CONSULTATION RESPONSE

Welsh Government

Draft professional teaching standards for the further education and work-based learning sectors in Wales

20 July 2017

1. The NASUWT welcomes the opportunity to comment on the proposals for new professional standards for further education (FE) teachers and work-based learning (WBL) practitioners.

2. The NASUWT is the largest teachers’ union in Wales representing teachers and school leaders.

GENERAL COMMENTS

3. The NASUWT acknowledges from the outset that the draft professional standards for FE teachers and WBL practitioners (the draft FE standards) present a far more transparent and accessible set of standards than the almost impenetrable standards maze proffered by the Welsh Government as draft professional standards for teaching and leadership in schools (the draft school standards).

4. In responding to the consultation on the draft school standards, the NASUWT highlighted numerous issues, concerns and objections which rendered them unfit for purpose. The Union condemned the draft school standards, and the PowerPoint presentation which formed the basis of the consultation, as an almost impenetrable, labyrinthine set of rules, requirements and demands by which teachers would be judged. Consequently, the NASUWT formally and firmly rejected the draft school standards (a copy of the NASUWT response and annex is attached as Appendix A).

5. In contrast, the NASUWT welcomes the clarity and simplicity of the design and construction of the draft FE standards, the short and efficient process used to develop them, and the five key principles which have formed the basis of the thinking behind the standards.

6. The Union maintains, however, that there is room for these standards to be streamlined further so that a more concise and generic set of professional standards could be offered across the school and college sectors.

7. The NASUWT notes that in the section of the engagement survey document ‘Why are we proposing change?’ it is suggested that the Welsh Government is revising the standards in order to raise ambitions within the FE sector. Whilst it is recognised that there is never any room for complacency, the Union asserts that it is important that this suggestion is not interpreted as meaning that the performance of the sector is deficient, as such a view would be wholly unsupported by evidence.

8. The NASUWT maintains that ambitions for FE provision should not be translated into additional requirements that add to already excessive levels of workload or distract the workforce from their core responsibilities for teaching and learning. Standards in the sector will only continue to rise if the workforce is given the opportunity to concentrate on tasks and activities focused on their professional expertise and skills. The Union does, however, recognise that the tone, thrust and construction of the draft FE standards is based on a trust in the workforce in the FE sector and to a large extent reflects these critical considerations.

9. However, on a note of discontent with the draft FE standards, the NASUWT objects strongly to the presentation of the standards as a series of personal commitments, as this is too akin to the concept of taking or swearing an oath. The Union maintains that this personal-affirmation style is not appropriate, as it is somewhat de-professionalising, contradicts the stated intention of the standards to enhance the status and esteem of the profession, and could encourage the standards to be used as a performance checklist.

10. In noting the contention, in the section of the engagement survey document ‘Why are we proposing change?’, that it will be important to align the FE standards with the new school standards where appropriate, the Union maintains that this view fails to appreciate that there can be no circumstances where this would be appropriate, because of the fundamentally flawed nature of the draft school standards.

11. The NASUWT acknowledges the view expressed in the section of the engagement survey document ‘Links to the new draft professional standards for teaching and leadership in schools’ that the five dimensions of practice in the draft school standards are reflected largely in the five key principles on which the draft FE standards were based. Thereafter, however, the Union asserts that the architects of the draft school standards, the New Deal Pioneers, lost their way and indulged themselves in an exercise of futility.

12. Notwithstanding the New Deal Pioneers’ wasted venture, the Union believes that it should be possible to incorporate the draft FE standards into the set of draft standards and descriptors which were presented by officials from the Department of Education and Skills (DfES) in the autumn of 2015, at the outset of a series of New Deal Partnership Group meetings to discuss the Review of the Professional Standards.

13. In the response to the draft school standards, the NASUWT confirmed that this set of draft standards and descriptors, with the exception of the first standard which related to the Education Workforce Council (EWC) conduct standards, was considered to be acceptable to the Union. The remaining standards and illustrative descriptors comprise:

· Pedagogy – select and use the most appropriate teaching and learning strategies to meet the needs of learners;

· Curriculum – provide learners with a curriculum that engages and motivates them to learn and to fulfil their potential;

· Assessment – select appropriate assessment methods to evaluate learning and use this information to make teaching more effective;

· Learning environment – create and maintain a safe, stimulating learning environment in which positive behaviour is promoted;

· Wider context – understand the role in the wider educational context in Wales and beyond and the contribution to eradicating inequalities in learner outcomes;

· Professional reflection and learning – engage in career-long professional learning and reflective practice to improve outcomes for learners;

· Leadership – develop and use effective leadership skills throughout your career.

14. The Union does not intend to attempt to integrate the draft FE standards into these standards and illustrative descriptors in this response.

15. Instead, the NASUWT calls on the Welsh Government to build on the work undertaken in producing the draft standards by entering into meaningful consultation directly and solely with the education workforce trade unions with a view to reaching agreement on a generic set of professional standards that are clear, concise and easily accessible, and that can be applied across the education sectors.

SPECIFIC COMMENTS

16. The NASUWT offers the observations and comments that follow in relation to the questions posed on the consultation response form.

Aims, principles and model

Question 1 ‒ Do you agree that the aims and the six key principles on which the standards have been developed are appropriate as a basis for developing these new professional standards?

Agree

Disagree

☐

Neither agree nor disagree

☐

Supporting comments

The NASUWT offers broad agreement with the aims of the five, not six, key principles on which the draft FE standards have been developed.

In noting that the concept of ‘dual professionalism’ reflects the abilities and attributes of the education workforce and their role as leaders of, and experts in, learning and teaching, the NASUWT acknowledges that the tone and thrust of the five key principles is based on a trust in the workforce in the FE sector.

The contrast with the vision for the draft school standards, which suggests that practitioners are not true professionals who constantly strive to develop and grow, could not be clearer.

However, on a note of caution, whilst it is acknowledged that the commitment set out in the document that professional collaboration is a fundamental element of effective provision, the NASUWT is clear that such collaboration should be organised in a way that recognises the professional agency of the workforce to use their judgement and expertise to determine the forms that such collaboration should take, as any notion of mandating collaboration and imposing models on the workforce would not only be inconsistent with recognising the professionalism of the workforce but would also impede the benefits for learners that genuine professional collaboration can generate.

Question 2 ‒ Do you agree with the statement that a particular blend of values, skills and knowledge taken together define professionalism in action and high-quality learning?

Agree

Disagree

☐

Neither agree nor disagree

☐

Supporting comments

The NASUWT acknowledges and welcomes the clarity and simplicity of the DNA-like model of professionalism, illustrated in the engagement survey, which explains simply and concisely how the three elements of values, skills and knowledge interlock and define the professionalism that exists within the FE and WBL workforce.

Again, the contrast with the draft school standards, which comprise a tangled web of values and dispositions, dimensions, elements and descriptors, could not be clearer.

Question 3‒ Do you agree that the values, skills and knowledge capture the appropriate requirements for sustained highly effective teaching?

Agree

Disagree

☐

Neither agree nor disagree

☐

Supporting comments

As stated in answer to question 2, the NASUWT recognises the concise and transparent nature of the DNA-like model of professionalism contained in the draft FE standards which contrasts with the convoluted and almost impenetrable nature of the draft school standards.

Question 4‒ Do you agree that the personal commitment statement and descriptors for further education (FE) teachers/work-based learning (WBL) practitioners will support them to take responsibility for their career-long professional learning?

Agree

☐

Disagree

Neither agree nor disagree

☐

Supporting comments

Whilst acknowledging that the standards enshrined in the statements would assist practitioners to recognise the value of engaging in career-long professional learning, as stated elsewhere in this response, the NASUWT rejects the personal-affirmation style in which the standards have been presented, as this is too akin to the concept of taking or swearing an oath.

Question 5 ‒ What are your views on how well the new standards will support you to reflect on your practice and to plan your professional learning?

Comments

The NASUWT notes that this question is directed specifically at individual practitioners and will, therefore, await the outcome of this aspect of the engagement survey with interest.

Organisation/employer

Question 6 ‒ What are your views on how well the new standards will support your organisation to engage your staff to reflect on their practice and to develop their and your own organisation’s professional learning?

Comments

As with question 5, the NASUWT notes that this question is directed at a specific group of consultees and will, therefore, await the outcome of this aspect of the engagement survey with interest.

Question 7 – We would like to know your views on the effects that the proposed new professional standards would have on the Welsh language, specifically on:

i) opportunities for people to use Welsh

ii) treating the Welsh language no less favourably than the English language.

What effects do you think there would be? How could positive effects be increased, or negative effects be mitigated?

Comments

The NASUWT finds no reason to believe that the draft FE standards would affect the opportunities for people to use Welsh or would cause the Welsh language to be treated less favourably than the English language.

Indeed, the Union notes that the draft FE standards recognise specifically the importance of the Welsh language and culture and its place in the world, and includes a standard which positively promotes the need for an understanding of the same and for personal development of the use of the Welsh Language.

The NASUWT maintains that this presents a more proportionate approach to that proffered in the draft school standards.

Question 8 – Please also explain how you believe the proposed new professional standards could be formulated or changed so as to have:

i) positive effects or increased positive effects on opportunities for people to use the Welsh language and on treating the Welsh language no less favourably than the English language

ii) no adverse effects on opportunities for people to use the Welsh language and on treating the Welsh language no less favourably than the English language.

Comments

The NASUWT finds no reason to believe that the draft FE standards would impact, either positively or adversely, on opportunities for people to use the Welsh language or on treating the Welsh language no less favourably than the English language.

The NASUWT maintains that this presents a more proportionate approach to that proffered in the draft school standards.

Question 9 – We have asked a number of specific questions. If you have any related issues which we have not specifically addressed, please use this space to report them.

The NASUWT reiterates the view that the Welsh Government should build on the work undertaken in producing the draft standards for the school and FE sectors by entering into meaningful consultation directly and solely with the education workforce trade unions, with a view to reaching agreement on a generic set of professional standards that are clear, concise and easily accessible, and that can be applied across both sectors.