NALDIC’s response to Ofsted’s draft education inspection framework for 2019

NALDIC has responded to the draft eduction inspection framework published by Ofsted earlier this year. Our statement is reproduced below. Anyone is entitled to submit a response to the document and may do so until 11:45 on Friday 5 April at this website.

Members are welcome to use NALDIC’s statement to guide their personal responses.


NALDIC has clearly stated its position for more than 25 years: that the teaching and learning of English as an Additional Language (EAL) has a distinct pedagogy. It is therefore regrettable that the new Ofsted framework makes no reference to EAL as either a discrete focus or a paradigm. EAL is not a marker of ‘vulnerability’. It is a sign of a rich linguistic heritage that schools and pupils should capitalise on to the benefit of all. Nevertheless, we recognise that in the current approach there are limited opportunities to make visible the distinct needs of EAL learners. Below we offer our recommendations to Ofsted for the revision of its draft inspection framework to ensure that the needs of the 1.54 million pupils in England for whom English is an additional language are explicitly and accurately acknowledged.

NALDIC urges Ofsted to set an expectation that schools will reflect the linguistic and cultural characters of their communities

We are encouraged by positive statements around equality, diversity and inclusion to place safeguarding and the monitoring of good relations between all pupils at the heart of the inspection framework. From an EAL perspective this implies that schools must take account of the linguistic and cultural contexts of their school community, ensuring that all schools develop an explicit strategy for multilingualism and the development of intercultural perspectives that seek to eliminate discrimination for all.

NALDIC urges Ofsted to set an expectation that schools will carefully assess and monitor the English language development of their EAL learners, using an appropriate EAL-specific assessment framework, to inform effective planning and provision for pupils at all stages of English proficiency

Research suggests, for example, that it takes 5-10 years for new-to-English pupils to develop linguistic competence in-line with age-related expectations for their monolingual peers. There is also good evidence that pupils for whom English is an additional language who are also competent or fluent in English (as demonstrated by the recently scrapped Proficiency in English scale) attain more highly than the average for all pupils on many measures, such as SATs and GCSEs. However, those with poorer command of English tend to underperform relative to the average attainment for all pupils. Understanding EAL learners’ levels of attainment in English and using these data to inform practice is key to effective planning and provision.

NALDIC urges Ofsted to set an expectation that an ‘ambitious curriculum’ for EAL learners accurately reflects their cognitive and academic potential

We welcome the acknowledgement of the importance of a high-quality ambitious curriculum that provides all pupils with the knowledge and cultural capital for success through study of a ‘full curriculum’. For pupils with EAL this implies learning in mainstream classrooms, in contexts which match teaching approaches to cognitive and academic potential. This means not filtering learning experiences through materials and approaches that are rooted in an EAL learner’s current level of English proficiency only. Teaching approaches that use English proficiency as a proxy for general academic ability are likely to be inappropriately challenging. Guidance in the inspection framework should reflect this.

NALDIC urges Ofsted to ensure that the inspection framework reflects the importance of inclusion for EAL learners

We understand the pressures on staff and the notion of ‘unnecessary workload’ but are concerned about the increasing incidence of ‘outsourcing’ teaching and learning to external providers (such as extensive ESOL-type courses), inappropriate interventions offered by non-specialists, or interventions delivered by trained EAL specialists in pedagogically insecure withdrawal contexts. All of these allow mainstream practitioners to abdicate their responsibility for making the necessary plans and provision for the EAL learner to whom they are ultimately responsible. EAL learners need specialist support, but language-rich teaching benefits all pupils and should be at the heart of every lesson.

NALDIC urges Ofsted to set an expectation that engagement with EAL research is a central part of school accountability

It is reassuring to see that the value of research is recognised in the new framework, particularly the evidence on the variations in attainment data for different ethnic groups. This shows clearly that schools need to be aware of the communities most at risk of disengagement and concomitant under-attainment. We call for further use of research evidence: there is a substantial body of specialist knowledge around EAL.

NALDIC commends the expectation that leaders should be committed to ongoing staff CPD, and wish to highlight NALDIC’s continuing contribution to EAL-specific CPD through the EAL Journal, national training events, and the many Regional Interest Groups (RIGs) around the country.

NALDIC recognises that Ofsted is uniquely placed to inform and influence teaching and learning in schools in the UK. By failing to make explicit reference to EAL learners in its inspection framework, Ofsted tacitly suggests that schools do not need to demonstrate how they meet the statutory entitlements of those learners. 

NALDIC urges the framers of this document to make explicit their expectations regarding the 1.54 million EAL learners in English schools. By including explicit reference to EAL learners, Ofsted is in a position to ensure that the statutory entitlements of this significant group are delivered and not ignored.

Below we have highlighted specific areas from within the document where explicit reference to EAL learners could have been made but was not. We trust that these will be given due consideration following the consultation and that Ofsted will address the absence of EAL in its revision of the document.



NALDIC acknowledges that OFSTED have released two draft documents

1.    Proposed Inspection Framework

2.    An Equality, Diversity and Inclusion statement

The two need to be read in tandem

Points of consideration

  • ‘English as an Additional Language’ is invisible in both documents
  • As a learner group with protected characteristics, unlike disability (SEND); race; religion and belief; sex. (EDI p5)
  • As a skill/knowledge (including multilingual/translanguaging affordances and developing Proficiency in English)
  • As a concept: as with all OFSTED’s recent releases (e.g. Bold Beginnings) the draft Inspection Framework is based on a monolingual model of society and education. This model does not reflect the reality of the UK’s education system, nor UK society.
  • In contrast, SEND and ‘disadvantage’ is specified as areas of concern and priority throughout both documents.

This is regrettable on several counts

  • Research indicates that Proficiency in English is the most significant risk factor for EAL learners (e.g. Strand and Hessle 2018). However, there is no flag on this in relation to assessment.
  • Research indicates the importance of intersectional analysis to establish EAL groups who characteristically enact protected characteristics. ‘Race’ as defined by Census ascription is insufficient for the purpose.
  • ‘EAL’ is not in itself a ‘disadvantage’ although poor provision may construe it as such for any individual learner in any given context. However, this is the only space available to make EAL learners and their discrete needs visible within the proposed Framework (unless they are SEND or otherwise intersect with an OFSTED protected characteristic). It is a meagre vision for EAL.

Therefore, although much of what is contained within the Proposal for Inspection could be beneficial for EAL learners in their complex variety, there is no guarantee that this will be the case.

Helping to protect learners. Framework p5

  • ‘Inspectors will always take into account how well learners are helped and protected so that they are kept safe’.
  • NALDIC response: If schools do not have an explicit strategy for multilingualism and intercultural perspectives in its community, how is safeguarding to be assured for EAL children and young people?

Equalities Act/Human Rights Act. Framework p5

o  NALDIC response: This has the potential to offer the most direct leverage for HMI to ensure equitable provision for EAL learners and their families and its explicit referencing is very welcome.

Key Judgements. Framework p10

  • ‘leaders adopt or construct a curriculum that is ambitious and designed to give all learners, particularly the most disadvantaged, the knowledge and cultural capital they need to succeed in life’

o  NALDIC response: This could be beneficial for EAL learners because it is inclusive and holds to account discriminatory practices such as extended withdrawal with limited curriculum content, age inappropriate ESOL classes and off rolling’. However, it does not factor in the cultural capital (including linguistic knowledge) that EAL Learners bring to school and may prioritise narrow assimilation strategies.

  • ‘the provider has the same academic, technical or vocational ambitions for almost all learners’.
  • ‘Where this is not practical – for example, for some learners with high levels of special educational needs and/or disabilities – their curriculum is designed to be ambitious and to meet their needs’
  • ‘learners study the full curriculum’
  • ‘teachers present subject matter clearly, promoting appropriate discussion about the subject matter being taught. They check learners’ understanding systematically, identify misconceptions accurately and provide clear, direct feedback. In doing so, they respond and adapt their teaching as necessary, without unnecessarily elaborate or differentiated approaches’
  • ‘Promoting discussion’…where children can experience and potentially participate within only reasonably can happen in orally dynamic contexts…this implies curriculum related discussion where good models of language are apparent (the mainstream) rather than in orally linguistically reduced often ‘guided’ sessions such as in lower sets/groups or withdrawal settings (1:1 or small groups of beginners).
  • ‘over the course of study, teaching is designed to help learners to remember in the long term the content they have been taught and to integrate new knowledge into larger concepts’.

o  NALDIC response: All of these could be beneficial for EAL learners because the focus is inclusive and ambitious and holds to account discriminatory practices such as extended withdrawal with limited curriculum content, age inappropriate ESOL/EFL classes and ‘off rolling’. However, the devil is in the detail. As EAL learners are not mentioned as a discrete group, it is not possible to be sure (for example) that the pedagogies required to ensure they are learning both curriculum and language may not also be deemed ‘unnecessarily elaborate’. The language used here also implies learning of mainstream curricula that is differentiated sufficiently for all learners to build upon what they already know. Explicit acknowledgement should be made here by Ofsted that EAL learners may know more than they are able to articulate at their current level of Proficiency in English. Ofsted should, therefore, make explicit that it expects to see approaches to teaching EAL learners that acknowledge and account for this, rather than filtering EAL learners’ educational offer through materials and approaches that are rooted at their current Proficiency in English rather than their cognitive and academic potential.

Key Judgements: Framework p10

  • ‘teachers and leaders use assessment well’
  • ‘leaders understand the limitations of assessment and do not use it in a way that creates unnecessary burdens for staff or learners’

o  NALDIC response: As noted, Proficiency in English is a crucial factor in enabling EAL progress and attainment. Ofsted should be clear that it considers assessment of Proficiency in English to be a prerequisite to effective provision for EAL learners. Thus wording in the document should protect against the possibility that language assessment will be framed as an ‘unnecessary burden’?

  • ‘The resources and materials that teachers select – in a way that does not create unnecessary workload for staff – reflect the provider’s ambitious intentions’

o  NALDIC response: As noted, EAL learners have discrete provision needs. The framework should use language that helps to ensure that the selection, creation and use of resources that address these discrete needs are not framed as ‘unnecessary workload’.

As mentioned above, there is a statutory right for EAL learners to receive a full and balanced curriculum. NALDIC is concerned that the job of teaching and learning for some EAL learners, especially those new to English will be referred on to pedagogical contexts that contradict this entitlement (e.g. inappropriate withdrawal, ESOL model teaching, tasks of insufficient cognitive challenges, off rolling and so on). Ofsted should make clear that it expects mainstream educators to be the individuals responsible for ensuring appropriate provision in the first instance to protect against abdication of this responsibility.

Impact Framework p11

  • ‘learners develop detailed knowledge and skills across the curriculum and, as a result, achieve well. Where relevant, this is reflected in results from national tests and examinations which meet government expectations, or in the qualifications obtained.’

o  NALDIC response: This must be couched in terms of known trajectories for EAL learners in terms of age entering the system and other contextual factors that affect rates of progress and ultimate attainment.

Personal development: Framework p12

  • ‘the curriculum extends beyond the academic, technical or vocational and provides for learners’ broader development’
  • ‘the curriculum and the provider’s wider work support learners to develop their character’
  • ‘at each stage of education, the provider prepares learners for future success in their next steps’
  • ‘the provider prepares learners for life in modern Britain by: equipping them to be responsible, respectful, active citizens who contribute positively to society; developing their understanding of fundamental British values; developing their understanding and appreciation of diversity; celebrating what we have in common’
  • NALDIC response: These elements strongly imply that EAL learners are not here just to learn English but need to acquire appropriate academic language through the curriculum and meet the wider aspirations of the educative process. If monitored within the context of knowledge, understanding and empathy of EAL learner contexts, this could offer positive leverage. Wording should reflect this.

Leadership Framework  p12

  • ‘leaders have a clear and ambitious vision for providing high-quality, inclusive education and training to all. This is realised through strong, shared values, policies and practice’

o  NALDIC response: Inclusion as a principle implies broad and balanced provision which is best achieved for EAL learners through full inclusion in mainstream classes, with appropriate pedagogical adjustments. Wording should reflect the expectation that EAL learners will be included at all levels of their educational offer.

  • ‘leaders focus on improving staff’s subject, pedagogical and pedagogical content knowledge to enhance the teaching of the curriculum and the appropriate use of assessment’.

o  NALDIC response: Pedagogical knowledge would include knowledge of bilingualism, how a second language is acquired and how to teach to meet the distinctive needs of learners at different levels of Proficiency in English, making the curriculum appropriate and relevant to children with a range of additional life experiences beyond a monolingual, monocultural perspective, building upon prior learning and so on. This implies ongoing CPD for direct teaching and learning for those with EAL and guidance for those working in support roles and should be explicitly mentioned in the framework.

  • ‘leaders aim to ensure that all learners complete their programmes of study. They provide the support for staff to make this possible and do not allow gaming or off-rolling’

o  NALDIC response: Nor part release to uncertain providers e.g. ESOL-type courses without the school monitoring the practice and provision of the provider and monitoring the progress that students make in these contexts.

o  Offering suitable options at GCSE and ensuring that their curriculum offer is not restricted to English language learning at the expense of a broader and more balanced curriculum as an entitlement. is a publication of NALDIC, the subject association for EAL. Visit to become a member.