems to minimise red tape, duplication of effort and
unnecessary burdens. We need a means of reviewing education processes and
finding better ways through.

We therefore intend to establish an Implementation Review Unit in England, which
will have a panel of experienced, serving headteachers to provide a feedback
mechanism on policy implementation, to provide a challenge function on existing
systems, and a sounding board on innovation. We expect there to be some
nominated headteachers from partner organizations. The panel will:

         Meet quarterly;
         Be serviced by a dedicated team drawn from inside and outside government;
         Produce a public annual report;
         Have access to call in NDPBs;
         Learn from the experience of the Better Regulation Unit;
         Meet Ministers six monthly;
         Set its own work programme.

There will be one member in each region, acting as a local champion for reducing
bureaucracy, talking to neighbouring schools, encouraging LEAs to play their part,
and making sure that grass-roots concerns get through to DfES and central agencies
and are tackled.

The Unit will meet the concerns of the STRB for a mechanism which will ensure:

         A more rigorous assessment of the need for initiatives and fewer of them;
         Better management of initiatives, including trials and evaluation before
          national implementation, thus avoiding constant modifications;
         More resolute matching of initiatives to capacity;
         Regular review of requirements and the removal of these which are no longer
          necessary.

The establishment of the Unit and panel is dependent on reaching agreement with
our partners.

The Review Body also proposed that there should be early reduction in the pressures
on teachers through:

         A contractually guaranteed allocation of time for planning, preparation,
          marking and recording, part of which will be in the timetabled week;


2
    “Planning guidance for primary teachers” – DfES / Ofsted / QCA, October 2002.


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         A contractual limit on the number of hours per year in which individuals are
          expected to cover for absent colleagues.

The Department endorses the general thrust of these principles: there will be a
need to clarify some practical issues to ensure effective implementation.

Guaranteed time

The Department agrees with STRB about the potential merits of introducing
guaranteed professional time for planning, preparation and assessment (PPA). This
should both help ease teachers’ workload and also give teachers the space they
need to ensure lessons are well prepared and take account of the individual needs
and circumstances of pupils in the class. It is at the heart of the reforms set out in
our document published today, Time for Standards3.

Section 4 sets out a formal proposition for consultation purposes. But, in more detail,
we see the key elements of PPA as follows:

         PPA is intended to support teachers’ teaching, whether through individual or
          collaborative work, and has the clear purpose of helping teachers to raise
          standards;
         schools would be able to introduce PPA time with immediate effect and,
          subject to the outcome of consultation, and finalising an agreement with
          national partners, will be obliged to do so from September 2005;
         Because this would be guaranteed time, it could not be eroded by any
          obligation to cover for absent colleagues;
         PPA should be set at the equivalent of at least 10% of a teacher’s teaching
          time, eg a teacher teaching 20 hours per week would have 2 hours per week
          of guaranteed PPA;
         Only teaching time within a teacher’s 1265 contracted hours would count for
          these purposes, not other forms of pupil contact time;
         PPA time would itself be in “directed” time (and sometimes in the timetabled
          week) and would therefore count towards a teacher’s 1265 contractual
          hours4;
         this contractual PPA would be distinct from any planning, preparation or
          assessment undertaken outside the 1265 hours, as part of a teacher’s
          professional duties;
         consultees will be asked to comment, inter alia, on whether PPA should be
          timetabled in by heads as a weekly entitlement, or whether it should be
          subject to an aggregated approach, over a month, half-term, full term or year.

At the appropriate time, the Department would be likely to ask Ofsted to keep under
review the use of PPA time, and to offer guidance on good practice.

Cover

The Department concurs with the analysis of the present cover arrangements set out
in the Review Body’s report. Moreover, the current system tends to encourage a
crisis management approach to cover, rather than a planned and orderly approach
based on historic patterns of absence.


3
    “Time for Standards” – DfES, October 2002
4
    See paragraph 67 of “School Teachers’ Pay and Conditions Document 2002” – DfES, 2002.


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The Department has decided to consult on the change recommended by the STRB,
and proposes that:

      The amount of cover a teacher could be required to provide for absent
       colleagues would be calculated by reference to the covering teacher, not the
       absent teacher as at present;
      This limit on cover would be set at 38 hours of cover per year per teacher: this
       annualised approach would help schools cope with variations over the year;
      The requirement to cover would be subordinate to the PPA provisions above;
      The limit would be introduced to have contractual effect no later than
       September 2004;
      There would be an exemption clause where providing cover is one of the
       agreed primary purposes of a particular teacher’s job description.

The Department has it in mind to develop guidance on effective practice for schools
in relation to cover. This would help them make a successful transition from the
current system to the new one. And it would acknowledge that the supply of
teachers is finite. The elements of good practice, drawn from what innovative
schools are already doing, would be likely to include:

      Cover supervisors, where support staff with appropriate skills and training are
       able to manage pupils in their own classroom when their teacher is absent;
      The establishment of ICT learn centres, with supervision by an appropriate
       adult;
      Setting staffing levels to take account of historic levels of cover in the school:
       this ensures that cover can be absorbed in-house, with less reliance on
       supply teachers who will not be familiar with the school and whose quality is
       unknown in advance.

The STRB also proposed that, to support the framework of principles and give
leverage to change, there should be:

      Incorporation within the STCPD of a work/life balance clause to act as a
       restraint on the potential for unlimited demands offered by paragraph [67.7] of
       the Document;

      Adoption of targets by the Department to achieve a reduction of average
       weekly term-time hours worked by teachers from 52 to 48 at the end of two
       school years and to 45 at the end of four school years.

The Department shares the STRB’s concern that some teachers are working
excessive hours and that action is needed to address this.

A tired teacher cannot be a fully effective teacher and this must impact negatively on
pupil standards of achievement. Working with our partners in the education service,
we must find ways of bearing down on this problem. However, we are concerned
that the precise practical details of the STRB’s recommendations may not be
workable. We reflect this in the proposals below.

Work/life balance

The Department strongly endorses the importance of a healthy work/life balance. It
considers that schools have the same responsibility as any organization for ensuring
that staff are not exploited. Through its Implementation Review Unit proposals



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above, the Department has acknowledged that it, alongside the national and local
partners in education, have a responsibility to help schools to help teachers deal with
excessive overall workloads.

In their report, the STRB make some specific proposals for new clauses on work/life
balance for insertion in the teacher contract. The Department has every intention of
promoting work/life balance for teachers. However, after careful reflection, we are
concerned that the wording offered in good faith by the Review Body could be
unclear if it were required to be tested in the courts. Although this would not happen
often, it would be precisely at such a moment when the credibility of the provision
would be under most pressure. Moreover, any lack of clarity would also undermine
the sense that the clause offered teachers some entitlement, insofar as this was part
of the purpose of making a contractual change.

Consequently, the Department intends to continue exploring urgently with our
partners other options for contractual change over work/life balance. The aim is to
secure a provision that is more than symbolic, that is clear in terms of its legal
meaning and import, and that avoids introducing any new bureaucracy. If a suitable
provision can be implemented, the Department will consult with Ofsted about
monitoring arrangements.

Reducing excessive hours

The Department considers that we must have a campaign in England to get
downward movement on excessive hours. This must also involve reducing the
average weekly term-time hours from the current 52. The pace of progress on this
will depend on how quickly schools are able to make progress with remodelling the
school workforce and the use of time. But the Department considers it is right to aim
for progressive reductions in average overall hours over the period to 2006.

It sees three main ways of doing this.

Firstly, the proposals for an Implementation Review Unit. These must result in better
streamlining and therefore remove some of the pressures and paperwork from heads
and teachers.

Secondly, the next phase of ICT investment. This should help teachers reap
significant benefits, whether it be in terms of quicker and more efficient administrative
work, or of downloading lesson plans from the web. Learning to be efficient will take
some additional effort to begin with. But it is not credible to argue that ICT cannot
save teachers time.

Thirdly, the transfer of a range of tasks from teachers to support staff. At present, too
many teachers are spending significant amounts of time on the tasks listed at
appendix 1. The Department proposes that these tasks should be routinely
delegated. In the consultation, it is seeking views on the following propositions:

      the 25 tasks at appendix 1 should be defined more fully, to remove ambiguity
       as far as possible, in keeping with their new contractual status;
      the teachers’ contract should be changed with effect from September 2003,
       so that no teacher can be routinely required to undertake these tasks, subject
       to any phasing as below;
      phasing should not apply across the board; it is relevant only where national
       partners or other consultees make a reasoned case for delay over a small



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       number of tasks, or to assist very small schools; and, even in these cases, we
       propose that the implementation date be no later than September 2005.

In addition, STRB proposed that:

      Leadership group members be allocated sufficient time to carry out their
       leadership responsibilities;

      An entitlement be given to continuing professional development (CPD) for all
       teachers, including the option for them to undertake an additional five days
       outside the school year, with fees and expenses paid.

The Department endorses the view that leaders need time to carry out their
leadership work. However, it does not intend to proceed with the CPD
proposal above, in light of the recent consultation.

Leadership time

The Department endorses the principle of leadership time. It now wishes to explore
in more detail with the partners how this might be given practical and contractual
effect, from the earliest possible date. As the Review Body argues, this will mean
provisions so that Governing Bodies ensure headteachers get adequate leadership
time; and so that headteachers ensure other members of the leadership group get
adequate leadership time.

CPD

The CPD proposals did not attract support in principle from the majority of our
partners, so the Department does not intend to proceed with them.

However, the Review Body’s proposals raise two important issues. Firstly, the need
for CPD to be embedded as part of each teacher’s responsibilities. CPD should not
merely be an entitlement but a duty, insofar as the main focus of CPD should be on
raising standards of pupil achievement. In addition, teachers who have real potential
to benefit should be able to access programmes to help develop them for future
roles, eg leadership roles. Schools need to take account of the responsibility
teachers have for taking their professional development seriously, and to integrate
professional development into the teaching and learning process; but they also need
to balance this against disruption of pupils’ education. Consequently, this is not an
area which will necessarily lend itself to straightforward contractual provisions in
teachers’ contracts.

We believe the right approach, embodied in our Performance Management reforms
in England, in the various DfES National Strategies and in the CPD Strategy we
published last March, is to place responsibility for professional development where it
belongs, with teachers themselves, their senior colleagues and headteachers, and
encourage teachers to learn from each other and from what works. The Department
should then support this by creating an increasingly wide range of different
professional development opportunities, with appropriate funding, on which teachers
can draw to increase their skills and raise standards.

The second issue is how school closure days are being used in some schools. In the
best cases, teachers are working individually and collaboratively on how to raise
standards of pupil achievement. This should be the aspiration for every school and
the Department intends to explore further, with the help of the GTC for England in


                                          8
particular, how to assist the spread of good practice.

SECTION THREE – REMAINING DETAILED RECOMMENDATIONS

The Review Body proposed that the school workforce pathfinder programme should
include schools exploring PPA ratios

The Department has implemented this proposal and will be evaluating the outcomes
in a number of the pathfinder schools which began work last month.

The Review Body proposed that certain detailed questions of location of work and
specification of duties be included in statutory guidance

The Department is not minded to change current statutory or guidance provisions on
location of work. It considers that the STPCD already makes clear the current
position in relation to directed time. On specification of duties, the provisions of
STPCD are to be augmented by a partial codification under section 133 of the
Education Act 2002, with supporting guidance. A draft of the regulations and
guidance, which apply to England, has been published today in tandem with this and
other documents (see page 1 of this note).

SECTION FOUR – FORMAL GOVERNMENT PROPOSALS FOR CONSULTATION

The Department invites comments by Tuesday 26 November 2002 on the following
proposals and questions:

Contractual matters

These are matters which would result in changes to the School Teachers’ Pay and
Conditions Document covering teachers in both England and Wales.

A.     25 non-teaching tasks

      i.   Teachers should not routinely be required to do the 25 tasks at
           appendix 1, with this provision taking effect for most tasks in most
           schools from September 2003; and for all tasks in all schools from
           September 2005 at the latest;

     ii.   Each task should be more clearly defined to meet the test of being
           included in a statutory document.

Could every task be covered by the contractual change from September 2003? or is
there a small number that would need later implementation and, if so, why? In
addition, are there issues about the implementation date for very small schools, ie
below 100 pupils?

B.     Cover for absent teachers

      i.   Teachers should not be required to cover for absent colleagues for
           more than 38 hours within their 1265 contracted hours;

     ii.   This provision should have effect from September 2004 at the latest.

Could the proposed implementation date be brought forward earlier, and apply
effectively in every school?


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C.          Planning, preparation and assessment

      i.       Teachers should have guaranteed time for planning and preparing
               high quality lessons and for assessing pupils’ work, effective from
               September 2005 at the latest;

      ii.      This guaranteed time could not be eroded by any obligation to cover
               for absent colleagues;

     iii.      PPA should be set at the equivalent of at least 10% of a teacher’s
               teaching time, where only teaching time within a teacher’s 1265
               contracted hours would count for these purposes, not other forms of
               pupil contact time;

     iv.       PPA time would itself be in “directed” time and would therefore
               count towards a teacher’s 1265 contractual hours;

      v.       This contractual PPA would be distinct from any planning,
               preparation or assessment undertaken outside the 1265 hours, as
               part of a teacher’s professional duties.

Could the proposed implementation date be brought forward earlier, and apply
effectively in every school?

Should PPA be timetabled in by heads as a weekly entitlement, or should it be
subject to an aggregated approach, over a month, half-term, full term or year?

D.          Leadership time

      i.       The Government intends to explore further with national partners
               how best to introduce contractual changes, so that Governing
               Bodies ensure headteachers get adequate leadership time; and
               headteachers ensure other members of the leadership group get
               adequate leadership time;

      ii.      The intention is that these changes should be formulated to take
               effect from September 2005 at the latest.

E.          Work/life balance

       i.      The Government intends to explore further with national partners
               how best to introduce contractual changes, so that schools take
               account of the need for teachers to have a reasonable work/life
               balance.

Non-contractual matters

F.          Bureaucracy

      i.       The Government intends to establish an Implementation Review Unit
               during the early part of 2003.




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G.     Reducing excessive hours

     i.    The Government intends to lead a national campaign to bring
           downward pressure to bear on excessive teacher hours;

     ii.   The intention is that average overall hours should reduce
           progressively in the period 2003 to 2006, as monitored
           independently by the Office of Manpower Economics.

H.     CPD

     i.    The Government intends to explore further, with the help of the GTC
           in particular, how to assist the spread of good school practice over
           the use of school closure days.


Department for Education and Skills
October 2002




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                                                                      Appendix 1

25 NON-TEACHING TASKS

Tasks that classroom teachers should not routinely do

The list from DfEE circular 2/98 now ratified by STRB

      Collecting money
      Chasing absences
      Bulk photocopying
      Copy typing
      Producing standard letters
      Producing class lists
      Record keeping and filing
      Classroom display
      Analysing attendance figures
      Processing exam results
      Collating pupil reports
      Administering work experience
      Administering examinations
      Invigilating examinations
      Administering teacher cover
      ICT trouble shooting and minor repairs
      Commissioning new ICT equipment
      Ordering supplies and equipment
      Stocktaking
      Cataloguing, preparing, issuing and maintaining equipment and materials
      Minuting meetings
      Co-ordinating and submitting bids
      Seeking and giving personnel advice
      Managing pupil data
      Inputting pupil data.




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