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Consultation Response Form

Consultation closing date: 13 June 2014 Your comments must reach us by that date

National Curriculum Reform: 4 Core Subjects

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Draft Order and Regulations:

1 Do you have any comments on the draft Order which is proposed to give effect to the new ‘National Curriculum in – Framework Document’, which includes the programmes of study for English and mathematics for key stage 4? The programmes of study will be taught to year 10 pupils from September 2015 and to all key stage 4 pupils from September 2016.

 Yes No Not Sure

Comments:

It is unreasonable to expect comments when final programmes of study for Key Stage 4 English and mathematics have not yet been published. This gives no reassurance that our comments on the draft programmes of study have been taken into account. Based on these drafts, we have a number of concerns about the content of these programmes of study, the extent to which they provide for appropriate progression from , and the disproportionate negative impact which they are likely to have on various ‘protected characteristic’ groups. These concerns are set out below.

1. Comments on the draft programmes of study for Key Stage 4 English. 1.1. Although the subject content for KS4 English is intended to be consistent with the subject content for revised GCSEs in English language and English literature, it appears to be a truncated amalgam of the respective GCSE syllabi without any rationale being given for the chosen selection. 1.2. Given the removal of GCSE English, with the consequence that many pupils will in future be entered only for a single GCSE in English language (rather than GCSEs in both language and literature), there may be a disincentive for schools to teach some of literature elements of draft subject content, particularly a whole Shakespeare play and novels from across three centuries. It is expected that most schools will teach the KS4 English curriculum through GCSE courses in English language and English literature, so pupils who are only studying the single GCSE in English language may miss out on those aspects of the KS4 English curriculum which will be delivered through GCSE English literature. This could be remedied by reinstating a GCSE in English. 1.3. Given that the vast majority of pupils will be taking GCSE English language (perhaps also in conjunction with GCSE English literature), the KS4 English curriculum may only have relevance for the very small minority of pupils for whom GCSE entry is inappropriate. Such pupils will generally be functioning below level 1 of the national qualifications framework, in which case the KS4 English curriculum is likely to be very demanding for them, especially as much the content seems to be pitched at the current A*-B candidate.

1.4. It is of considerable concern that the draft subject content for KS4 English appears to focus on academic demand at the expense of the development of functional literacy. Insufficient basic literacy has been included for less able pupils and those for whom English is an additional language (especially those newly arrived in the country). Such pupils will be disenfranchised if the content is too demanding for them to access. 1.5. Ironically, it is also possible for pupils to demonstrate skill, knowledge and understanding in relation to some of the ‘higher’ content whilst still performing poorly in functional literacy. This is something that many employers complain about, as they would normally expect a C grade at GCSE to indicate that a young person possesses functional literacy, although they, apparently, often find that this is not necessarily the case. It seems, therefore, that it may be a perverse consequence of the accountability system that more pedagogical attention is given to the acquisition of so-called higher order skills at the expense of ensuring that more basic aspects of literacy are established. As the proposed subject content pays scant regard to basic literacy, this phenomenon is likely to continue. 1.6. As the proposals appear to emphasise technical and higher order English skills over functional literacy, it may be that pupils who are less confident as readers, writers and speakers of English will fall even further behind as they will find it difficult to access the subject at a level which meets their needs. The proposed subject content seems to assume that pupils will arrive at KS4 fully confident in their reading, writing and speaking skills, which, for significant numbers of pupils, will not be the case. 1.7. It is evident that there has been an attempt to embody an expectation of higher standards in the new curriculum, but too much reliance has been placed on adding more demanding content without considering how to engage pupils effectively in the process of learning. This could turn out to be counter-productive as, without ensuring that the curriculum is sufficiently stimulating to engage learners, pupils may become alienated, in which case standards would soon decline rather than increase. 1.8. The attention given to spoken English in the new curriculum is welcome; however, as for most pupils this will be assessed through GCSE English language, in which accreditation for speaking and listening is to be reported separately on the certificate rather than contributing to the final grade, there is a significant risk that spoken English will not be given the time and space that it deserves in terms of curriculum delivery. It is imperative that spoken English be taught and assessed on a par with reading and writing to prevent it being devalued, with the concomitant risk of estranging and demotivating pupils whose strengths lie in this area of the curriculum. 1.9. There are considerable implications for teacher workload, professional training and support if teachers are to be ready to deliver the new curriculum from September 2015. It is not clear that sufficient time and funding will be available, particularly in the case of small and rural schools.

2. Comments on the extent to which the draft programmes of study for English provide for appropriate progression from Key Stage 3. 2.1. There are many ways in which the proposed subject content is narrower than the current (disapplied) National Curriculum. In particular, the subject content for English at KS3 emphasises world literature and reading for pleasure, neither of which are specified in the draft revision. This may mean that it will be very difficult to ensure that reading for pleasure remains an essential aspect of English beyond KS3, and as the draft revision fails to mention non-British literature in English, it is not clear how a love and learning of literature written in English by people who are not English (which will have been encountered at earlier Key Stages) can continue to be developed in KS4 – surely an unnecessary restriction given the wealth of literature written in English by American, Antipodean, African and Indian writers? 2.2. Overall, there appears to have been an insufficient focus on progression between Key Stages. Whilst effective progression has been attempted in terms of subject content, it cannot be assumed that progression will follow automatically merely because of this. 2.3. The model of progression adopted in the new National Curriculum appears to be one in which pupils are seen as a homogeneous group and are, therefore, expected to achieve at the same level. This is a dangerously erroneous notion which, if enacted, could have a devastating impact on the lives of significant numbers of pupils, particularly those with special educational needs. 2.4. A major problem is that because the new KS4 curriculum is being implemented only one year after implementation of the new National Curriculum at all other Key Stages (except for years 2 and 6), the first few cohorts will not have had the benefit of studying the new curriculum at all the earlier Key Stages, which will mean that instead of there being a smooth incremental progression from KS3 to KS4, there will, instead, be a sharp and sudden increase in demand. This makes no educational sense at all and risks setting up many pupils to fail. The situation is exacerbated by the fact that it will take nine years for the system to catch up with itself (as it will be nine years before the Year 1 cohort of 2014 reach the beginning of Key Stage 4).

3. Comments on the draft programmes of study for Key Stage 4 mathematics. 3.1. No rationale is given for the subject content, which although intended to be consistent with the subject content for GCSE mathematics, is actually a truncated version. As most pupils will be studying for GCSE mathematics at KS4, it is not clear who the target market is for this selective version of the GCSE subject content. 3.2. Even more curious is the presence of additional mathematical content to be taught to more highly attaining pupils. As such pupils will invariably be studying for GCSE additional mathematics (which has even more content than that contained in the draft content for KS4 mathematics), it is not clear that there is a constituency for this additional content. It also seems perverse to present a National Curriculum which applies only to higher achieving pupils – shouldn’t a National Curriculum be an entitlement for all pupils (notwithstanding the fact that it only applies to a vanishingly small number of maintained schools)? 3.3. Whilst it is appreciated that a certain level of technical skill needs to be established to prepare those with an aptitude for scientific, engineering, technological and mathematical (i.e. STEM) professions, more attention needs to be paid to the development of functional numeracy, which will benefit all pupils into their adult lives. 3.4. As it is, the proposed curriculum appears to be designed with the higher achieving pupil in mind. The more challenging demand may prevent lesser able pupils from accessing the mathematics curriculum. It may transpire that only the very best pupils will be able to master the new curriculum, in which case this increase in demand (presumably intended to raise standards) may prove to be counter-productive as it may alienate or otherwise disenfranchise pupils who cannot reach the new expectations. 3.5. There appears to be an over-emphasis on facts and procedures at the expense of understanding and problem-solving. Deeper conceptual understanding will not be achieved merely by teaching content at an earlier age or stage, or by imposing additional content at each Key Stage. This approach is more likely to lead to topics being covered (and, therefore, learned) at a superficial level, which will not establish a firm foundation for later learning. 3.6. The amount, and level, of content included in the curriculum is far too ambitious, especially as many pupils will already have been left behind at earlier Key Stages. 3.7. The new curriculum in mathematics will undoubtedly require more teaching time than most schools currently devote to mathematics teaching. At a conservative estimate, most schools will need to find an additional hour per week to deliver this broader and more demanding curriculum. There are several problems associated with this. More teachers of mathematics will be required, and yet mathematics is already a shortage subject. This may mean that some schools will have to employ non-specialists, which will have profound consequences for both quality of teaching and learning outcomes. In order to make room for more time and additional teachers, many schools will have to reduce time for other subjects, with entirely foreseeable consequences for pupil attainment in those subjects and the continued employment of non-mathematicians. 3.8. Many pupils are likely to find this new curriculum very challenging, but it would be iniquitous if they were to have to spend more time grappling with mathematics at the expense of other subjects, especially subjects in which they may display talent and enthusiasm. Additional time spent on core subjects should not detract from pupils being taught a broad and balanced curriculum, especially as success in other subjects may prove to be an effective trigger for engaging pupils in mathematical content delivered through an appropriately contextualised cross-curricular programme. 3.9. There are significant funding, support and training implications associated with the implementation of this new curriculum. Time and resources will be needed for the necessary preparatory work to be done, when many teachers are already experiencing workload pressures and low morale. With the rapid contraction of an effective .middle tier’ within education, traditional sources of support are no longer available to many schools, and reduced budgets make it difficult for schools to buy in support from elsewhere. In this context, the must act responsibly and decisively in funding and promoting appropriate support and making resources available to schools to enable them to form collaborative networks.

4. Comments on the extent to which the draft programmes of study for mathematics provide for appropriate progression from Key Stage 3. 4.1. The main problem here is that the Programmes of Study for Key Stages 1-3 lack age appropriateness in that content which is currently required at higher Key Stages has been pushed down to lower Key Stages. In mathematics, more than any other subject, we fear that this takes insufficient account of research into child development, especially in relation to how children learn and the individual differences in rates of development between children. It appears that more content at a higher level of demand has been pushed down from the secondary to the primary curriculum in order to ensure that pupils will be ‘secondary ready’ for an even more demanding curriculum at KS3 and KS4. In a subject such as mathematics, in which early failure can lead to severe psychological impairment (including numerophobia and arithmophobia), it is irresponsible to impose demands which are unattainable for many children. The attempt to stretch the more able risks alienating the less able, and this may prevent smooth incremental progression for many pupils. 4.2. The key to effective progression in the learning of mathematics is to ensure that pupils master mathematical reasoning at an early stage, thus establishing a secure foundation on which to build. The stance taken in the new curriculum seems to involve expanding content and teaching more demanding content at an earlier age in an attempt to accelerate progress, which runs counter to what is actually needed. This even goes against the Government’s original intention of reducing curriculum content so that pupils could master less content in more depth. 4.3. By the time many pupils reach KS3, they will have fallen so far behind in mathematics that it hardly matters whether the subject content for KS4 provides appropriate progression from KS3. The main reason for this is that the Programmes of Study for primary mathematics require a high proportion of abstract mathematical concepts to be taught at an age when most children’s thinking is too concrete for this to be possible. The highest performing jurisdictions, including Singapore (which appears to have been the inspiration for much of the new mathematics curriculum), actually guard against teaching abstract concepts at too early an age as such a practice can seriously damage children’s cognitive development. 4.4. Mathematics is affected to an even greater extent than English by the problem outlined in 2.4 above.

5. Comments on the disproportionate negative impact which the proposed programmes of study are likely to have on various ‘protected characteristic’ groups. 5.1. The higher levels of demand and challenge which are incorporated within the new curriculum may prevent pupils with learning difficulties from accessing learning. In turn, this may impede the numeracy and literacy development of such pupils. To reduce this adverse impact, the content needs to be amenable to differentiation (by task and/or outcome) to accommodate the full range of ability found at KS4. 5.2. Making the knowledge requirements more demanding will frustrate teachers’ efforts to promote learning and is likely to demotivate lesser able students (including those with learning difficulties, whether general or specific), thus impeding their progress. Such an increase in demand, whilst intended to raise standards, may therefore have the opposite effect. Making a qualification more difficult does not, in itself, guarantee higher standards. In order to address this, it is important that there is adequate recognition of individual pupils’ needs in both the design and also the delivery of the curriculum. 5.3. The need to get through more content will leave less time for securing a sound understanding of that content. Whilst teachers will work hard to mitigate the impact of any negative consequences by differentiating the learning, putting on extra classes, providing individual and small-group coaching and specialist intervention, and also by using diverse and innovative pedagogies to stimulate and engage learners, it would be helpful if some dispensation were given to allow the content to be reduced in the case of lower-attaining pupils, especially those with learning difficulties or other disabilities which slow down cognitive processing. 5.4. Pupils who are undergoing, or have recently undergone, or are considering undergoing a gender reassignment process during their KS4 years may have periods of time when they are out of school. This is likely to have a negative impact if the curriculum being delivered is linear, incremental and cumulative, a situation which is more likely to occur in mathematics than in English. Solutions may lie in how the content is delivered. 5.5. As in the case of gender reassignment, pupils who are pregnant or who have recently given birth will experience some discontinuity in their schooling and may have difficulty re-engaging with the curriculum if it is delivered in a linear, incremental and cumulative manner, a situation which is more likely to occur in mathematics than in English. Teachers need to be trained (and supported through continuing professional development) to acquire the flexibility to adapt the curriculum so that it can be delivered cyclically (for example, revisiting ideas at regular intervals and putting them in different contexts, and reinforcing these ideas by adopting cross-curricular approaches (for example, delivering aspects of mathematics through other subject areas). 5.6. Race is most likely to have a negative impact in the case of Traveller children and asylum-seeking children, as both of these groups may experience disruption to their education through frequent changes of school and being admitted to a school mid-year. An added difficulty for some asylum-seeking children (and also children of economic migrants) is that they may be learning English as an additional language (EAL). In some cases, a reduced curriculum could be offered to such children so that they have more time to focus on less content. In the case of EAL children, provision of interpreters may be critical, and it may also be worth considering whether a GCSE in English as an additional language could be developed (in a similar way to how, in Wales, GCSEs are available for those learning Welsh as a first or second language). 5.7. The timing of some religious festivals and periods of religious observance (such as Ramadan) may vary from year to year, as will the potential impact on pupils who are celebrating a festival or observing a fast. In some cases, any negative impact can be reduced by schools offering additional support to pupils. 5.8. It is commonly thought that girls are less confident about their mathematical ability than boys, especially when they are in mixed classes – and that boys are less confident about their English skills than girls (again, especially when they are in mixed classes). However, research appears to be equivocal on both of these issues, especially as there is as much, if not more, variation within each sex group as there is between the sexes. In any case, good teachers are competent in using a variety of strategies to engage both boys and girls in the curriculum. Nevertheless, it would have been helpful for the new curriculum to have been piloted before being implemented nationally to see if any gender differences emerged. 5.9. In regard to sexual orientation, KS4 can be an unsettling time if, at that time, young people are ‘coming out’ in terms of disclosing their sexual orientation, as such disclosure may be associated with personal emotional stress and/or homophobic bullying, both of which can have a negative impact on a young person’s engagement with the curriculum. In such cases, access to counselling services, sensitive pastoral care and strong anti-bullying policies and practices may help to reduce any negative impact.

2. Do you have any comments on the draft Regulations which are proposed to disapply the current programmes of study for English and mathematics for key stage 4 for year 11 pupils in school year 2015/16 to allow for the phasing of the new programmes of study, set out in 1 (a).

 Yes No Not Sure

Comments:

As there are many schools for which the National Curriculum is not statutory, the question of disapplication is largely an irrelevance. Although some maintained schools may be enjoying being free of the current curriculum constraints in order to assist them in preparing for the forthcoming changes, there is a risk that the ‘free for all’ which this has created is engendering chaos in the system and depriving children of their statutory entitlement to a broad, balanced and relevant curriculum. For this reason, we have reservations about the proposal to extend the disapplication of the current programmes of study for a further school year. Whilst it would make little sense to re-instate a curriculum which has already been disapplied, it is clear from the original Order that this disapplication was not intended to extend to 2016. Furthermore, we are generally opposed to the introduction of mechanisms by which the government can fast- track changes by the increased use of secondary legislation in the form of statutory instruments which can be initiated at the whim of the Secretary of State without recourse to parliamentary scrutiny or Royal Assent. The use of such secondary legislation undermines the law, especially

when it involves removing underpinning primary legislation without the need for a vote in parliament.

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