Flawed Performance descriptors for use in Key Stage 1 and 2 – Consultation

Dear Colleagues,

The DfE is currently consulting until 18th December consulting on performance descriptors for use in Key Stage 1 and 2. These are flawed with a gap between those achieving P8 and the new category of being below national standards. It also contains the idea that many thousands of pupils with SEN and disability will be labelled as Being Below National Standard or Working Towards National Standard.

This comes about because the new primary curriculum is focussing on particular skills in reading, writing and mathematics to the exclusion on nearly all else and the level of national standard 1 is roughly 2 years above the National Curriculum Level currently considered achieveable by the end of Key Stage 1 and Key Stage 2. In 2016 these will form the new floor targets-below which OFSTED says a school is failing. One does not have to be a crystal ball gazer to realise this will force many more primary schools to be academies and create a reluctance to enroll them. Those with larger numbers of children with SEN will be particularly hard hit. The proposal ignore the equality implications and the need for reasonable adjustments and will take us back to the chaos that existed after the initial inroduction of the National Curriculum after 1988 which took 12 years to at least partially sort out. But now the stakes are much higher.

I urge as many of you to robustly respond to this consultation which is a broadside against the inclusion of disabled children and those with SEN.

I attach my response to the DfE

The consultation paper can be found at
Best wishes

Richard Rieser,
World of Inclusion Ltd,
78, Mildmay Grove South,
N1 4PJ,

Website: www.worldofinclusion.com
Phone: +44(0)207 359 2855
Mobile: +44(0)7715420727
Skype: Richard Rieser

Response KS1 And KS2 Assessment Performance Descriptors Consultation.

  1. World of Inclusion Ltd provides training, consultation and materials to enhance inclusion and disability equality for schools and colleges in the UK and around the world.
  2. It is important to understand the context of how the needs of disabled children and those with SEN were met under the previous assessment systems. After the introduction of the National Curriculum in 1988 with its 8 levels, there was a period of years where those who could not meet the levels of the National Curriculum were just classified as W –Working Towards or were disapplied from the National Curriculum. After this various guidance was issued, but not until the 2000 Curriculum changes was there an expectation that all children should be on the National Curriculum. The P Scales were introduced for teachers to assess the level of pupils working below Level 1 of the National Curriculum but were not to be used as a normative assessment/league tables. Many teachers working with these found the step too large for children with learning difficulty and other systems such as Pivots were widely introduced. Levels 1 and 2 were also found to be too large to cover the range of abilities and level 1c,b and a and 2 c, b, a and subsequently breakdowns of higher levels were introduced.
  3. The General Inclusion Guidelines were produced as statutory guidance for teachers to provide guidance for differentiating teaching and assessment tools had to be adapted under the 2001 SEN Disability Act and the 2005 Disability Amendment Act now both incorporated into the Equalities Act. The current proposed assessment performance descriptors appear normative and do not take account of learning difference or the need for reasonable adjustments to access them. The lessons of the chaos of the past introduction of performance descriptors have not been learned and are likely to occur all over again.
  4. There does not appear to have been any consideration of the equalities impact of these proposed changes, particularly on disabled pupils requiring reasonable adjustments.
  1. The major problem with the new Assessment criteria is that for the many pupils whowill not reach National Standard they will be labelled Working Toward National Standard, Below National Standard, or being ‘Below, Below National Standard’ or ton P8 to P1.
  2. WOI is concerned that there will be a gap between p 8 at the top of the P Scales and those working below national quote “15.There will be some pupils who are not assessed against the P-scales (because they are working above P8 or because they do not have special educational needs), but who have not yet achieved the contents of the ‘below national standard’ performance descriptor (in subjects with several descriptors). In such cases, pupils will be given a code (which will be determined) to ensure that their attainment is still captured.
  1. These pejorative and discriminatory grading labels will not be likely to encourage self esteem, on the contrary as they will be used to set new floor targets for primary schools to achieve they will act as a great disincentive for primary schools to admit those children with impairments and Special Needs that are likely to put them in these assessment categories.
  1. The last 20 years has demonstrated that many disabled pupils and those with SEN often progress at slower rates than their peers . The document says pupils should not move on to work on the next key stage even if they have mastery. It is silent about those who will need to be working below National Standard 1 when they progress to key stage 2, presumably they will still be working below National Standard 1, or is the intention to keep them back until they reach nation standard 1?
  1. Many parts of the world use a grade system and hold children back until they reach the required grade. This has an adverse effect and leads to drop out and non-recruitment of disabled children. The DFE need to be very careful that in their keenness to raise standards that they do not create a hidden grade system that will have a massive negative impact on inclusion and the achievement of disabled children.
  2. The value of the Level system was that they could work at their level in the class while their peers doing work on another level. The proposed assessment framework is geared to a normative level that is considerably higher than the previous levels –approximately 2 years. It is also much more restrictive than the previous Levels with a strong knowledge and skills base, which will also adversely impact on many disabled pupils and those with SEN.
  3. WOI is most concerned about the lack of thought or practical details about how disabled children and those with special educational needs are meant to demonstrate what they can do under these performance descriptors. There is no evidence of any thought about differentiating these performance descriptors or of taking account of children who due to their impairment will need reasonable adjustments in how they are graded. For example take handwriting in written English. There will be a range of pupils who will never be able to develop their handwriting due to their impairment. They will however be able to express themselves through using a keyboard, speech to text or other switching systems.
  4. There is little evidence from Primary Educationalists that the programmes of study or the assessment criteria will aid an education based on a child development model. (See the Cambridge Education Review and Robin Alexander’s work).It is worth noting that in the highest performing school systems in the world –Finland-children are only starting their formal education when under this assessment system children will already have been force fed this curriculum and testing for three years. There is a grave danger of turning many children off learning by imposing such a performance assessment system.
  5. “The United Kingdom Government is committed to continuing to develop an inclusive system where parents of disabled children have increasing access to mainstream schools and staff, which have the capacity to meet the needs of disabled children”.[Interpretive Declaration Article 24 UNCRPD] This is the interpretative declaration of Article 24 and the Children and Families Act Part 3 has a presumption of inclusion. It is hard to see how either of these commitments can be maintained with this teacher assessment tool which does not allow for measured progress from P-scales to Below National Standard.
  6. We propose replacing ‘Working Towards National Standard’, ‘Below National Standard’ and ‘Below, Below National Standard’ with a new scale of Emergent National Learner scale 1-6 which will bridge the areas in each curriculum area between p8 and National Standard 1. These could be pegged to the old levels 1c,b,a and 2c,b,a. These criteria are known to teachers and would plug the current gap. The content could be adjusted to fit the new curriculum programmes of study. This would also enable teacher assessment to cover all learners.
  7. In January 20134 17.9% pupils in schools in England had special educational needs (equating to 1,492,950 pupils). Current statistics (Sept 2014 Annual Report DfE) demonstrate the folly of proceeding in the way proposed. The attainment gap in phonics has increased in the last year The attainment gap was 44 percentage points with 32% of pupils with SEN meeting the required standard compared to 76% of pupils with no SEN. Pupils with SEN performed significantly worse than pupils without SEN at the end of KS1 The gap is largest in writing (45 percentage points), and smallest in mathematics (31 percentage points). Compared to 2011/2012 the gap has narrowed in all subjects, most notably by 2 percentage points in both reading and writing. At KS 2 the attainment gap between pupils with SEN and those without in reading, writing and mathematics is 53 percentage points. These statistics are only based on those entered for the tests/assessments and many were not suggesting an even larger gap.
  8. The current proposals ignore these realities and as it is generally acknowledged that the National Standard is two levels above the current levels the impact is going to be far greater and the attainment gap far larger. The system proposed is not fit for use in as school system where 18% of pupils have special needs and an unknown but likely but different but overlapping population count as disabled under the Equalities Act
  9. WOI strongly urges that these draft performance assessment descriptors are withdrawn and reconceptualised in a way that can include all learners and to take account of the need for reasonable adjustments for disabled learners.
  10. Submitted by Richard Rieser CEO World of Inclusion Ltd submitted to Department for Education rlrierser@gmail.com

PerformanceDescriptor.CONSULTATION@education.gsi.gov.uk by closing date of consultation 18th December 2014.

The consultation paper can be found at


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