RSC0017

Written evidence submitted by the Liberal Democrat Education Association

1. The post of Regional School Commissioner is relatively new on the education scene. Each Commissioner covers a large geographical area that in many cases seems to lack any coherence. Many RSC regions are not co-terminus with other regions such as those of Ofsted. While this may be less of an issue if RSCs remain only responsible for secondary schools, once coasting and converter primary schools are added to their portfolio of schools they will each potentially be responsible for several thousand schools.
2. Indeed, the RSC responsible for schools from Brimsdown in eastern Enfield to Burford in the Cotswolds of Oxfordshire has a region that can take two hours to traverse and is over 80 miles from one side to the other. Regions in more rural parts of the country are even larger. It is not clear how this relates to the provision of schooling as a service to a community?
3. A key consideration is whether, in an age of austerity, a third system of school oversight by regional commissioners to sit alongside that already in existence for community schools and the largely faith-based voluntary school sector is an efficient use of resources?
4. Furthermore it is not clear how the commissioner role relates to the oversight of education that remains with local authorities. For instance, community schools must go through a process of consultation before either growing in size or contracting. As has been shown by one UTC and an academy in 2015, these schools that come under the auspices of commissioners can close with no more than a phone call. At present, it is the local authority where the school is located that this then required to find alternative places for the young people affected.
5. In the longer-term it is not clear how the supply of school places, still currently a responsibility for local authorities, will be handled by commissioners, especially if the DfE insists on creating new ‘free’ schools and UTCs or Studio Schools where there is no need for extra places at present. If there were sufficient funds to allow an over-supply of school places such an approach might not matter. However, with other services being cut, it seems a curious approach to austerity.
6. Although the School Admissions Adjudicator has the responsibility for policing the admissions code there is a question about what role the commissioner should take if an academy or free school breaks the code?
7. Local authorities are also responsible for the following other functions that can conflict with the role of commissioners;

• support services for schools
• career development for teachers
• research
• whether or not there is selective secondary education locally
• school transport
• home schooling
• educating children out of school including those excluded
• Early years
• Children with special education needs and the creation of EHCPs

• Child protection and in particular missing children episodes including during the school day.

8. Commissioners do not have a support mechanism to deal with oversight and policy development for these issues where they are their responsibility. It also not clear how they would deal with complaints from parents not satisfactorily dealt with at the school level. It is not a matter of just enlarging the head teacher board that in many cases is lacking in expertise of the primary and special school sectors. Is there a need to build a parallel system to the existing local authority arrangements overseen by local democratically elected councillors, and if so, at what cost?
9. Commissioners need to be called to account by local scrutiny arrangements while local authorities have the responsibility for oversight of the education and welfare of young people.
10. Local authorities are inspected by Ofsted and in areas such as child protection must account for all schools. For that reason alone they need to be able to call commissioners and their staff before a scrutiny committee. Not to be able to do so would mean local authorities were open to comment by Osfted for services they cannot account for.
11. The alternative is to transfer all responsibility for national schools controlled by the DfE (Free schools, UTCs, studio schools and the various other forms of academies) to the commissioners and to make them subject to Ofsted inspection.
12. Either way, there is a need for clear and public accountability for work of the commissioners as they direct a key area of public policy. With such large geographical regions to cover it seems likely that a model closer to the NHS than to that traditionally used in schooling for the past hundred years might emerge. This risks weakening the relationship between parents and the policy process for education in a local area.
13. The Liberal Democrat Education Association would like to see primary education remain a local function since most parents send their children to the local primary school. With the return of public health to local authorities is seems less than sensible in planning and policy terms to remove primary and early years education for local control.
14. The case for secondary education to be regionally controlled needs to be evaluated alongside the success of the further education sector as a nationally controlled service operated by free-standing autonomous institutions. However, there are only around 600 colleges in the further education sector compared with around 2,000 schools in the secondary sector.
15. It seems both illogical and a waste of resources in a time of austerity to have several over-lapping bodies responsible for schools. Our preference would clearly be for democratic oversight by locally elected councillors supported by nominated professions and representatives of parents and local employers.
16. Our greatest concern is for the development and support of the workforce, both teaching and otherwise, if commissioners do not develop policies with regard to career development. The future leadership of the profession and its schools cannot be left to individual schools, academy chains or other groupings. Someone has to take responsibility for identifying and creating the next generation of school leaders. If commissioners do not do so, then who will take on this responsibility in these schools?

September 2015