Following consultation on the recommendations made by the Rochford Review (2016), the Department for Education (DfE) published its response at the beginning of the 2017/18 academic year.  Respondents to the consultation included teachers and school leaders from mainstream and special schools, organisations representing pupils with special educational needs and disabilities (SEND) and a small number of parents/carers.  Importantly from a democratic perspective, the Rochford Review recommendations were sufficiently well supported for the DfE to endorse the general thrust of the proposed reforms.

The most significant comment included in the DfE response is undoubtedly the intention to remove P Scale levels as an instrument of statutory assessment. The evidence gathered by the Rochford Review in 2016 generated considerable support for the view that P levels were no longer fit for purpose, so it is re-assuring the DfE is now supporting the recommendation for their removal.  However, removal of the P levels will not mean an end to the statutory assessment of pupils by reference to end of key stage national curriculum standards. In place of P levels, the DfE is organising a trial of the pre-key stage standards (ie., as described in the Rochford Review) so that the final versions take account of feedback from how these operate in the classroom for the statutory assessment of pupils who are working below the standard of national curriculum tests, but capable of subject specific. Unfortunately, there may be a temptation for some school leaders to regard these pre-key standards as being no more than a reincarnation of P levels 5-8. Was this to become a feature, there would be the associated risk that some school leaders might continue  “teaching to the test” with pupils being driven through narrow, linear aligned assessment criteria with an overriding ambition of securing more favourable rankings in school league tables.

As far back as 2010 the DfE was advising schools to, “Consider more holistic approaches to assessment for the small group of children working at very low levels of attainment where progress is not linear”. Despite this advice, in 2015 the Commission for Assessment Without Levels  (CAWL) felt it necessary to comment that a prevailing “school league table mentality” was still encouraging schools to give national curriculum related assessment absolute priority over any other assessment approach. According to Imray (2013), publications such as the DfE’s Progression Guidance in 2010 may have prompted some school improvement partners and OfSTED inspectors to advocate that the vast majority of pupils with learning difficulties should be able to make similar rates of linear progress, further suggesting that OfSTED required at least 75% of pupils to have attainment levels in the upper quartile of the national data sets before outstanding status could be granted. In relation to the impact such anecdotes were having upon special education, the CAWL report recommended a review of the P Scale levels which brought into being the Rochford Review.  As well as echoing the findings of the CAWL report, the Rochford Review endorsed the views expressed by critics such as Riddick (2009) who had described the P level approach as “a bureaucratic tool” which was having a “negative impact on the curriculum balance required by some children to meet their needs”.

In regards to the DfE’s decision to trial use of the pre-key stage standards, and in order not to repeat the mistakes attributable to the misuse of P levels, school leaders will need to be guided by what the DfE is actually stating in its response to the Rochford Review.  Special note should be taken that use of the pre-key stage standards is intended to provide “a clear route of progression onto national curriculum assessments”, but only, “if and when pupils are ready” (our emphasis).  School leaders will need to interpret how, “if and when pupils are ready” applies to pupils identified as having SEND and to help with this, the DfE’s response states, “It is important schools continue to monitor and support pupils’ development in the four areas of need to foster engagement with the world and to encourage autonomy.”  There is a risk that when pupils are beginning to acquire subject specific knowledge, their academic attainment (an aspect of cognition and learning) might mistakenly be viewed as something discreet from the other three SEND areas of need.  In the DfE’s response, the words “engagement” and “autonomy” are used to reduce such a risk and it is important that school leaders understand what these terms mean.  In this context, “autonomy” means that before pupils are assessed by reference to the pre-key stage standards, they should not only be able to demonstrate mastery of all the concepts and skills pertaining to key stage descriptors, but they should also be able to generalise and apply this knowledge in ways which the DfE says will promote their “independence and quality of life”.  The meaning of “engagement” is discussed in detail later in this article.

Building on their statement, “There is merit in statutory assessment focusing on areas that support the development of concepts and skills that are pre-requisites for progressing onto subject-specific learning”, the DfE has decided to pilot a new approach to the statutory assessment of pupils who have complex SEND working at pre-subject specific standards.  Whereas P level assessment assumed that the cognitive development of pupils with complex SEND follows a linear trajectory of attainment, the DfE is stating how important it is for schools to work holistically, using whatever assessment approaches they feel are appropriate to assist pupils become autonomous in things which are pre-requisite to subject-specific learning.  This is to ensure that schools are providing effective support in all SEND areas of need and are adhering to their fundamental duty to prepare pupils for adulthood and promote what the DfE is describing as “independence and quality of life”.

According to the DfE’s response, the statutory assessment of pupils with SEND is no longer to be based purely on generic, standardised measures of learning and this change is to be welcomed because improved curriculum balance, personalised pedagogy and a more holistic approach to assessment are all desperately needed if the ambitions of recent SEND related legislation are to be realised in practice.  Education, Health and Care Plans (EHCPs) were introduced in an effort to facilitate early intervention into SEND issues and ensure that pupils with SEND benefit from positive long term outcomes as they enter the adult world. However, as reported to the House of Lords in November 2016, the introduction of EHCPs has not been as successful as was first envisaged and things like inappropriate statutory assessment have very likely contributed to this.  In order to prepare pupils for adulthood, teachers must have a sound appreciation of how curriculum content, pedagogy and assessment can be personalised in response to the idiosyncratic, holistic needs of each pupil.  This is where the focus of school leaders and OfSTED also needs to be, providing much needed support to teachers so that personalised learning targets can not only be successfully embedded into everyday practice, but also facilitate demonstrable, measurable progress towards pre-planned EHCP outcomes in the four areas of need.

Putting “engagement” at the heart of SEND provision has already been proven to be highly effective and this is why the DfE has declared its intention to pilot use of the seven aspects of engagement as recommended by the Rochford Review. Engagement is a child centred, non-curriculum related approach which is radically different in concept to P level assessment.  The DfE’s decision to pilot use of the seven aspects of engagement should be regarded as signifying the end of standardisation in the statutory assessment of pupils who have the most complex SEND.  The seven aspects of Engagement in cognition and learning are based on the Engagement for Learning Framework (ELF) published at the conclusion of the Complex Learning Difficulties and Disabilities (CLDD) research project in 2011. The Rochford Review took what the CLDD had developed primarily as a pedagogical approach, refining and extending the principle so teachers could use the same methodology to accurately assess the performance of pupils whose progress is not always linear.  ELF uses a process of enquiry into the personalisation of learning in relation to a pupil’s idiosyncratic SEND profile, enabling teachers to track even the smallest rates of pupil attainment, using a powerful, evidence based approach (the ELF Scale) that can be numerically calculated to provide objective data, robust enough to accommodate forensic moderation. This is not done by giving the seven aspects of engagement any relative hierarchical value, but by recording the extent to which a pupil is being engaged via a 0-4 scale in each of the seven aspects during a specific learning task:

The scores from each aspect of engagement are combined to provide a total from which subsequent improvements in pupil engagement can be measured.  Use of the ELF scale is ideal for assessing pupils who do not find linear progression easy because the data readily exemplifies rates of lateral progression. This is in keeping with the DfE response which includes the statement, “schools have the freedom to use approaches appropriate to their pupils’ needs that demonstrate every kind of progress made by a pupil (linear, lateral or consolidation)”. As discussed below, ELF can facilitate both summative and formative assessment approaches to help analyse pupil progress in any developmental or curriculum related aspect of improvement:

Trialling the pre-key stage standards and piloting of the seven aspects of engagement are to be welcomed, but it is very pertinent to their successful implementation that the vast majority of teachers, together with many school leaders, have never experienced special educational provision without the overarching framework of the national curriculum and statutory P level assessment.  It is also pertinent that many teachers will not have had the benefit of in depth SEND related professional development, particularly in the use of specialised approaches such as assessing pupil performance by reference to Engagement.  Given this context, it is crucial that all of the teachers involved in the trial and pilot are provided with a common baseline of understanding and skill, or otherwise the triangulation of findings during evaluation will prove difficult to establish.

Although the pilot for assessing pupils working at pre-subject specific standards will only evaluate use of the seven aspects of engagement in the area of cognition and learning, assessing pupil performance in the other SEND areas of need is of equal importance. Already, in keeping with the ambitions stated in their pupils’ EHCPs, the best schools devote a lot of time, energy and expense to improve pupil performance in crucial areas such as mobility, interaction, sensory function and emotional regulation. However, evidence about the progress these pupils make as a consequence is not always given sufficient priority by some OfSTED inspectors, who anecdotally have been known to dismiss such evidence as being insufficiently robust. Use of the ELF could help overcome this by assisting schools to exemplify holistic pupil progress more objectively.  Although the DfE pilot will concentrate on use of the seven aspects of engagement in the area of cognition and learning, the schools involved in the pilot are encouraged to use ELF across all four SEND areas of need and submit the resulting data as part of the formal evaluation.  This suggestion might assist the DfE to further recognise the importance of holistic assessment and perhaps pave the way for legislative change to strengthen the implementation of EHCPs.

Mapping and Assessing Pupil Progress, now available as MAPP2 (Sissons, 2017) is a tool which can be used very successfully alongside ELF to exemplify the acquisition of learning targets relating to the four areas of need, as “without engagement there is no deep learning” (Hargreaves, 2006). MAPP incorporates a Continuum of Skills Development (CSD), with which to map learning autonomy via independence, maintenance, fluency and generalisation, thus corresponding very closely to the DfE’s recommendation. Similarly to ELF, the CSD is a structured, measurable way of assessing pupil performance in personalised targets and extends the principle of lateral progression by measuring the process of learning autonomy.  The relationship between the CSD and scales of engagement can be illustrated using the following diagram adapted from David Hargreaves by The Dales School (2010):

Although MAPP also has a bank of learning targets or ‘milestones’ for teachers to select from, care must be taken not to replicate a linear approach to holistic assessment and teachers must select personalised targets strictly according to a pupil’s SEND issues and learning barriers, rather than any pre-prescribed, standardised hierarchy. Other sources of learning targets which can be used in response to a pupil’s identified areas of need are available from publications such as SCERTS and the exemplary non-hierarchical approach used in Routes for Learning. As recommended by the Rochford Review, it is essential that schools work collaboratively, particularly across different settings. A collaborative approach is important to both support and moderate the robustness of judgements and data when a combination of ELF and MAPP approaches are used to measure progress in personalised learning targets that are non-linear, but in which engagement for learning and autonomy are absolutely crucial for securing EHCP related outcomes.

Despite the DfE’s positive response to the Rochford Review recommendations, there may be some practitioners who feel that abandoning the P levels might somehow undermine what they perceive to be the inclusivity of the education system and its notion of equal rights.  Members of the Rochford Review reflected on the topic of equal rights and came to the same conclusion as Lacey and Scull did in 2015 who reported, “Equality and inclusion is not about treating everyone the same but about identifying and mitigating individual learning barriers”.  Treating all pupils the same in terms of statutory assessment is not helpful to pupils with SEND.  Although inclusive education might be championed by those who believe it to be “fair”, the concept is nothing more than a social construct and far removed from the objective reality of SEND issues which demand discreet, personalised assessment approaches such as those included in the DfE response.  However, before a new culture of personalised SEND provision can come to fruition, the pace of change will be dictated by OFSTED and without a change in the inspection framework, the pace of change will undoubtedly be painfully slow.  In relation to shortcomings inherent in the current inspection framework, the Rochford Review reflected on whether statutory peer review might be a more effective way for judging the performance of SEND providers, but even with a growing tendency for schools to participate in peer review, the inspection framework will still require urgent revisions in order to bring it into line with the DfE response.  To be compatible with what the DfE is stating in its response to the Rochford Review, Ofsted will need to have a stronger focus on how learning targets being set by schools correspond to the EHCPs of the pupils concerned, and how effectively provisions such as curriculum differentiation, personalised pedagogy and formative assessment are securing progress in relation to such targets.


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Author biographies

Richard Aird: Before retiring Richard had 30 years experience as headteacher of four special schools, leading his last school through three successive outstanding OfSTED/HMI inspections. In 2013 he was made an OBE in recognition of his services to special education and he has continued to be closely involved in SEND provision, most recently serving as a member of the Rochford Review.

Claire Owens: Claire is Manager of a Special Resource Provision for children with Complex and Additional Needs at Red Oaks Primary School – a mainstream school located on the North Swindon Learning Campus. She is also currently Chair of a Research and Innovation Group responding to the Rochford Review funded by Swindon Teaching School.