Ofsted proposal to make use of unregistered provision a “limiting judgement” would be holding councils to “unattainable standard”: ADCS

Responding to Ofsted’s Improving the way Ofsted inspects children’s social care consultation, the ADCS clarified that although no Director of Children’s Services “actively condones” the use of unregistered placements, scrutinising individuals for factors “outside their control” may exacerbate existing workforce challenges and deter potential leaders from pursuing the role.

The Ofsted consultation, published in July, sets out proposals to reform two of its children’s social care inspection frameworks: the inspecting local authority children’s services (ILACS) framework; and the social care common inspection framework (SCCIF).

One of the changes proposed to the ILACS framework is that a local authority using unregistered provision would automatically fall below the requirements to be graded ‘expected standard’ within the relevant evaluation area.

Responding to this, the ADCS said: “DCSs share Ofsted’s vision for a children’s social care market which satisfies the needs of each place and allows children to stay living in their local area, where it is in their best interests.

“Adequate sufficiency can only be achieved once LAs have sufficient resource to create a surplus of availability to draw on when needed. Regrettably, that is not how the system works at present, and this change to the framework would, in effect, be holding LAs to an unattainable standard.”

It continued: “It is right for LAs to be held to account for use of public funds and decision making, but the issues here are systemic and members challenge use of these placements being included in the ‘Impact of Leaders’ evaluation area. It seems to run counter to Ofsted’s wider focus on, and prioritisation of, wellbeing and reducing the impact of inspections on leaders.”

The Association added that the use of unregistered placements, in the absence of an alternative for the cohort with the most complex needs, is “almost always a last resort”.

It noted that due to the unplanned nature of unregistered placements, a limiting judgement could also introduce an element of “luck” to inspection results.

It said: “An area might have had no children in unregistered provision for some time, yet find themselves in a situation as outlined above, shortly before an inspection commences.

“Ofsted plans to consider frequency of usage. How this will be calculated is important but, as yet, unclear. If the consistency of inspection is an area Ofsted is seeking to improve upon, ADCS members caution this could well have the opposite effect.”

The full ADCS response can be found here.

Lottie Winson