How did the Department for Education come up with these proposals?

All of this material comes from a Freedom of Information request, available here. The proposals themselves are available here. They amount to the biggest change in the secondary MFL Curriculum since 1987 and relate to a subject widely accepted to be in crisis, yet one of crucial importance to post-Brexit Britain.

Key documents

Details on how the panel was appointed and when it met:

The Minister’s decision to create the panel and approve its membership

Terms of Reference of the panel

What does this FOI request show?

The panel

  1. It was convened very hastily – in 8 working days, seemingly for political reasons:
    24th October 2019: Minister Nick Gibb MP pre-selects some names that he wants to see on the panel. Its creation is prompted by Ofqual’s work on GCSE grading in MFL.
    25th October 2019: DfE officials email the Chair (whose name was pre-decided) saying that they have the go-ahead to proceed
    28th October 2019: The Chair replies and agrees to Chair the group
    Intervening Days: Panelists’ names are drawn up
    31st October 2019: A paper is submitted to Nick Gibb MP for him to formally sign-off creation of the panel
    4th November 2019: DfE emails panel members to sign them up and agree confidentiality of the work.
    5th November 2019: The Panel is publicly announced alongside Ofqual’s decision on grading.
    6th November 2019: Purdah period commenced, prior to the 2019 General Election.

    DfE was keen to time the announcement of the panel alongside Ofqual’s work on grading. This is expressed as a wish to “align comms” and explains why the DfE said “[they]’d like to move fairly quickly”. They note that the wording of comms and statements would depend on the purdah period and “grid slots” from Number 10.
  2. Ofsted and Ofqual were present in most meetings, despite not actually being on the panel. None of the subject associations were invited to comment, or invited to the meetings, as participants or observers. In this way, the Association for Language Learning was excluded, as was ISMLA, NALA, the UCML, LAGB, the Chartered Institute of Linguists, the British Council, and the British Academy. National cultural and linguistic associations present in the UK (Goethe Institute, Institut Français, Instituto Cervantes) were excluded, as were organisations representing lesser-taught languages (such as Confucius Institute or the Qatar Foundation International). Professional bodies such as the Chartered College of Teaching, NEU and ASCoL were excluded, too.
  3. It did not meet very often; 4 times as a full panel (Nov 2019, Dec 2019, Jan 2020, March 2020) and twice additionally as a seemingly ‘core’ group (Feb 2020). This was not curtailed by Covid-19. It was only ever intended to meet 6 times.
  4. The Chair noted the “relatively short timescale” and preferred a “smallish” panel of “6-8” people. My comment: this is a small group given the fundamental nature of the proposed changes.
  5. The Chair prefers to discuss the “balance of expertise as a whole” on the phone, not in writing. I wonder why…
  6. The Minister himself asked officials to approach 3 people to join the panel, along with the Chair: Emma Marsden (Director of NCELP), Katrin Kohl (Professor of German Literature) and John Bald, (former Ofsted inspector and blogger for Conservative Home, an “independent consultant”). This means that four of seven panelists were nominated by the Minister.
  7. It is written in black and white that DfE officials were drafting criteria for panel membership AFTER panelists had already been nominated / chosen by the Minister.
  8. The DfE has declined to disclose the rationale for the appointment of individual panel members, citing that to do so might
    – “discourage future broad and innovative policy development”
    – “significantly increase the risk that there will not be an in depth and open discussion at official and Ministerial level which would adversely affect good policy making”
    My comment: If broad and innovative policy development are such priorities, why did the panel have so few members and so few meetings?
  9. The Terms of Reference, not dated, detail criteria for panel membership. Only one criterion had to be met to qualify for the panel. Thousands of teachers would have qualified for this panel according to these criteria. One criterion stands out: “Independent advisor on MFL – who can bring a wider perspective of working with a range of schools and teachers”. It is not explained what “independent” means, but in the subsequently published panel list, John Bald is named as an “independent languages and literacy consultant”. He writes for the Conservative Home blog. The Terms of Reference confirm that panel membership be based on “recommendations” [i.e. not applications]. The Chair was invited to advise on panel members.
  10. DfE asserts confidence that the panel had “the necessary expertise and experience”, enabling the review to be “broad and balanced”, despite the fact that the panel only had 7 members, none of which were full-time classroom teachers.
  11. Attendance at meetings raises questions: In the Terms of Reference, it was stated that “[p]anel members must be able to make the commitment to attend these meetings”. But many panelists were not invited to two of the 6 panel meetings, suggesting the existence of a “core” panel comprising Ian Bauckham and Emma Marsden.
  12. As an aside, the Chair uses insider shorthand for DfE’s Headquarters, which is located in a premises called Sanctuary Buildings in central London. Mr Bauckham refers to this as “SB”.

The proposals

  1. DfE have been sitting on the proposals since 18 March 2020. A year later, on 10 March 2021, the proposals were published, precisely during the time in which teachers are grappling with how to assess work and award grades for the Summer 2021 GCSE/A-level cycle.
  2. It is confirmed that the panel did not consider grading standards or boundaries. In other words, this review has nothing to do with grading, severe grading or any other grading issue, and there is nothing to suggest grading will change.
  3. The outcome of the review was pre-determined before the review started, insofar as
    – the recommendation of topics was out of scope (and the proposals suggest that GCSEs no longer be topic-based)
    – all recommendations were required to be “compatible with the MFL pedagogy review” from 2016
    – a specific task for the Chair was to “assure that all recommendations by the panel about GCSE subject content are aligned to the MFL Pedagogy Review”
    This was also apparent in the emails from October 2019 shared between DfE Officials and the soon-to-be panel Chair, in which DfE officials state that the job of the Chair will be to “ensure that all recommendations from the group align with the your/the [sic] Teaching Schools Council MFL pedagogy review”. Note that the review panel and the Pedagogy Review were chaired by the same person.
  4. Prior to the review commencing, the DfE had already decided what it thought the problems with the existing GCSEs were: “some lower priority or extraneous content is taking pupil and teacher time away from the core study of vocabulary, grammar and phonics and other essential core knowledge” (although it does not elaborate on what this “other essential core knowledge” is)
  5. DfE set out very deliberately to “consider the direct and indirect impact of the subject content on teacher practice“. This is interesting as it appears to confirm teachers’ concerns that these proposals seem designed to influence how they go about their classroom practice
  6. Exam boards saw the draft proposals twice in 2020 – in March and November. They were formally submitted to Ofqual in December 2020.
  7. DfE appear to have an understanding of what “teaching hours” are usually allocated to MFL, as this was part of the overall consideration for the review. To my knowledge, the DfE has never published any guidance of or research on teaching hours for MFL.
  8. The DfE noted the Ofqual finding that low attainment in MFL may relate to “the extent to which content motivates students”. This is confirmed in the Terms of Reference. However, the subsequent proposals for actual content (words, phonics and grammar) do not clarify how the changes will ensure that content is indeed more motivating.
  9. The DfE was keen to identify where there are items in the current GCSEs which are “unreasonably [formatting sic] difficult”. It is not clear what the distinction is between ‘reasonably’ difficult and ‘unreasonably’ difficult.

If, like me, you think that MFL deserves better policymaking, better standards of transparency and above all a proper, expert-led, open review, then please write to your MP. Curriculum design is political, so our response has to be political, too. You should also sign this petition too, calling for a new panel and a new set of proposals.

2 thoughts on “How did the Department for Education come up with these proposals?

  1. Pingback: Write to your MP to express your concern about the proposals for the MFL GCSE – Transform MFL

  2. Pingback: Why the GCSE proposals are disproportionately grammar-heavy – Transform MFL

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