1. The Association of School and College Leaders (ASCL) represents nearly 19,000 education system leaders, heads, principals, deputies, vice-principals, assistant heads, business managers and other senior staff of state-funded and independent schools and colleges throughout the UK.

ASCL Cymru represents school leaders in more than 90 per cent of the secondary schools and an increasing proportion in the primary phase in Wales. This places the association in a strong position to consider this issue from the viewpoint of the leaders of Welsh schools and colleges of all types.

2.    ASCL Cymru has been fully supportive of the Welsh Government’s principle of providing targeted funding to address the issues and needs of specific groups of students, and welcomes the opportunity to contribute to this enquiry.

With reference to your specific areas of focus:

3.    Schools have found a variety of ways of using PDG in order to benefit the students for whom it was designed.  However, there has always been an issue with the boundary between provision for eFSM students and others whose needs may be just as great, but who do not necessarily, for a variety of reasons, fit that category.  In practice it has proved almost impossible to separate out these types of student.  We see this as a positive benefit, as the use of free school meals is, at best, a blunt tool that can miss out students for whom this additional support can be a critical part of their education.

4.    In general terms, we feel that the majority of schools are using the additional funds in a positive and constructive manner.  However, there have been situations where the restrictions placed upon the use of the PDG funds have resulted in schools having to be very creative in their reporting of it.  This highlights an issue with the current system, namely that, the more restrictive and specific the conditions of the grant, the more time and resource has to go into justifying its use.  It is surely not the intention that a senior member of staff should have to spend days (if not weeks) of their time dealing with the bureaucracy associated with the grant in order to ensure that reporting forms and spreadsheets demonstrate the required use of the grant.  One of our schools estimated that the cost (in staffing terms) of administering the PDG was in the region of £5-7,500 per year.  This was in a school where the actual PDG income was £50,000.  This potentially reduced the impact of the grant by 10-15%.  We do not believe that this level of required bureaucracy is necessary or desirable.

5.    It is a positive benefit of PDG, that where schools invest in interventions and support packages for eFSM students, these will have an impact on other students within the school.  New and innovative approaches to teaching and learning, however they are arrived at, will impact the work of staff across the school.  This should be encouraged and recognised as an important part of the benefits of this grant.  It is sad, although perhaps inevitable, that some schools are so focused on meeting the requirements of the grant that they may not to publicise or overtly encourage these cross-over benefits.

6.    We are concerned, therefore, that some of the consortia, in attempting to ensure that the conditions of the grant are demonstrably met, have put in place a level of bureaucracy that can stifle creativity and encourage a “tick-box” mentality.  We have no figures to be able to estimate the staffing cost to the consortia of running the bureaucratic systems they have put in place, but feel sure it represent a significant use of scarce funds. We would maintain that it would be far more cost-effective to reduce significantly the level of detailed reporting and justification for spending, and replace it with an analysis of impact on the students concerned.  It would very soon become apparent where the funds are being well used to the benefit of those who most need it, and vica-versa.

7.    It is appropriate that specific funds should be made available to support the learning of looked after and adopted children.  The consortia are proper gate-keepers for these funds, and the allocations to schools are normally timely and appropriate.  These additional funds appear to be well-used and support the learning of these students. We would reiterate our comment above about the level of bureaucracy that can sometimes be required.

8.    We consider that there has been good progress since the 2014 enquiry Educational outcomes for children from low income households.  This can be attributed to a large extent to the continuation of the PDG, which has allowed schools to ensure that resources are channelled to areas of identified need.  However, the following two paragraphs identify some areas of concern that remain.

9.    The additional funding supplied by the PDG has been most welcome and has allowed schools to implement strategies for the most vulnerable students.  However, the year-to-year nature of the grant means that long-term planning is impossible.  This has an impact on the ability of schools to provide stability for staff or consider spending on medium to long-term projects.  It would be most helpful if the Welsh Government could provide a clear time-frame for the lifetime of the grant, to allow schools to plan more effectively.  We would suggest that a five-year commitment (which could be renewed at a future date if felt appropriate), would allow schools an appropriate level of certainty that would encourage longer-term planning and even more effective use of the grant.

10.  We are still concerned that, whilst schools rightly are charged with ensuring that the quality of the educational experience of young people, there remains a significant issue about the role of parents in education.  It is evident that, particularly in many low-income households, there is at best an ambivalent attitude to education, and in many a feeling that education is of little value.  This sort of attitude can be a major influence on young people, and seriously affect their approach to their education.  Schools will always do whatever they can to encourage parents to adopt a more positive approach, but this can be almost impossible if the parents cannot be enticed into engagement with the profession.  We feel there is a major role here for the Welsh Government to play in helping to engage and enthuse parents as partners in education.

11.  It is clear that the Schools Challenge Cymru project did not result in consistent improvements in all participating schools.  Whilst in many of the schools it lead to clear and measurable improvements, in others it did not.  Our view is that whilst the intent of the project was admirable and had enormous potential, in implementation there were issues. The most significant of these was in the lack of coordination and resulting layering of further accountabilities on these schools.  The fact that separate improvement boards were set up, and were not required to engage with the local consortia and local authorities led to significant duplication of effort and contradictory advice being given in some cases.  If these had formed part of a coordinated approach, in our view, it would have been more likely to have resulted in more widespread success.

12.  In our view, there is a place for identifying schools in need of additional support in order to raise standards.  However, to an extent, these are already in place through the work of ESTYN and the current Schools Categorisation system. The resources that went into the SCC could perhaps have been better used to ensure that the additional support required for these schools came through established channels, and in a clearly structured and fully coordinated manner.

13.  We are concerned that attainment data has remained focused on an artificial pass/fail concept based around a GCSE “C” grade.  Whilst it is appropriate that schools are given targets that challenge them and encourage them to ensure all students realise their potential, this sort of artificial hurdle is always likely to give a skewed picture. We would maintain that it would be far more beneficial to measure the level of improvement of the individual from a clear starting point, in order to be able to demonstrate actual “value-added”.  This is not to say that schools should not do everything they can to motivate students to achieve the highest grade they can, but it does recognise that not every student is capable of achieving five or more “C” grades at GCSE. It is surely not just that an individual student or the school should made to feel they have failed because a great deal of hard work and professional support has resulted in an “E” grade.  There needs to be recognition of the success of the many students for whom this is a reality.

14.  We are fully supportive of the intent to ensure that there is similar support for more able and talented students in our educational system.  There is always a danger that, with an accountability system that focuses on achieving a minimum level, the focus will be on getting to that point.  This can mean that the needs of our most able students may be a lower priority.  In the best schools, these students are well catered for, but in many they are not given the attention they need.  We would encourage the Welsh Government to maintain and even expand their focus on these students, to ensure that we also allow them to achieve their full potential.

15.  In our view, the PDG is a well-used resource, and whilst we question the financial impact of the accompanying bureaucracy, we feel that overall the money is well used.  We fear that the Schools Challenge Cymru project did not represent such a good use of funds in all cases.  It would be wrong to write it off as a failure, because there is clear evidence of significant improvement and positive outcomes in some schools.  However, it is also clear that in other cases, the level of duplication, contradictory advice and lack of coordination caused issues and did not represent value for money.

Conclusion

16.   I hope that this is of value to your enquiry, ASCL Cymru is willing to be further consulted and assist in any way that it can.