A Shared Quality Framework
The final section of the consultation document set out proposals for a shared quality framework. This would take the form of a self-evaluation tool designed to support services to improve the provision of ELC and SAC for children and families, and would replace the Care Inspectorate’s ‘A quality framework for daycare of children, childminding and school-aged childcare’, and Education Scotland’s ‘How Good is our ELC?’. In the consultation document, it was proposed that the shared quality framework would provide an integrated approach, enable the two inspectorates to work together and assess settings at the same time, and provide just one document for settings to understand what is required of them.
Feedback was sought on whether respondents supported the development of a shared quality framework, the possible benefits and challenges to implementing such a system, whether this would meet the needs of the sector, and which settings and children’s age groups the framework should apply to.
Q3.1 Do you support the proposal to develop a shared quality framework between HMIE and the Care Inspectorate? Can you tell us why you think this?
Q3.1 Do you support the proposal to develop a shared quality framework between HMIE and the Care Inspectorate?
|Number of respondents||Percentage of respondents||Valid %|
Over three quarters (n=191, 78%) of those respondents who answered the question supported the development of a shared quality framework between HMIE and the Care Inspectorate.
The main reasons given in support of the proposal (by respondents from a range of different affiliations) were that it would ensure a more consistent approach to inspection, provide clarity around the expectations of ELC settings (including standards and quality indicators) and would provide clear criteria and a clear focus for improvement actions for staff.
One local authority representative argued for the new shared framework to include quality indicators relating to care, play, nurture, wellbeing and safeguarding, education, development and learning, environments, parental engagement, staffing, self-evaluation, leadership and management. Others (from different organisations) argued that ‘equality’ should be added to this list, and the inspection framework and implementation should draw on existing expertise of other organisations in ensuring that equality outcomes are met. Similarly, one organisation argued that the proposal should include a clear reference to Gaelic Medium Education (GME) and English Medium Education (EME) provision and aligned quality indicators synchronised with the Advice on Gaelic Education, the Statutory Guidance on Gaelic Education and the Gaelic Medium Early Learning and Childcare Guidance.
Opportunities presented by the proposal for ‘streamlining’, to remove bureaucracy and duplication in paperwork and reduce burdens on the sector (especially in terms of staff time required in preparing for and facilitating evaluation) were all welcomed. One respondent suggested that reducing such pressures would be beneficial to the mental wellbeing of staff. The change would also provide a clearer vision for the sector, and build a more cohesive and unified system, it was felt.
Many also supported the proposal on the basis that a shared framework would result in better quality of care for learners/positive outcomes for children, and that it would allow service users and their families to have a better understanding of the inspection process:
“It is our belief that a shared quality framework across ELC and school age childcare services will help to provide clarity and consistency for the sector. It will also help to ensure consistency of approach in how ELC and school age childcare services self-evaluate their work to deliver high quality services for the children and families they serve.” (Sector representative body/membership organisation)
“A single quality framework for all settings, whether or not they provide funded ELC, will provide a national expectation on what quality provision for our children should be.” (Inspectorate Body)
Caveats to support and queries in relation to the proposal included that a single shared inspection framework would not necessary meet needs around inspection versus self-evaluation. For example, not all aspects of self-evaluation may need to be subject to external accountability through inspection and, conversely, any self-evaluation framework used in inspection may not necessarily address all aspects which require to be agreed in the development of a new approach to inspection. Respondents also stressed that any new model must be based on the ethos of ‘support’ rather than ‘scrutiny’.
A view was also offered that the proposed implementation of a new framework should be done in tandem with changes to inspection in other sectors, particularly the primary school sector. Two respondents also suggested that careful consideration should be given to how the new shared framework would dovetail with ‘How Good is our School?’ (HGIOS?) to support headteachers to drive improvement across the whole school community. Aligning the new approach with other changes in education was seen as key to maintain confidence of key stakeholders:
“A series of changes over coming years would be unhelpful to the practitioners and leaders involved. The sector needs well planned, strategic change and leadership to secure stability and build confidence of practitioners, leaders and parents.” (Trade Union)
Similarly, comments were made about the plethora of changing frameworks that had been introduced in recent years and respondents argued for a framework that had longevity (to avoid any more changes being required in the short term). This was raised by both the Care Inspectorate and practitioners alike. Others suggested that merging and tweaking existing frameworks would be more effective than starting from scratch, and could cause less confusion for staff (with some expressing concerns that the existing Care Inspectorate Quality Framework would be lost):
“[There have been] a lot of change for providers over the last few years and many are beginning to break under the strain of getting to grips with new guidance documents. The saying 'if it’s not broke, why fix it' should be borne in mind when reviewing the new Care Inspectorate Quality Framework as it is already well received…” (Individual)
“[For staff] who have just begun to appreciate the clarity and resourcefulness of the Care Inspectorate Quality Framework, there are anxieties that this good resource would be watered down or dominated by academic educational standards which do not apply to their settings. We would suggest that the current content and structure of this framework is retained, with any additional and necessary educational outcomes, specifically for funded early years settings, could be added in as a section, where applicable, and clearly labelled as such. We are amongst those who admire the style, content and rich resourcefulness of this quality framework and it would be a pity to lose any of that.” (Sector representative body/membership organisation)
The need for collaboration and co-production in designing and implementing the shared framework was stressed by several respondents including that there must be collaboration between the education inspectorates, Scottish Social Services Council (SSSC) and the Care Inspectorate (which itself also expressed a desire to work in partnership with Scottish Government, other inspectorates, partner organisations and the sector to work on a single framework). A shared framework should also take account and be cognisant of the extensive consultation recently undertaken by the Care Inspectorate, it was suggested, which had included consultation with services and partner organisations across the sector.
Among the minority who did not support a shared quality framework, the main views were that different settings required more tailored approaches to reflect the wide diversity of work and services that are provided in such settings. Trying to achieve effective inspection of such a broad range of services within one framework was seen as too ambitious and potentially too convoluted:
“…I feel there is too wide a scope over all of the provisions and services for this to be undertaken effectively by a shared framework. It is already a complex and labyrinthine process at present, and I feel this will just add further unneeded multiplicity rather than streamline the process.” (Private or independent or third sector ELC or SAC provider)
Again, views were also offered that the two current inspection organisations had very different functions, cultures and operating models and that it would be difficult to reconcile or merge these into one inspection framework. There was evidence of cynicism that either agency would be prepared to ‘change’ their approach.
Some suggested that the proposed approach did not meet or address the issues highlighted in the Muir report and that the proposals did not go far enough to remove existing challenges already faced by ELC settings. Again, linked to this were views that one inspection agency would be preferable and would be in the best interests of ELC settings (although in the absence of a single inspection body, one framework was considered the next best thing):
“The opportunity should be taken to fully re-imagine inspection to make a real impact on the burdensome and bureaucratic system that is currently in place. We would like to see a move to a single inspection body for local authority provision which supports and inspects the local authority’s approach to safeguarding and improving quality.” (Trade union)
Respondents (including some of those who supported the proposal) questioned why there was a need for two separate bodies if there was only one framework and felt that the improvements sought would only be achieved if a single body was established:
“This is an opportunity to really get inspection processes right, both for the sector and for children and families. Therefore, while [organisation] is in agreement in principle with the vision for a single framework, we feel it is unlikely that there will be any meaningful change if this is not accompanied by the necessary structural changes and the creation of a single inspection body, which encompasses the skillset and expertise of both organisations.” (Sector representative body/membership organisation)
One organisation supported the proposed change as a short-term measure to address the immediate issues in relation to workload and bureaucracy, but noted that wider reform to change the inspection model should be undertaken in the long term. Another stated specifically that the future direction should be a single inspection body:
“It is our view that a shared quality framework has the potential to bring about some improvement and lessen some of the problems in the current system. However, ultimately [organisation] supports the establishment of a single-body approach, recognising that the impact of a shared framework would be limited and cannot, in itself, fully address current challenges.” (Sector representative body/membership organisation)
Having two separate inspection bodies remain over the long term would mean continued inconsistency of approaches and unnecessary pressures on staff, it was felt.
One respondent suggested that inspection should be focussed on schools only and not early learning settings. Another felt that frameworks tended to be “woolly and open to interpretation” and suggested an alternative approach of continuous assessment with a named inspector, (and subsequent inspection by other inspectors), would more quickly ensure consistency across all settings.
One respondent also suggested that full agreement with the proposal was difficult without knowing the final detail of what the framework would look like. A few others also agreed, especially on the basis that it was unclear how the shared framework would apply to out of school care and how it would support childminders (i.e. more information was needed to inform a meaningful response).
Finally, if adopted, respondents urged that implementation must be well thought out and supported.
Q3.2 and Event Q6. What do you consider are the benefits to implementation of a shared quality framework?
The themes identified in relation to the benefits of implementing a shared quality framework were largely consistent between the main written consultation and the events. As such, all response formats are considered below.
The main benefit which respondents felt a shared framework would provide was consistency. This was interpreted broadly, including that there would be consistency in approach and messaging; that everyone would be working to a shared vision and consistent quality indicators; there would be consistency in expectations placed upon different providers and across the sector; it would provide consistency in providers experiences of inspections; consistency in judgements made by inspectorates/inspectors; and consistency in care/standards for children regardless of the setting.
Another significant benefit was felt to be clarity. This included the provision of clearer and more consistent guidance; clarity for providers over what is expected, both in terms of standards and improvement; improved understanding of the inspection process; and tackle the subjectivity of the current approach. A few again suggested it would provide greater clarity for parents/families as well as staff:
“In theory it would provide clarity and hopefully cut down on the confusion over the expectations between the different organisations and inspection processes.” (Private or independent or third sector ELC or SAC provider)
“A clear understanding for parents about what to expect in our child’s nursery.” (Individual)
Both inspectorates and a wide range of other respondents agreed that it would provide a more streamlined and joined up process, with one document/set of guidelines to work with, resulting in the process being less burdensome, less bureaucratic, and with less duplication in work and/or paperwork required. This, it was felt, would result in a more manageable workload, better support self-evaluation, and ultimately, mean that staff are less stressed and have more time to spend with the children and/or implementing improvements. It was also suggested this would result in “shared language” across the sector:
“One framework would stop duplication of paperwork, confusion between what each inspection body wants and allow us to move forward.” (Local authority ELC or SAC provider)
“A shared framework should be less bureaucratic and reduce workload. With concise and clear expectations, it should positively impact on self-evaluation processes.” (Local Authority)
It was felt that such a framework would be easier for staff to use, less confusing, less overwhelming and less stressful, thus making them more confident in the requirements and their own delivery, and bringing overall improvements to the sector. A few of those attending the events also suggested that having a more joined up system would support staff transitions and career progression between settings.:
“Would increase depth of focus on one framework rather than splitting attention between a number of docs. Our staff teams need to be focused on the day to day quality provided. This will be easier when reflecting on one document rather than dozens (including guidance and best practice documents).” (Private or independent or third sector ELC or SAC provider)
Some felt a shared framework could deliver a more supportive and collaborative approach, with a greater degree of discussion between practitioners and inspectors. It was also suggested this would allow the inspection process to focus on improvement (rather than “fault finding”), and would facilitate the sharing of best practice. The Care Inspectorate agreed with others that a shared framework would facilitate strong collaboration between them and HMIE:
“A single framework for the sector would provide the platform for strong collaboration between the inspectorates of ELC and the national agency for Scottish education, which will support the improvement, professional learning, and leadership across the sector.” (Inspectorate Body)
Several suggested a shared framework had the potential to deliver more thorough inspections which covered both care and education, and which understood and promoted the relationship between these. This was seen as an opportunity to consider care, play, education and learning together and to stop separating these:
“Bringing education and care together in a clear and concise way.” (Individual)
The development of a shared framework was also said to provide the opportunity to deliver specific guidance to the different sectors/types of settings so each service knew what was expected of them. Further, it was felt this would allow the framework to take account of specialist providers and minority sectors within the approach - for example, SAC/OSC, GME, and those with provisions for deaf children.
A few also suggested that it may help to better align and link ELC and school, thus better supporting school based ELC settings, and ensuring better transitions between the stages.
Caveats to Support
It should be noted, however, that despite respondents discussing a range of benefits that could be achieved by a shared framework, several highlighted caveats and limitations across both the main written submissions and the events.
Several respondents and event attendees indicated that they either saw no benefits to implementing a shared quality framework, or highlighted that the current proposals would do little to tackle the duplication or conflicting expectations between the requirements of the two inspectorates:
“Such a change should have the effect of reducing administrative burdens for ELC leaders though, as set out, it will not reduce the number of inspections and the risk of duplication or conflicting activities and expectations would remain.” (Trade Union)
“Continuity for ELC through singular framework, but still does not address the dual inspection process for ELC.” (Local Authority)
“One framework would still be interpreted in different ways by two very different organisations.” (EYS Event Attendee)
Some event attendees, particularly from the organisation based events (as opposed to the public events) caveated their support for a shared framework, or questioned how this would operate. The main concern was related to the impact on SAC and childminders. Those representing childminders said this would only be welcomed if it reflected the childminding sector and resulted in a simplified and streamlined system based on significantly reduced paperwork and reporting requirements:
“[This] should be more childminding-specific recognising the unique nature of childminding and that it spans pre-school and school-age (and including similar aspects to other providers where appropriate).” (Sector representative body/membership organisation)
Those who felt the framework should or would be applicable to the SAC network stressed that it would have to be relevant, accessible, useful and place equal value on all sectors (including childminders and SAC). It was also suggested by several attendees at the SOSCN event that the framework would need to be flexible, and use play principles for the SAC sector rather than for them to be inspected against educational values/indicators.
Other attending the SOSCN event, however, argued that there were no benefits of implementing a shared framework in the SAC sector, or suggested that this was not appropriate as SAC providers should not be assessed in the same way as ELC/ learning environments, and that it could increase confusion within this sector. Another (who attended the Trade Union event) felt that no argument had been made to support the shared framework being applied to the SAC sector:
“Do we mean shared across the two agencies or shared across ELC and school age childcare? The latter represents a considerable shift in the scrutiny of early education and no case has been made for this.” (Trade Union Event Attendee)
Other caveats or concerns, noted by fewer respondents and event attendees, are outlined below:
- Several noted that the existing documents (the Care Inspectorate Quality Framework and HGIOELC) were useful, and could be used as a starting point rather than ‘reinventing the wheel’. One also flagged that departure from HGIOELC could have implications for consistency between ELC and school settings/ transitions;
- That the benefits would be dependent upon the content of the shared framework and the two inspectorates having a shared understanding of it;
- There needed to be clarity on the purpose of scrutiny and inspection, as well as how the shared framework would be used by the inspectorates, their roles and responsibilities;
- Clarity was needed on the extent to which the shared framework would be aimed at self-evaluation and/or informing inspections;
- That other bodies were also involved in ensuring quality, such as local authorities;
- The framework needed to be created from the ‘ground up’, or avoid taking a ‘top-down’ approach; and
- A few were sceptical about how achievable it would be to design a shared framework, noting that previous attempts to achieve this had failed.
Q3.3 and Event Q7. What do you consider are the challenges to implementation of a shared quality framework?
Although the question asked respondents to identify potential challenges to the implementation of a shared framework, several respondents also outlined potential negative impacts which a shared framework could bring, or elements which they thought would be necessary to support implementation. Again, responses were largely consistent between the main written submissions and comments from those who attended the events, and are therefore considered together below.
General or Common Challenges
Several factors which related to the framework generally were discussed by respondents.
It was noted that greater communication and collaboration between the two inspectorates would be needed, as well as between the inspectorates and the sector so that inspectors understood the nuances, needs, and challenges faced by the different types of settings.
Some respondents (across all respondent groups and response formats) stressed the need to make the framework/document(s) streamlined, manageable, accessible, jargon free, use clear and easily understood language which will not alienate any setting/type of service provider, provide clarity around terminology, and to ensure it did not contain any conflicting or contradictory information. A few event attendees also suggested that practitioners views should be sought when planning and developing the framework and document.
There were mixed responses in relation to what the starting point of the shared framework should be. Some felt that the new Care Inspectorate Quality Framework should be updated in order to avoid providers feeling overwhelmed by another significant change or a brand new document. Others argued that the shared framework needed to maintain links to HGIOS and the school framework in order to support early level and transitions. Several also stated that links were needed to the National Standard and that the framework should align to Realising the Ambition.
HMIE stressed the need to ensure the requirements did not become ‘too generic’ or too ‘tick-box’ in nature, but that it must continue to allow inspectors to ‘drill-down’ into the detail. A few were also concerned, however, that the framework may be too big/lengthy and confusing, or that it would be challenging to maintain it at a manageable size.
Resourcing of the inspectorates and service providers was also highlighted (across all response formats), with concerns that they may be under-resourced or underfunded to manage this change successfully. For example, it was noted that childminders (and others) might find it difficult to afford or lack the time to attend training on the new framework while others have a largely young and inexperienced workforce. In terms of the inspectorates, the difference in salaries and their terms and conditions was noted as an issue if both sets of inspectors were to be expected to undertake the same work:
“Inspection staff are questioning whether a JEGS [job evaluation and grading support] will be carried out as both inspectorates will be carrying inspections against the same criteria which is similar work but salaries are very different.” (Trade Union Event Attendee)
A few local authorities, however, expressed disappointment about the timing of the consultation on proposals to develop a shared framework when there has been no decision yet regarding who would replace Education Scotland:
“The implementation should also be dependent on the scrutiny agency. Again it is a challenge when this consultation is pressing ahead at a time when the consultation on the body who will replace Education Scotland is still to commence. Again the sector is isolated, excluded and disconnected from other education providers.” (Local Authority)
Challenges Related to the Inspectorates
One of the main challenges related to the inspectorates themselves was the perception that it would be difficult to get the two organisations to work together effectively and to agree on a single approach and single set of quality indicators. It was suggested that the two bodies had competing agendas/differing remits and that they may not been keen to relinquish their own dedicated frameworks. A few respondents also highlighted that the two organisations serve different purposes as set out in legislation, one regulatory (i.e. the CI) and the other to measure the quality of education provided and outcomes for children (i.e. HMIE). As such, they felt it might be difficult to find an arrangement which would be acceptable to both:
“Two agencies working together, streamlining the systems and changing the mindsets is a very big tasks that can take time if there is no willingness to change and adapt.” (Private or independent or third sector ELC or SAC provider)
“Both bodies agreeing what they are looking for as at the moment they seem a million miles apart.” (Individual)
A few suggested that a ‘culture change’ would be needed from both inspectorates, while others were concerned that the views of one inspectorate may be favoured or become dominant within the new framework. Indeed, a few of those attending the Care Inspectorate event stressed that the roles, skills and expertise of each inspectorate needed to be equally valued and respected. There was a strong sense among Care Inspectorate event attendees, however, that they had not always felt like equal partners, and that their views and experience had not always been respected.
Another common concern (across all response formats) was that the two inspectorates, and individual inspectors, may still provide inconsistency between their approaches and interpretation of the requirements. A few suggested that joint training would be required for inspectors to ensure consistency in understanding, interpretation and approach, while others felt that moderation of evaluations between the different organisations would be necessary to ensure consistency in standards:
“Will there be jointly planned ongoing PL [professional learning] sessions between both bodies to ensure clarity and consistency of practice and advice. At present, we can have very different approaches to practice between the two inspection bodies, so there would need to be a lot of joint working behind the scenes before this was implemented.” (EYS Event Attendee)
Across all response formats, several suggested that inspectors lacked direct (recent) experience, knowledge and understanding of how the sector operates, how each setting is run, the relevant challenges faced by each service, and how to apply the framework in each case. It was felt that inspectors would require training in sector specific issues, as well as training in the new shared approach:
“Ensuring appropriate joint training for both inspection bodies to achieve consistent, collaborative approaches and shared agreement.” (Local Authority)
It was also suggested that the concept of a shared framework currently lacked details about the role and responsibilities of each of the inspectorates, but that this would be vital going forward. A few respondents also suggested that the only way to overcome many of the potential challenges of implementing a new inspection framework, if retaining the involvement of two inspectorates, would be to ensure clear roles and remits for each, and ensuring there is no overlap in responsibilities or the quality indicators each considers:
“Drawing a line around the domain of each body so that inspections do not inappropriately creep outside the professional expertise of each organisation.” (Trade Union)
A few respondents also noted the possibility for merging roles and job losses where there was duplication.
Challenges or Negative Impacts for Providers
One of the main challenges for a shared framework was that it would need to ensure all sectors, provider types, and the disparate nature of the workforce were reflected, treated fairly, equally/equitably, and offered the same support and opportunities, and that it met the needs of all children (including those in GME settings). There were concerns that the new framework would prioritise or focus on some ELC sectors more than others (i.e. on funded ELC providers above all others), or on certain age groups, with those attending the SOSCN event largely criticised the proposals for not having a clear understanding of the SAC or childminding sectors. Childminders were concerned that they may lose out or it may result in more childminders leaving the profession, while SAC settings were concerned that tick-box requirements or educational principles would be placed on play based settings. Rather, it was stressed that the unique aspects of childminders, PVI settings, school or local authority based ELC, and SAC needed to be taken into account, with play recognised and SAC settings not inspected against educational indicators. It was also highlighted that this would be a significant change for unfunded providers who had not been subject to HMIE inspection requirements previously, and that it would be difficult to achieve a shared framework which fairly represented all sectors and not introduce unintended negative consequences:
“…only focusing on some of the ELC providers could neglect the quality and support offered to those not prioritised, including childminders.” (Childminder)
“Concerns that one framework could further dilute the role and unique position of school age childcare with formal education taking a further priority.” (Private or independent or third sector ELC or SAC provider)
“The requirements and conditions for high quality ELC and SAC are not the same. There is a high risk of unintended negative consequences for both sectors.” (Trade Union Event Attendee)
A few respondents suggested that different documents may be needed to cover different types of settings to avoid the shared framework becoming too broad or it failing to adequately reflect all sectors. Others, however, argued that the shared framework should not apply to SAC:
“Possibly a separate document for out of school care, different age children and sometimes purpose of setting” (Private or independent or third sector ELC or SAC provider)
It was stressed (across all response formats) that providers would need time, resources and support to understand and familiarise themselves with the new framework, and to embed any new requirements. It was felt that the change may be stressful or unsettling for staff, and that various types of support may be required, including the provision of ‘what to expect’ style materials, opportunities for professional dialogue (both locally and nationally), support from local authorities, and support from inspectors during the transition period:
“Time to read, digest and action. Harder for staff to meet as a team due to the increase in hours of provision and the varied working patterns by staff.” (Individual)
Practitioner training would also be needed, it was felt, to ensure everyone had the same information and understanding of the new system, although there were concerns about how achievable this would be for some:
“The training and capacity of ELC staff to understand, interpret and action guidance. Training for all staff will be needed to be able to use the guidance effectively.” (School with ELC provision)
“…we've just had a new CI [Care Inspectorate] framework to learn, and now this is another one whilst staff cannot get time off the floor for professional learning and development as it is, so it would be very hard to implement another framework that will take time to embed.” (EYS Event Attendee)
There were also concerns over how long a shared framework would take to implement, with a few stressing that immediate support was required. There was also a common perception among providers that this would be ‘yet another framework’ to learn, with concerns over burnout and the demotivation of staff, as well as how much time, support and training staff would need to transition.
The timing of the changes may also prove challenging for the sector. Respondents highlighted that this comes at a time when the sector has experienced unprecedented changes and challenges, including both COVID-19 and the expansion of the funded ELC hours, and the staffing challenges created by both. Others noted that the Care Inspectorate Quality Framework was also fairly new with staff still trying to familiarise and adapt to this, and therefore a further change could be confusing and demotivating:
“Much as the change is needed it comes on the back of unprecedented change and burn out in the sector with the pandemic.” (Playgroup)
“We are just getting confident with the CI [Care Inspectorate] quality framework - changing too soon will cause upset and deflation in a sector already stressed and under-valued.” (Private or independent or third sector ELC or SAC provider)
HMIE also indicated that the wider educational reform process being undertaken provided an opportunity for more bold changes, to ensure that inspection meets the needs of the sector. However, they cautioned against making interim changes followed by larger system changes at a later date:
“We believe that the reform of education, the national review of care and the establishment of a new education inspection agency means that this is the perfect moment in time to be bold, sector leading with ELC, setting the standard for the education and care systems as a whole and consider what it is that the ELC sector really needs. However, to publish a vision and principles without clarity of the outcome of reform and national reviews could potentially mean further changes to the structure of roles and responsibilities of each organisation after reform. The sector, local authorities and the system cannot face a temporary change and then later system wide changes… We believe a strategic review of inspection and improvement support for ELC across Scotland is required now rather than trying to ‘fix’ bits of what is wrong, with the potential of further change in the near future.” (Inspectorate Body)
However, it should be noted that, even where respondents highlighted potential challenges and difficulties, some also stressed that they still thought the development of a shared framework would be an improvement over the current system:
“It may be challenging to implement to begin with, but I feel in the long run it will be more beneficial than the current inspection process.” (Individual)
“A shared quality framework, as it is proposed, will not fully address the needs of the ELC sector… However, it is better than two different frameworks.” (Local Authority)
Shared Framework Not Enough to Tackle Problems
Several respondents (largely from local authorities and sector representative bodies/membership organisations) argued that if two inspectorates continued to be involved, then a shared framework would not fully meet the needs of the sector, and difficulties and challenges would remain inherent within the system. This included duplication of effort; separation of care and education; and inspections carried out by two bodies with different priorities, expectations, and on different inspection timeframes:
“While we support implementation of a shared quality framework, it will still be necessary to consider how the scrutiny landscape can be best configured to reduce unnecessary duplication and burden inherent in a dual system of scrutiny.” (Inspectorate Body)
“Issues that exist currently when two inspectors are present will remain. While education and care remain of separate interest to the different inspectorate bodies there will remain difficulties in implementing a shared quality framework.” (Sector representative body/membership organisation)
Similarly, one other respondent felt that the proposed changes did not go far enough as they perceived the shared framework to focus too much on self-evaluation and not on the inspection process itself:
“We are not confident that significant enough change is proposed and are concerned that too much emphasis is being placed on a shared quality framework as a ‘tool for self-evaluation’ rather than the transformational change to inspection required. There is a risk the new shared quality framework will be considered simply as a re-organisation of the current frameworks under a different banner… Clarity is required as to how it will be considered during joint inspections in a proportionate and manageable way.” (Sector representative body/membership organisation)
Some respondents suggested there were no challenges and that the changes would be welcomed, while others argued that a shared framework would not necessarily result in the inspectorates working more closely or solve all the problems associated with having two inspectorates involved. Rather it was suggested that a culture change was required within the inspectorates, and that the process/delivery of inspection also needed to be addressed, otherwise double scrutiny would remain:
“The idea of a shared framework could be very beneficial, with inspectors using one document to perform inspections which in theory should simplify things overall. However - regardless of that, it simply won’t work if it’s not backed up with a single body. Both bodies use different approaches and it will be very difficult for them to stop doing that even with one framework. Look at the National Standard - that’s a single document that isn’t successfully being administered by different bodies so why would one framework be any different?” (EYS Event Attendee)
A few attendees at the Association of Head teachers and Deputes in Scotland (AHDS) event also suggested that the existing frameworks were fine and that perhaps a shared framework was not required, but that either a few additions could be made to each of these to better align and link them, or that guidance for the two inspectorates could be developed to help them work together to use the existing frameworks more effectively.
Q3.4 Do you think that the development of a shared quality framework will meet the needs of the sector to simplify the inspection landscape and reduce the inspection burden? Why do you think this?
Q3.4 Do you think that the development of a shared quality framework will meet the needs of the sector to simplify the inspection landscape and reduce the inspection burden?
|Number of respondents||Percentage of respondents||Valid %|
Just under two thirds (n=150, 63%) of respondents who provided a response felt that the development of a shared quality framework would meet the needs of the sector to simplify the inspection landscape and reduce the inspection burden. Much smaller proportions felt this would not (n=29, 12%) or were unsure (n=60, 25%).
Those who said ‘yes’ to this question again mainly did so on the basis that it would provide a clear vision and shared inspection language with no conflicting messages, would provide better clarity on expectations, and allow for consistency of approach. Shared understanding across whole sector would, in turn, lead to more robust self-evaluation and better planning for change, it was felt.
Respondents (including both inspectorates) again indicated that the shared framework would provide a simplified landscape, reduce burdens of paperwork and staff time in preparing for inspections and would remove feelings of being ‘over-regulated’. There were hopes that the shared framework would also increase transparency in what was required of providers:
“It will offer clarity, a shared vision and will be far more supportive to staff then the current situation.” (Individual)
Again, it was felt that the shared framework that was developed collaboratively was needed to lead to better outcomes for children and families:
“A shared framework developed collaboratively with children parents, practitioners and partners is an opportunity towards simplifying the inspection landscape and reducing the inspection burden. All efforts need to be carefully evaluated to ensure that change brings about improvement for the children who are central to all our work.” (Inspectorate Body)
In a similar vein, respondents encouraged ongoing collaboration between key stakeholders in the development and implementation of the new framework:
“[Organisation] believes that a shared quality framework that is developed collaboratively by the Care Inspectorate, HMIE, sector representatives, practitioners, teachers, staff, children and families would help to simplify the inspection landscape and reduce the inspection burden. This would ensure the voices of all key stakeholders are able to develop workable solutions that benefit the sector.” (Sector representative body/membership organisation)
Those who said ‘no’ to this question mainly did so on the basis that the proposal did not go far enough to fully meet the needs of the sector to simplify the landscape and reduce the inspection burden. Again, such respondents felt that a single inspection body was required to achieve this, as there would otherwise still be separate bodies or providers to content with and potential for inconsistent interpretation of the document:
“Such a development would partly achieve that goal by reducing complexity. However, it will not reduce the inspection burden in any meaningful way as a reduction in the number of inspections or the style/duration of inspections has not been discussed in this consultation.” (Trade Union)
Again, it was unclear how having two inspectorates with a shared inspection framework would reduce the frequency of inspection and the associated workload, i.e. “The issue of double scrutiny will remain unless the inspections were jointly undertaken by the regulatory bodies at the same time.” (Local Authority) Again, there were concerns that without one body, staff would remain unsure as to what was expected of them from the different inspectorate bodies which would continue to lead to them feeling under pressure.
Others again expressed views that it was not required (i.e. the current frameworks worked well) and that a single framework was too simple to apply to all settings:
“I fear that it would do the opposite and further complicate an already laborious and intricate process, as stated above there is such variety within all the service you was to encompass under one framework.” (Private or independent or third sector ELC or SAC provider)
Specifically, some felt that it would not simplify things or meet the needs of childminders (for whom a more proportionate approach was needed), play providers and school aged children (SAC), who should be removed from the proposal it was felt, as including them would create less focussed, sector-specific outcomes. Indeed, inspectorates themselves expressed views that inclusion of inspection of school age childcare at this time should not be considered and that the sector would benefit from clarity of responsibility of delivering all aspects of scrutiny in a coherent way for these groups.
More thought was needed ahead of any change, especially in relation to GME and EME provision, and the full range of ELC settings (particularly childminding and school aged children services):
“These services are quite unique in the way they are delivered, and this needs to be recognised. For example, we cannot expect childminder's who operate solely to complete self-evaluation documentation in the same way that a nursery would. Similarly, we must recognise that a home cannot contain as many resources as a nursery…[and] we cannot expect after school care services to provide the same deep meaningful play and learning as school and nursery, as these children are often tired, and would prefer to relax, unwind, and chat with friends after school.” (Individual)
Some respondents also stressed that any new framework must not be overly complicated and must be accessible to practitioners (and one provider argued for a supporting Inspection Handbook/Framework, to set out expectations and judging criteria). Again, time for proper implementation and planning time to support the change was encouraged by both practitioners and inspectorates. Views were expressed that the change must be well thought out and that implementation must not be rushed, with no watering down of standards and expectations, or of the frequency of inspection visits:
“We believe that the success of developing and implementing a shared ELC inspection framework will be dependent on preparation, timing and the clarity of purpose.” (Inspectorate Body)
Several respondents stressed that the shared quality framework would only meet the needs of the sector to simplify the inspection landscape/reduce burdens if it was implemented well, tested and adjusted as necessary:
“In principle, yes. However, this is very much dependent on the finer details and implementation. Further clarity around what this will look like in practice is required about frequency of inspection and the changes made to existing frameworks around quality.” (Local Authority)
Finally, one respondent again stated that there was “no place for HMI in ELC” (Private or independent or third sector ELC or SAC provider).
Q3.5 Do you think that the shared framework should apply to all ELC services, including funded and unfunded nursery and childminder provision for 0-5 year olds, and to childcare provision for children of school age (over 5 years old)? Why do you think this?
Q3.5 Do you think that the shared framework should apply to all ELC services, including funded and unfunded nursery and childminder provision for 0-5 year olds, and to childcare provision for children of school age (over 5 years old)?
|Number of respondents||Percentage of respondents||Valid %|
Just over two thirds (n=164, 68%) of respondents (who answered the question) agreed that the shared framework should apply to all ELC services, including funded and unfunded nursery and childminder provision for 0-5 year olds, and to childcare provision for children of school age (over 5 years old). Fewer than one in five respondents (n=43, 18%) felt this should not be the case, and a further 14% (n=33) were unsure.
Those who said ‘yes’ to this question felt that the framework should apply equally to all settings since this would bring about the most collaborative and consistent approach to inspection and strengthen the wider ELC workforce. It would provide a consistent benchmark for all services to work towards.
Having one framework that applied to all settings would also have the added advantage of ensuring that staff who move between providers/settings remain focussed on the same goals and outcomes, and that children who move between different settings can expect the same standards of service in each. Consistency in standards was again seen as key and having a shared framework that applied in all settings would remove potential bias around interpretation with regards to quality and standards.
While some felt that exclusions should apply (discussed more below) views were given that the Care Inspectorate’s quality framework was already effective at meeting the needs of multiple settings (with flexibility and proportionality in how care is regulated being built in). On this basis, there was no need to exclude some groups in the new revised framework, it was felt, as to do so would mean having multiple different frameworks for children of different ages/in different settings, (and would therefore undermine the shared framework approach being proposed):
“As the current Care Inspectorate framework is used by all settings, we see no reason a single inspection framework would not accomplish this. It is important to take account that many settings do not only provide for children receiving funded ELC but also babies and school aged childcare. Unless there was a single framework for all children, we would continue to compound the current situation with different frameworks for different age ranges of children cared for in the same setting.” (Inspectorate Body)
Where people mentioned including both funded and non-funded services, there was general consensus that it was important to ensure that the same standards were achieved:
“Equality is essential and children should receive the same standards of education and care regardless of where they attend and how it is funded.” (Private or independent or third sector ELC or SAC provider).
Caveats to support included that the framework should be applied proportionately rather than routinely to different settings (i.e. childminders should not be inspected to the same intensity as local authority funded nurseries) and that care must be taken not to stifle innovation and competition by trying to make things ‘all the same’. If the framework was too complex/challenging for some to adhere to, this may inadvertently lead to reduced choice in services, which could compromise affordability and equality of opportunity for children. It may also undermine the good work done by some of the small providers in closing the poverty related attainment gap, it was felt (for example, limited resources available to voluntary playgroups may set them at an unfair advantage to settings who have access to teachers, more resources, etc.) In contrast, not having the same framework apply to all could result in some parts of the ELC sector being considered as inferior to others, creating a multi-tiered system, which should also be avoided.
Those who said ‘no’ to this question again expressed views that the framework was too generic and would not cater to all individual settings. One suggested that “other add-ons” would need to be included to recognise the purpose of specific services, i.e. one size would not fit all:
“I think the range and variety of childcare providers have different roles and rationales which makes having one model very difficult.” (Individual)
Again, there were strong views that services for school aged children should be kept separate from other ELC provision (from both practitioners, local authorities and one of the inspectorates), due to having different curriculums (although others noted that the Curriculum for Excellence for the Early Stage did include up to P1). Views were given that services for school aged children are not responsible for children’s progress and achievement and did not require the same focus on learning and development and so the framework should not apply:
“Separating the inspection of ELC from that of school age childcare should be seriously considered, given the inherent differences between these types of provision, and the standards to which they are subject.” (Sector representative body/membership organisation)
Similarly, the shared framework was not considered appropriate for out of school settings (including before and after school care) since they were not providing ‘education’ per se:
“I think ELC is very different from an after school or breakfast club - they need to be different standards and expectations for some of the outcomes.” (Individual)
The framework was also not considered by some to be appropriate for childminders and smaller providers, with the potential to deter some people from becoming childminders if the inspection process was too onerous and bureaucratic. However, this was not unanimous with one childminder suggesting that not including childminders may seek to perpetuate negative perceptions that they are “glorified babysitters” rather than a formal childcare service:
“A more appropriate version should be made available for childminders or smaller businesses as the main document may be overwhelming. There is a lack of childminders, and it is important therefore that this framework is proportionate and does not discourage potential providers.” (Local Authority)
Similarly, the training and qualifications required of different providers varied and so this needed to be reflected in any inspection standards/expectations (for example, childminders were not required to be trained/qualified to the same levels as other ELC providers). Childminders and single person providers in particular were also operating without the same support infrastructure as larger providers, and this should be considered in terms of what they were expected to deliver (i.e. differentiation must be given to support all sectors.)
A view was also put forward by a trade union respondent that the framework was appropriate for non-local authority settings but that there should again be only one inspection body for local authority providers, to ensure that local education authorities have effective systems in place to safeguard and improve the quality of ELC provision.
Overall, both those who supported and did not support the shared framework being applied in different settings indicated that it would need to have flexibility to accommodate service differences and nuances.
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