Governance for Initial Teacher Training (ITT)

Transcription

1 Governance for Initial Teacher Training (ITT) Guidance materials for school-based providers setting up or reviewing their governance arrangements E&OE (Errors & Omissions Excepted) First Edition Published: July 2018

2 Contents Acronyms 3 Introduction 4 1. Governance an overview Why do we need Governance? Which documents will help me understand what my Governance obligations are? What are the key elements to consider in Governance? How do I ensure Strategic Governance of my ITT provision is compliant? How do I ensure the operational Management of my ITT provision is compliant? How do I ensure my ITT programme is compliant with the wider legislation relevant to ITT? How does my Governance ensure effective Monitoring and Quality Assurance (QA)? How does my Governance ensure Strategic Direction and Improvement Planning? Roles and responsibilities What are the key roles and responsibilities within Strategic Governance? What does Operational Management in terms of Governance cover? Designing your Organogram 18 2

3 Acronyms GFA ITEIH PMAP QA SPFG ToR Grant Funding Agreement Initial teacher education inspection handbook The NCTL process for migration of accreditation Quality Assurance School Centred Initial Teacher Training (SCITT) Providers Financial Guide Terms of Reference Italics Words in italics are taken directly from the source document. 3

4 Introduction This guidance is designed to support school-based teacher training organisations develop and review their governance arrangements. There are a wide variety of SCITTs, Consortia, Multi- Academy Trusts, Teaching Schools and Partnerships that provide school-based ITT. Their different legal entities and history mean that this document cannot provide for each aspect of this individuality. It will, therefore, seek to provide general principles and exemplars from which providers can draw what is most applicable to their situation. This guidance will cover: Section 1 Governance an overview Section 2 Roles and responsibilities Section 3 Organograms 4

5 1. Governance an overview 1.1. Why do we need Governance? Governance is the way organisations are directed and controlled to ensure that they are effective in achieving their objectives. The Governing Body provide both support and challenge to the operational management to ensure accountability. Documentation needs to clearly set out the core relationships within the organisation and this ensures that the core principles of governance are met. The core principles of governance are: clarity of purpose; openness and transparency; integrity; accountability; effectiveness. Documents should describe the roles and responsibilities of each part of the organisation within the Terms of Reference (ToR) and role descriptions. In particular they should set out: the powers and responsibilities held by each part of the organisation; which of these powers have been delegated (there are some which cannot be delegated by the highest tier of the organisation); the distinction between strategic governance and operational management; the process through which decisions are made; the process by which the governance arrangements themselves are altered. The Terms of Reference (ToR) and organograms set out in Sections 2 and 3 of this document will support providers in identifying how clarity within governance arrangements can be achieved Which documents will help me understand what my Governance obligations are? The relevant sections that you will need to know in relation to your governance will be set out for you later in this guidance. The source documents are the five immediately below. The DfE publishes statutory guidance for ITT providers in two documents depending on the age range you are offering: a) Initial teacher training (ITT): criteria and supporting advice b) Early years initial teacher training (ITT): a guide for providers Ofsted provide guidance for inspection which includes governance within the Leadership and Management sections: c) Initial teacher education inspection handbook (ITEIH) The DfE provide guidance which assist providers in understanding their finance and governance, including the roles of specific parts of an organisation: 5

6 d) School Centred Initial Teacher Training (SCITT) Providers Financial Guide (SPFG) The document below relates to those providers who are already accredited but who are seeking migration to another legal entity, for example moving from a local authority to a MAT: e) NCTL process for migration of accreditation (PMAP) 1.3. What are the key elements to consider in Governance? In setting up or reviewing Governance, it is helpful to consider the following five key elements: 1. Strategic Compliance ensuring that your Governance arrangements themselves meet your statutory and legal obligations for ITT (see Section 1.4); 2. Operational Compliance ensuring that your operational management is meeting its statutory and legal obligations for ITT (see Section 1.5); 3. General Compliance ensuring that the obligations applicable to all organisations, e.g. Equality, Data Protection, GPDR, are being maintained by your provision (see Section 1.6); 4. Monitoring and Quality Assurance providing accountability for the effective work of the organisation (see Section 1.7); 5. Strategic Direction ensuring forward planning to meet the needs of the organisation and its core purposes (see Section 1.8) How do I ensure Strategic Governance of my ITT provision is compliant? Two documents detail the Strategic Governance structure of a provider. Which applies to your organisation depends on whether you are an existing provider or you are a new provider/one who is seeking migration. Even if you are an existing provider, it will be very useful for you to look at the best practice for new/migrating providers School Centred Initial Teacher Training (SCITT) Providers Financial Guide (SPFG) Organisational Structure: Section SPFG All new providers are required to put in place a sound organisational structure to ensure that the ITT grants paid by the NCTL are used for the purpose intended and in accordance with the Grant Funding Agreement. The structure should clearly define areas of responsibility to ensure proper segregation of duties and transparency in the way the provider manages its affairs. The provider should have a clearly defined organisational structure with identified lines of reporting for all areas of its operations. Conduct of Meetings: Section SPFG The Board and its committees should meet regularly enough to discharge their responsibilities under their GFA to ensure robust governance and effective financial management arrangements. Board meetings should take place regularly with decisionmaking only conducted when sufficient members are present [quorum]. 6

7 Delegation & Control: Section SPFG Whilst the Board cannot delegate overall responsibility for the provider's funds, it should approve a written scheme of delegation of financial powers that maintains robust internal control arrangements. Finance Committee: Section SPFG The provider should have a finance committee or equivalent to which the Board delegates financial scrutiny and oversight. The responsibilities of the Governing Body of the [Legal] Accredited entity/board and provider staff should be clearly defined and allocated so as to ensure proper segregation of duties in the way finance functions are managed and processed. Lines of Responsibility: Section SPFG There should be clearly defined lines of responsibilities between the Governing Body of the [Legal] Accredited entity/board and the provider, including in the areas of stewardship, designation of Accounting Officer, financial management and provision of information. Appointment of an Accounting Officer: Section1.6.1 SPFG A new ITT provider should designate a named individual as its Accounting Officer. The individual should be a fit and suitable person for the role. This should be the Principal, the Chief Executive or equivalent. The appointment of an Accounting Officer does not remove the responsibility of the Board, both individually and as a Board, for the proper conduct and financial operation of the provider The NCTL process for migration of accreditation (PMAP) sets out the following specific requirements: 2.1 Provide a diagram of the proposed strategic management structure, identifying key governance roles, including that of the Accounting Officer. Considerations The Accounting Officer and Governing Body must sit at top of the strategic management structure. Ensure that you identify the links between operational management (see 2.2) and strategic management structures. Have you shown the reporting lines between committees and the Governing Body? 2.2 Provide a diagram of the proposed operational structure, identifying all partners, committees, groups and individuals involved in the partnership. Considerations (See sections 2.1 and 2.2) Ensure that all partners, committees, groups and individuals with a role in the operational management of the provision are included. Ensure that you identify the links between operational and strategic management structures. 2.3 Provide details of proposed staffing, particularly where roles, responsibilities and personnel are changing. Considerations 7

8 Include details of all staff, including their roles and responsibilities, relevant prior experience and any relevant training they will undertake in advance of migration. Identify staff new to any post. Make sure that staff responsible for administration and finance are included. 6.5 Include a financial management organisation structure (organogram) that identifies lines of accountability, details responsibilities and demonstrates the segregation of duties. Considerations Provide a financial management organogram for the proposed provider, ensuring reporting lines are clearly defined. Include job descriptions and person specifications for all staff with financial responsibilities. 6.6 Designate an Accounting Officer who shall discharge the proposer s responsibilities in meeting its financial and governance obligations, and in continuing to comply with ITT requirements. Considerations Include full details of the proposed Accounting Officer of the provision; including name, job title, job description and person specification (including accountability for regularity, propriety and value for money) The Terms of Reference (ToRs) and Organograms set out later in this document will help you to ensure that your governance arrangements are secure and compliant. Note: It is worth noting the following requirement if your organisation is undergoing substantial structural change, particularly if the Legal Entity is altering: Providers must contact DfE to seek approval for any proposed significant changes to their governance and/or operational structure. This includes, for example, the loss or removal of a partner organisation, or a change in the accounting officer [or a change of legal entity which might, for instance, becoming part of a MAT]. If a provider is in any doubt as to whether they should advise DfE of any changes, they should do. If a provider makes significant changes to their governance and/or operational structures, DfE reserves the right to withdraw accreditation, and require the newly configured organisation to seek accreditation as a new provider How do I ensure the operational Management of my ITT provision is compliant? Two documents provide overview guidance in this area the ITT criteria and the ITE Inspection Handbook. For specific guidance on financial operations (e.g. internal controls, auditing, etc.) you should refer to Parts 2 and 3 of the SCITT Providers Financial Guide. ITT criteria: 3.1 relating to Management Structure All accredited ITT providers must ensure: that their management structure ensures the effective operation of the training programme. Schools should play a significant, and often leading, role in the design and delivery of training provision. 8

9 The management structure should demonstrate the central role that schools should play in all aspects of provision, from selection and recruitment, through delivery and training, to the assessment of trainees for the award of QTS. Providers must plan their training programme to ensure that they comply with the current ITT criteria and provide the opportunity for trainees to demonstrate they meet all the Teachers Standards. Training should be of high quality and providers should seek continuing improvement. ITE Inspection Handbook: Section 145 Sets out the key question that inspectors will ask a provider in this area: How well does the partnership meet current statutory initial teacher training criteria and requirements? This means that Governance must monitor compliance with the following sections of the ITT criteria: Section 1 - Entry criteria Section 2 - Training criteria Section 4 - Employment criteria You may find completion of the suggested NASBTT Compliance Audit and Self-Evaluation Document (SED) helps provide evidence that you are complying with this core function: ITT criteria 3.2 Partnerships All accredited ITT providers must ensure: that partners establish a partnership agreement setting out the roles and responsibilities of each partner. The partnership agreement should also include details of the: partnership s quality assurance procedures content and delivery of each of the ITT programmes policies for equality of opportunity organisation and management of the partnership As part of your Governance arrangements you should also make clear in your Partnership Agreements with schools how they relate to your structure How do I ensure my ITT programme is compliant with the wider legislation relevant to ITT? C3.3 of the ITT criteria states that: All accredited ITT providers must ensure: that they comply with all current legislation relevant to ITT. Section 145 of the ITEIH states that inspectors will judge how well the partnership complies with all relevant legislation. Governance processes should include a range of policies that are reviewed regularly by different committees to ensure compliance. It should be clear which policies have been delegated and which, such as financial budget setting, remain with the highest tier of Governance. The criteria gives examples of different areas where the Governance Body is accountable, for instance Data Protection to the Information Commissioner s Office. A comprehensive compliance list is given within the NASBTT Compliance Audit. 9

10 1.7. How does my Governance ensure effective Monitoring and Quality Assurance (QA)? C 3.4 of the ITT criteria covers QA and states: All accredited ITT providers must ensure: that they monitor, evaluate and moderate all aspects of provision rigorously and demonstrate how these contribute to securing improvements in the quality of training and the assessment of trainees Section 145 of the ITEIH states: The effectiveness of leadership and management is evaluated in terms of: quality provision and outcomes for trainees the rigour of the recruitment and selection process evidence of effective monitoring and evaluation A schedule of monitoring and reports that are reviewed and minuted on a regular basis will provide good evidence of quality assurance, especially where these are used as appendices within your SED. Governance arrangements should make clear who is responsible for different areas of QA. Particularly important areas within QA are the accuracy of assessment and consistency across the partnership. This is informed by two types of moderation: Internal Moderation - to ensure consistency across the partnership this should be linked to your organisation s Assessment Framework (e.g. the NASBTT Training and Assessment Toolkit if used or adapted by the partnership). It should also be linked to the different elements requiring evaluation within the SED. External Moderation - there is a requirement for an external moderator to be appointed (ITT criteria 3.4) without which a provider would not be compliant. They must be suitable, independent and be able to offer an external perspective on the attainment of other providers trainees being assessed for the award of QTS, which should help to verify the accuracy of the provider assessments. There are specific financial areas of monitoring and adherence that are within Part 2 and 3 of the SCITT Providers Financial Guide which should be built into the Terms of Reference (ToR) of committees as outlined later in this guidance How does my Governance ensure Strategic Direction and Improvement Planning? C3.4 of the ITT criteria states: All accredited ITT providers must ensure: that they monitor, evaluate and moderate all aspects of provision rigorously and demonstrate how these contribute to securing improvements in the quality of training and assessment of trainees. Section 145 of the ITEIH states: The effectiveness of leadership and management is evaluated in terms of: how relentlessly leaders and managers pursue a vision for excellence, focused on improving or sustaining high-quality provision and outcomes for trainees 10

11 how effectively schools, colleges and/or other settings are engaged in the ITE partnership, including those in challenging socio-economic circumstances and those judged as requires improvement demonstrable capacity to bring about further improvement.. Governance arrangements should set out who is responsible for evaluating the provider s performance (SED) and the setting of an Improvement Plan (IP) based on the arising priorities, local need and national priorities. The annual SED, annotated Improvement Plans and a three-year strategic plan will be prima facie evidence that strategic governance is taking place securely. Having provided an overview, the following sections will give you an understanding of different governance arrangements and how roles and responsibilities are established. 11

12 2. Roles and responsibilities This section of the guidance should help you to select the relevant roles and responsibilities of your various boards and committees to ensure Governance of your provision is compliant What are the key roles and responsibilities within Strategic Governance? The DfE provide guidance to assist providers in understanding their financial and governance responsibilities, including the roles of specific parties of the SCITT. Reference will be made to this publication throughout this section: School Centred Initial Teacher Training (SCITT) Providers Financial Guide (SPFG) The Strategic Governance will consist of the following parties: Legal Entity Accounting Officer Business Manager Strategic Board (could be Steering Committee/Partnership Committee/Executive Committee) Assessment Board (could be Examination Board) Appeals Committee You will need to consider the organogram that will best represent your organisation. An example of Strategic Governance is below: Legal Entity Board of Governors Accounting Officer Assessment Board QTS and Academic Award External Moderator Strategic Board Policy, Strategy, Aims Quality Assurance Finance 12 Finance Committee (including Business Manager) Appeals Committee Trainee appeals Trainee termination Complaint procedures

13 Legal Entity All providers must have a body which is named as their Legal Entity also known as the Accrediting Body which is monitored by the DfE (see Section 1.5). This is the highest level of Governance and may take the form of: a school s governing body; a Muti-Academy Trust; a Local Authority. Terms of Reference: Section SPFG Terms of Reference for the Governing Body of the Legal Entity/Accrediting Body would normally include: the approval of the annual budget including the delegation of the budget responsibilities to budget managers; the regular (at least termly) monitoring of actual income and expenditure against each budget and revised forecast for the year in the format agreed; reviewing reports by the Accounting Officer as to the effectiveness of the financial procedures and controls; responsibility for the implementation and management of an effective system of internal controls that are consistent with the requirements set; appointment of external auditors. Section SPFG Whilst the Board [Governing Body of the Legal Entity/Accrediting Body] cannot delegate overall responsibility for the provider's funds, it should approve a written scheme of delegation of financial powers that maintains robust internal control arrangements. All providers must appoint an Accounting Officer who is registered with the DfE. This appointment will automatically be: a school s governing body - headteacher of that school; a Muti-Academy Trust board - CEO of the trust; a Local Authority a nominated person from the Local Authority. The Accounting Officer Not only is the Accounting Officer responsible for financial matters but they are also accountable for Quality Assurance. Responsibilities could include ensuring: Financial: measures are in place to prevent losses or misuse; a fixed asset register is maintained; bank accounts, financial systems and financial records are operated in accordance with the DfE regulations; duties are properly segregated between nominated individuals; internal and external systems provide full audit trails; demonstrating value for money; overseeing areas that are delegated to the Business Manager. Quality Assurance: internal reports from various boards and committees are considered with the appropriate action being taken or delegated. External reports could include: o External Moderator reports;

14 o Ofsted reports; o Reports from HEI validating body (if offering PGCE). Business Manager The individual is appointed by the Legal Entity and should play both a technical and leadership role, including ensuring sound and appropriate financial governance and risk management arrangements are in place, preparing and monitoring budgets, and ensuring the delivery of annual accounts. Responsibilities could include: discharge of responsibilities under the GFA, and satisfying that all terms and conditions of the GFA are complied with; ensuring the efficient, economical and effective management and distribution of funds paid by the DfE, including capital assets, equipment and staff; maintenance of sound financial controls in respect of funds paid by the DfE; ensuring financial considerations are taken fully into account in reaching decisions on the management of the provider. The Legal Entity will appoint a board which can take various names, e.g. Strategic Board/Steering Committee/Partnership Steering Committee/Executive Committee. Composition of the Strategic Board could include: Accounting Officer Headteacher(s) or a nominated number of primary/secondary Headteachers Representatives from Governing Body/Trust Board/Local Authority SCITT Leader and Deputy Mentor representatives Tutor representatives Subject related partners Directors of Teaching School Alliances Headteachers of local delivery groups Representative from a Higher Education Institute (HEI) Student representatives Business Manager (Finance) NQT representatives Outside agency (e.g. local recruitment agency) You must determine the number of members to constitute a quorum and how often meetings will be held. Election of Chair and Vice-Chair The Board will specify procedures in relation to: election; resignation; term of office; voting rights; absence from meetings. Declaration of Interest Members should sign a declaration of interest document annually. The Strategic Board could have overall responsibility for: 14

15 Policy, Strategy and Aims: work of the partnership meets the requirements of any regulations covering the structure and development of ITT (currently Teachers Standards for Qualified Teacher Status, ITT criteria, Ofsted framework and the requirements of the Office of the Independent Adjudicator); impact of legislative and Government/local policy changes; determining the aims/objective/strategic direction of the partnership; improving high quality provision to maximise outcomes for all trainees; approving new partnerships and procedures for the deselection of schools; premises requirements; appointing and deploying human resources effectively; approving professional development programmes to meet aims and objectives; appointing a safeguarding officer; approving the Partnership Agreement; ensuring interview procedure is fit for purpose and meets the ITT criteria; reviewing policies pertaining to wider legislation relevant to ITT and the ITT criteria (refer to NASBTT Compliance Audit). Finance: proper stewardship of funds paid by the DfE and Student Loans Company; formally adopting the annual budget and scrutinising the report from the official auditors; reviewing actual income and expenditure against each budget heading and revising the forecast for the year ensuring best value for money; reviewing financial reports as to the effectiveness of financial procedures and controls; setting staff pay and conditions; reviewing the risk register. Quality Assurance: reviewing the Quality Assurance mechanisms of the partnership; quality assuring academic standards with various validating bodies; reviewing minutes of board/committee meetings; examining data and evaluations feeding into the SED and identifying priorities for the next academic year; regularly reviewing the Improvement Plan to ascertain progress towards priorities; approving the appointment of internal and external moderators; appointing an Assessment Board/Examination Board; appointing an Appeals Committee when appropriate; overseeing trainee termination in accordance with written procedures; establishing such committees as it deems necessary for the partnership to function. Other areas for consideration: minute taking; areas that cannot be delegated to other boards/committees; policies delegated to other boards/committees. Composition of the Assessment Board/Examination Board could be: Accounting Officer Programme Leader Mentor representatives Programme moderators 15

16 Programme tutors External moderator You must determine the number of members to constitute a quorum and how often meetings will be held. Conflict of Interest You must detail arrangements for if a conflict of interest arises. The remit of the Assessment Board/Examination Board could include the following: assessing progress made by trainees towards meeting the Teachers Standards; determining action to be taken when a trainee is not making the necessary progress; making recommendations for the award of Qualified Teacher Status and reporting outcomes to the validating body to grant the relevant academic award; actioning such matters as directed by the Strategic Board/Steering Committee/Partnership Steering Committee/Executive Committee; evaluating the consistency and development of academic and assessment processes; reviewing Quality Assurance mechanisms to inform self-evaluation and the Improvement Plan; reporting improvements/changes to Strategic Board/Steering Committee/Partnership Steering Committee. Composition of the Appeals (and Complaints) Committee could be: a member of the Strategic Board a member of the Management/Operations Board a member of the Mentor Group members of a group who have not been involved in previous decisions. The remit of the Appeals Committee could be to: follow the guidelines as detailed in the appeals and disciplinary policy; be aware of the process available to trainees under the Office of the Independent Adjudicator What does Operational Management in terms of Governance cover? 16

17 Staff Group Mentors, Tutors Partnership Board Operational co-ordination, strategy implementation and development Management and planning Trainee Group Operational Committee For example: Curriculum committee Programme planning, structure, content, delivery Other committees can be added to this organogram. This involves a board or committee who will be responsible for the delivery of the programme and who reports to the Strategic Board. You must determine the number of members to constitute a quorum and how often meetings will be held. Composition of the Partnership Board/Steering Group/Operations Board could be: Headteachers of partnership schools Mentor representatives Programme leads Programme tutors Programme moderators Trainee representative(s) You must determine the number of members to constitute a quorum and how often meetings will be held. The remit of the Partnership Board/Steering Group/Operations Board could be to: determine the nature and scope of the partnership. This could include: programme planning, structure, content and delivery; deployment and development of staff; being compliant with the ITT criteria (Sections 1 and 2). review and action reports from all programme personnel and committees; review the Improvement Plan; review statistical information to benchmark against other providers; report to the Strategic Board on issues relating to management and Quality Assurance; action any directives from the Strategic Board. The Strategic Board may recommend further committees be appointed to support the Partnership Board/Steering Group/Operations Board, e.g. curriculum committee, resources committee.

18 3. Designing your Organogram When designing your organogram consider the levels of Governance as detailed in this guidance. Remember to include reporting lines within your organogram.

19 Example organogram Legal Entity Board of Governors Strategic Accounting Officer Assessment Board QTS and Academic Award External Moderator Strategic Board Policy, Strategy, Aims Quality Assurance Finance Finance Committee (including Business Manager) Appeals Committee Trainee appeals Trainee termination Complaint procedures Operational Staff Group Mentors, Tutors Partnership Board Operational co-ordination, strategy implementation and development Management & planning Trainee Group Operational Committee For example: Curriculum Committee Programme planning, structure, content, delivery Other committees can be added to this organogram.

20 Reporting lines to the Partnership Board Curriculum and Trainee Related Matters Committee Partnership Board Personel Committee Programme Director Programme Administrators Mentors Programme Tutors Trainees Job Descriptions will need to be written for each of the personnel named in your organogram. Responsibilities of the Accounting Officer: Section 1.6 SPFG The role of Accounting Officer includes specific responsibilities for financial matters. Accounting Officers should be able to assure high standards of probity in the management of public funds, particularly: Regularity dealing with all items of income and expenditure in accordance with legislation, the terms of the provider's GFA and compliance with the provider's internal procedures. This includes spending public money for the purposes intended by Parliament; Propriety the requirement that expenditure and receipts should be dealt with in accordance with Parliament s intentions and the principles of parliamentary control. This covers standards of conduct, behaviour and corporate governance; Value for money this is about achieving the best possible educational and wider societal outcomes, within the provider's objects, through the economic, efficient and effective use of resources, the avoidance of waste and extravagance, and prudent and economical administration. A key objective is to achieve value for money not only for the provider but for taxpayers generally. Responsibilities of the Accounting Officer: Section SPFG Whilst the provider s Accounting Officer is accountable for the provider s financial affairs, for keeping proper financial records, and for the management of opportunities and risks, the 'delivery' of the provider's detailed accounting processes could be delegated to a Chief Financial Officer or equivalent [e.g. Business Manager].