Consultation Response Form
Consultation closing date: 8 August 2013
Your comments must reach us by that date

National curriculum review: new programmes of study and attainment targets from September 2014

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/ Name: Anne Fox
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/ Name of Organisation (if applicable): The Communication Trust
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/ Maintained primary school /
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/ Please Specify: The Communication Trust is a coalition of nearly 50 voluntary and community organisations with expertise in speech, language and communication. We harness our collective expertise to support the children's workforce and commissioners to meet the speech, language and communication needs (SLCN) of all children and young people, particularly those with SLCN.
We do this by raising awareness, providing information and workforce development opportunities, influencing policy, promoting best practice among the children's workforce and commissioning work from our members. The Trust is advised by specialist advisors and works with a broader network of partners.
The Trust, which is partner of the Department for Education, was set up in 2007 by children's charities Afasic and I CAN, with BT and Council for Disabled Children.

1 Do you have any general comments on the draft Order?

/ 
/ Yes /
/ No
/ Comments:
Whilst we welcome the reinstatment of a programme of study for Speaking and Listening, The Trust’s most concerning observation of the Draft Order was that it is due to order the ‘National Curriculum, Attainment Targets and Programmes of Study’ into effect on 1st September 2014, when the attainment targets aspect of the Order has been almost entirely removed. The Department for Education has since confirmed that the attainment levels system is going to be removed and not replaced, while in relation to attainment targets the Draft National Curriculum merely states that ‘by the end of each key stage, pupils are expected to know, apply and understand the matters, skills and processes specified in the relevant programme of study’. This is a substantial policy shift considering how attainment targets have traditionally been integrated with the Programmes of Study and have set the levels that pupils are expected to reach. [We also have very strong issues with the length of time given to respond to this draft order, which we have set out in response to question 14.] The review of the National Curriculum is too important to be rushed and the time needs to be given for proper reflection of the implications for pupils with SLCN so that this significant cohort of students is not inadvertently disadvantaged in the future.
Most significantly for The Communication Trust, attainment targets have been used to delineate where pupils are falling below expected levels, which has been incredibly important for teachers and parents to identify and measure the progress of children with speech and language communication needs (SLCN). We are concerned with the proposals in the Department’s subsequent primary accountability proposals to abolish the level system and allow teachers to introduce their own methods to measure attainment, alongside end of key stage National Curriculum tests that rate pupils by a scaled score compared against the national cohort. We believe that for teachers to understand and identify learning difficulties and needs such as SLCN, they need to better understand expected attainment against nationally defined measures that this Draft Order would remove, rather than a patchwork system of standards that the Department seems to be proposing.
This is particularly pertinent for children with SLCN, because in areas of social deprivation upwards of 50% of children are starting school with language delay, equivalent to as many as 17 per classroom. This delay can be significant and impactful, as while their general cognitive abilities may be in the average range for their age, their language skills are delayed. Evidence suggests these delays do not catch up and conversely can remain so into secondary school, impacting on literacy and more general attainment. As the Department will know, pupils from deprived areas often cluster in particular schools and, without a national standard for teachers to reference to, schools may develop their own attainment targets without realising that SLCN is far more prominent in its school than it would be among a more affluent cohort of pupils – because their only barometer for comparing expectations would be within the class intake itself. Teachers will not know that pupils with SLCN are not reaching standards until they take Key Stage 2 and Key Stage 3 National tests, losing valuable time for SLCN to be identified if it is even identified at all. Moreover, the Better Communication Research Programme findings published in December found that SLCN is severely under-identified and we fear this Draft Order to remove attainment targets will only exacerbate this.
This issue cannot be underestimated, especially when you consider that at the end of primary school, although nearly 80% of all children achieve the expected level in English, just 25% of children with SLCN reach that level – a gap of almost 55%, while the gap in Maths is 46% and in science it is 41%. This proves that SLCN is a cross curricula concern. And while we are encouraged that the Draft National Curriculum framework sets out that spoken language should be addressed across and integrated within the KS1-KS3 curriculum, we are concerned that, outside the English framework, only in Maths and Science is there even the slightest reference to ‘spoken language’ in the opening section, while in all other subjects it is difficult to find any reference to language, vocabulary or communication. Spoken language needs to be more clearly integrated across the national curriculum to give teachers the structure from which to drive improvement, not just in English but across the entire spectrum.
The implications and issues of removing attainment levels are set out below.
Looking back to an era when curriculum guidance was thin, programmes of study were vague and there were no level descriptors there was initial concern about over prescription and inhibition of individual teaching style when the current system was introduced. However, there was a lot of poor teaching at the time, little accountability, idiosyncratic curriculum and teaching practice, and the needs of pupils with SEN in general and SLCN in particular were identified and met more by chance than planning. We certainly do not want to return to that era. We recognise the fact that National Curriculum levels and sub levels, P scales, and level descriptors are not without their flaws and in particular evidenced developmental stages of learning were not always accurately represented. However, particularly in terms of SEN and SLCN, the current system gives a clear framework to schools and teachers in association with reasonably detailed programmes of study, from which they can develop the school curriculum of their choice to address those Programmes of Study. The Communication Trust has case studies from its member organisations of the sorts of innovation that can bloom within a framework of development and achievement. The Framework has given us a nationally recognised, consistent and comparable way of making judgements of attainment and of measuring and demonstrating progress meaning that children and young people with SEN have a level playing field.
For Children and young people with SEN generally:
-Levels of progression create a level playing field for children with SEN, giving them access to the same system as their peers and therefore raising expectations of pupils and enabling them to be integrated into the same processes the school operates for all pupils.
-Levels of progression support children in seeing what the next small step is, and how they can achieve it. They create a mechanism for showing which skills and/or knowledge are needed to move on. This also applies to parents – as it gives them clarity of where their child is and what they have achieved against smallish step national markers as opposed to the unhelpful and potentially damaging approach proposed of telling young children where they are in terms of national comparison by percentage. We run the risk of going back to the days of pupils being told where they stand in the class league, not to their own starting point - but with no information about progress made. This approach does not take account of pupil’s needs in general and SEN in particular.
-As such, levels provide the framework for Achievement for All – a vehicle for pupil involvement in their own learning which is also supportive of good teaching practice and builds on learning theory such as Bruner and Vygotsky and is a necessary skill to develop in terms of achieving the deeper learning needed to understand as opposed to regurgitate.
-Summative end of key stage assessment sets a high bar and the result can be a simple pass/fail that does not support learning. What happens if you fail? To motivate and engage, we need to be able to reward tangible small steps of progress as you build to your goal of attainment. Such a system gives no indication as to what to do next or how to improve; it’s diagnostic testing at its worst.
For children with SLCN:
-The removal of levels may encourage a focus on knowledge acquisition rather than skills as the new curriculum is knowledge based. Children with SLCN need specific teaching of the skills needed to reach the next level, which will be outside the remit of a school published subject curriculum document – unless there is some guidance. This is exemplified by the lack of specificity around spoken language through KS1 & KS2 in the English Programme of Study thereby giving no guidance to schools at all in what to expect, what needs to be addressed and how. All children, including those with SLCN, need a range of skills in order to acquire knowledge; it’s a balance. Either one without the other results in poorer learning. Children with SEN and SLCN won’t develop those reflective skills by themselves as they are language dependent so the curriculum is skewed in favour of those able articulate and do the skills analysis for themselves.
-Despite the fact that the levels were not necessarily developmental in their progression, they none the less provided a breakdown – particularly for speaking and listening. This was important to show that speech, language and communication (SLC) skills do develop throughout school and also important in other subject areas. It’s not just the knowledge but also the skills that develop.
-We know that teachers struggle to measure progress in SLC, particularly at secondary age. It goes against research to suggest that schools and teachers will know how to achieve an end of KS summation of where pupils should be within ‘spoken language’ and to know all the developmental stages of receptive and expressive language and be able to apply these within English and across other subjects.
A note on inclusion and speech, language and communication needs.
The current National Curriculum documenthas useful information on how to make the curriculum more accessible which was extremely useful for teachers in terms of offering them guidance in how to adapt and ensure that the curriculum is accessible forpupils with SEN. This may be appropriate for the new SEN Code of Practice, and indeed reference is made to the new Code in the consultation document, stating that it will provide "advice on approaches to the identification of SEN" and "outline what needs to be done for pupils who will need access to specialist equipment and different approaches". However, the Indicative Code as stands does not contain this information. And indeed, if as the Code states, ‘all teachers are teachers of SEN’, it is important that guidance on SEN is integrated into all documents, such as the new Curriculum.
We are keen to see that reference to ‘spoken language’ also recognises the fact that pupils may communicate via sign systems, communication aids such as AAC, or other communication support.
We very much welcome the statement that 'all the skills of language are essential to participating fully as a member of society; pupils, therefore, who do not learn to speak, read and write fluently and confidently are effectively disenfranchised' and that the English curriculum 'will teach pupils to write and speak fluently so that they can communicate their ideas and emotions to others'. However, we are keen that the wording of the new Framework does not discriminate against those who may be able to communicate effectively but not speak fluently. We would therefore like to suggest alternativewording for this section ‘pupils, therefore, who do not learn to communicate effectively in speech, reading and writing are effectively disenfranchised'

2 Do you have any comments on the revised draft programmes of study or attainment targets for English?

/ 
/ Yes /
/ No
/ Comments:
The Trust welcomes the renewed emphasis on spoken language for the revised Framework Curriculum. We were particularly encouraged that the importance of spoken language has been clearly recognised and welcome the statements to this effect, such as that ‘spoken language underpins the development of reading and writing’.In particular we commend the Department’sintention in the use of the line: ‘all the skills of language are essential to participating fully as a member of society; pupils, therefore, who do not learn to speak, read and write fluently and confidently are effectively disenfranchised’, albeit with our earlier observations on the notions of ‘spokenlanguage’ and ‘fluency’. However, we believe that the English framework itself does not do this and and therefore the emphasis on spoken language risks being lost in the translation into classroom practice. We therefore believe the revised programmes of study for English presents something of a missed opportunity.
The English Curriculum Framework is broken down into 3 areas; Spoken Language, Reading and Writing. The Spoken Language Programme of Study for years 1-6 on one page (p17), featuring 11 bullet points of statutory requirements of what must be taught, which are not dissimilar to overarching elements of Speaking & Listening set out in the current curriculum. However, the omission of ‘Listening’ from the title is telling and the lack of reference specifically to ‘communication’ is also concerning. It is also telling that the only notes and guidance for primary schools around spoken language is less than 200 words long, which would be acceptable as a general outline but we do not believe is sufficient as a Programme of Study for children over a 6 year period. In contrast, there are approximately 25 detailed pages of guidance for the teaching of Reading & Writing. This is especially concerning when research has consistently found that teachers are far less familiar and confident in supporting the language development of their pupils.
As we expressed in response to the Reform of the National Curriculum consultation in April, a spoken language strand of this nature should take an evidenced approach, highlighting component elements of language and communication through a developmental approach, recognising shifts in language development and language demands throughout a child’s educational journey across a number of parameters as highlighted in the Trust’s Universally Speaking publications:
  1. Attention and listening
  2. Vocabulary
  3. Sentence building and grammar
  4. Story-telling and narrative
  5. Conversations and social interaction
A balance of these components provides a strong foundation for learning and the necessary vehicle for thinking and development across all subject areas, in addition to children developing the spoken language skills for the future. Whilst we appreciate the need to give teachers flexibility in the classroom we also know that many teachers report finding it very difficult to support children’s speech and language needs and that they are calling for more assistance in meeting the needs of children who struggle to communicate. We would suggest, based on the solid evidence available to us:
  1. more specific accompanying guidance for teachers to ensure spoken language is recognised for a wider range of purposes and guidance to demonstrate how spoken language can be embedded across the curriculum
  2. guidance around the component elements of spoken language to include the foundation skills that sit beneath complex concepts such as “discussion”
  3. professional development for teaching staff, for example level 3 award for all staff[1]
With over one million children in the country estimated as having some form of SLCN it is likely that two to three in every classroom will have difficulty and it is therefore vital that teachers are guided, through the curriculum, in how best to provide support. The detailed subject-level aims are an important part of achieving that and whilst they have not always been successful this is because of:
  • the importance of literacy in current measures / accountability
  • the lack of expertise on the part of teachers to teach speaking and listening well
  • the lack of detail for speaking and listening targets and teaching approaches
  • alongside detailed approaches to literacy (which teachers know far more about anyway)
We would like to see a fair and equitable system introduced for measuring progress and would encourage Ministers to look at the systems recommended by the Better Communication Research Programme[2] as a way of achieving that for speech, language and communication.
Some further suggestions relating to specific pages and paragraphs:
-We welcome the statement that spoken language is integral to all subjects (page 10), but the individual subject sections do not all make it clear how speaking and listening are to be incorporated. We would like to see a statement relating to the role of spoken language in each subject area with consistency as to how language supports learning. Additionally, we feel the spoken language strategies may be overlooked since they are not included directly in the programmes of study as they currently are.
-We are pleased to see that there is a general description of the speaking and listening skills that a child might be expected to develop in primary (page 17), but there is no year by year description of expected progression - this is only for reading and writing - and speaking and listening skills are only described here in the context of reading and writing (for example expressing views on poetry children have heard), rather than as skills in their own right.
-In the Language & Literacy section (page 10) - the list should include ‘understanding’ as ‘listening’ has been lost
-In the Vocabulary section (page 10) – comprehension of vocabulary is only mentioned in relation to reading and not spoken vocabulary
-Spoken Language section (page 17) – there is no linkage to the EYFS curriculum and building upon Communication and Language in particular,whereas in reading/writing they explicitly talk about building on the phonic skills etc from the EYFS
-KS1 Year 1 Reading (page 18) – full page about reading then a final paragraph about teaching oralvocabulary and helping those whose oral language skills are insufficiently developed, This important section should be in thespoken language section and built upon.
-There is a summary programme for years 1-6 which details the expected skills, but gives no guidance on progression. This is in contrast, for example, with other subject areas such as history, art, where broad guidance is provided about progression from years 1-2 to 5-6. Given that this research exists for spoken language, it may be helpful to consider some of the essential features of progression for how children develop their understanding and use of different aspects of language.
-We would like to see reference to pupils with speech, language and communication needs as well as those with literacy needs within English.

3 Do you have any comments on the revised draft programmes of study or attainment targets for mathematics?