DRAFT NATIONAL PROFESSIONAL STANDARDS FOR TEACHERS. Teachers Registration Board of South Australia. Submission

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1 DRAFT NATIONAL PROFESSIONAL STANDARDS FOR TEACHERS Teachers Registration Board of South Australia Submission 21 May 2010

2 Table of Contents 1. EXECUTIVE SUMMARY 1 2. TEACHERS REGISTRATION BOARD OF SOUTH AUSTRALIA ROLE OF THE BOARD EXISTING PROFESSIONAL TEACHING STANDARDS FOR REGISTRATION 3 3. CONSULTATION PROCESS 4 4. STRUCTURE OF THE KEY QUESTIONS AND THE CONSULTATION PAPER QUESTION ONE Introduction Purpose Organisation Domains of Teaching Standards Descriptors Levels of Professional Capability QUESTION The use of the continuum Progression of teachers' proficiency Developmental progression of the Descriptors The range of teachers' work Inclusion of contemporary theory, curricula and practice QUESTION The Descriptors in the Graduate level The Descriptors in the Proficient level QUESTION FOUR The link with other educational initiatives 13 ii

3 4.4.2 Number of Descriptors Role of parents and the community in learning QUESTION Impact of the Graduate and Proficient levels on existing standards Transition from Graduate to Proficient Assessment and determination of professional capability QUESTION Consideration of submissions and reporting of outcomes Nomenclature Further issues raised by stakeholders 16 iii

4 1. Executive Summary The Teachers Registration Board of South Australia is committed to the development of common criteria and processes for nationally consistent registration. This includes the accreditation of pre-service teacher education programs (led by the Australian Institute for Teaching and School Leadership (AITSL) in collaboration with teacher regulatory authorities) and the assessment of provisionally registered teachers against a set of standards to change status from provisional registration to registration (full). The development of a set of National Professional Standards for Teachers is an important opportunity to define and recognise the complex work of teachers and achieve (with other current national initiatives) national consistency in teacher registration. For this reason, the submission is focused on the Levels of Professional Capability of Graduate and Proficient. Although committed to a set of National Professional Standards for Teachers, after consultation with key stakeholders, the Board is of the view the Draft Standards in their current format require more work if they are to be successfully implemented for teacher registration purposes. Specific concerns raised relate to the following: 1. The intent, purpose and intended use of the Draft Standards is unclear. This makes it difficult to contextualise how, when and by whom they might be used and whether there would be any reporting requirements. 2. There is limited reference to the profession, education or teachers as professionals. Recognition of the status of teachers, the importance of their role and the changing and evolving nature of their work need to be emphasized. 3. The research and/or knowledge about successful teacher practice upon which it is stated the Draft Standards are grounded, need to be clearly articulated. 4. The Draft Standards do not appear to recognise and/or reflect: o the Melbourne Declaration on Educational Goals for Young Australians (December 2008) o their relationship with any other national initiatives (eg: curriculum, professional learning, registration, National Quality Framework for Early Childhood Education and Care etc) o contemporary practice or educational contexts o the complexity of teachers work o the range of teachers roles o early childhood education development o the importance of parent, family and community partnerships o the effect of changing contexts on teacher proficiency 1

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6 2. Teachers Registration Board of South Australia 2.1. Role of the Board The Teachers Registration Board of South Australia ( The Board ) is established under the Teachers Registration and Standards Act 2004 to regulate the teaching profession. The object of the Act is to establish and maintain a teacher registration system and professional standards for teachers to safeguard the public interest in there being a teaching profession whose members are competent educators and fit and proper persons to have the care of children. The Board has a number of functions. Those that relate directly to the purpose of this submission are: a) to promote the teaching profession and professional standards for teachers; b) to confer and collaborate with teacher education institutions with respect to the appropriateness for registration purposes of teacher education courses; c) to confer and collaborate with teacher employers, the teaching profession, teacher unions or other organizations and other bodies and persons with respect to requirements for teacher registration and professional and other standards for teachers; d) to confer and collaborate with other teacher regulatory authorities to ensure effective national exchange of information and promote uniformity and consistency in the regulation of the teaching profession within Australia and New Zealand; e) To keep the teaching profession, professional standards for teachers and other measures for the regulation of the profession under review and to introduce change or provide advice to the Minister as appropriate. 2.2 Existing Professional Teaching Standards for Registration Following the proclamation of the Teachers Registration and Standards Act 2004 and after extensive consultation with the profession and stakeholder groups, the Professional Teaching Standards for Registration in South Australia were developed. The Professional Teaching Standards were implemented by the Board in The standards are used for the purposes of Entry to the Register and Change of Registration status from Provisional Registration to Registration. The standards are a critical component of the process of approving pre-service teacher education programs for registration purposes. Graduates applying for Entry to the Register will have met the standards on completion of an approved program. Teachers applying for a change of registration status from provisional registration 3

7 to registration address the nine standards as a part of the teaching evaluation process. 3. Consultation Process This submission was developed following 14 consultation sessions held in both metropolitan and country locations with key stakeholder groups including: provisionally registered and registered teachers (including those teachers who have recently changed their status and beginning teachers) employing bodies pre-service teacher education providers and students parent associations education unions Individuals attending consultations led by the Teachers Registration Board were asked to provide feedback on the Draft Standards for Teachers using the six consultation questions provided with the document. The consultations undertaken focused predominantly on the Graduate and Proficient Levels of Professional Capability because of the Board s current use of South Australian professional standards in the registration process at entry to the Register and change of status. 4. Structure of the Key Questions and the Consultation Paper Stakeholders were critical of the six key questions provided for consultation as they were perceived to be narrow in focus and poorly constructed. Each question was closed requiring only yes or no responses. The questions also appeared to be based on the presumption that those choosing to respond: a) agreed with this set of proposed Draft Standards for Teachers and the contents of the document and; b) need only to provide comment on the structure of the document and the text. Stakeholders expressed difficulty in providing considered responses to questions and the validity and reliability of the Draft Standards given that no specifications were provided as to: the purpose of the standards and how and when they would be used; the scope, structure and delivery of support materials that would be provided. The questions did not invite wider discussion about the conceptual basis for establishing a set of National Professional Standards for Teachers. Despite this, at each consultation session undertaken, stakeholders initiated debate about the rationale for National Standards. 4

8 It was noted that the Consultation Paper did not include an explanation of: the rationale for the consultation; how the consultation process would be validated; how submissions would be considered and by whom; how those providing submissions would be informed about the findings, proposed actions and/or recommendations resulting from the consultation. While the Consultation Paper included a contents page, the document would have been easier to navigate if pages had been numbered to correspond with the numbers indicated on the contents page. The Consultation Paper as a whole was too wordy. There was inconsistency in the way language was used throughout the document and the inclusion of technical terminology may have restricted its accessibility to stakeholders. The use of some terms was exclusive (e.g.: 'students' does not recognise Early Childhood Education and could have been replaced with the more inclusive term of learners. 'Parent' does not reflect the wide range of familial contexts). 4.1 Question One Does the Preamble to the Standards give a clear picture of the context for the reason, use and purpose of the Standards? The responses to question one are recorded under the headings of the Preamble. The Draft Standards document does not clearly establish the intent, purpose and rationale for establishing National Professional Standards for Teachers or the Draft Standards as presented. In the absence of this information, stakeholders constructed their own frames of reference which during the consultation process led to inconsistent interpretations of the document as a whole. The terminology in the Preamble and throughout the document leaves the reader with the distinct impression that these Draft Standards apply only to teachers working in a classroom located in a school. Indeed the very first sentence of the document begins with The most important school-based factor.... This is an extremely narrow definition of where and how learning programs are provided by teachers in the 21st century. The Preamble fails to recognise that teachers are employed to provide learning programs from birth to the conclusion of secondary schooling. Teachers do not always undertake this work in a classroom. A significant number of teachers provide important support to learners through alternate programs. Are these Draft Standards meant to reflect the work of all teachers or just some? 5

9 The Preamble is silent on specifics of the practical application of the standards. There is no explanation in the document about how, when or why standards would be measured, by whom and for whom. It is not clear whether it is intended that teachers move through the levels and if so how, when and for what purpose? How the Draft Standards would be interpreted at the local level is not clear. The Preamble needs to be clear about the purpose of the Draft Standards. There is no rationale presented for having teacher standards in the current context. The reader is not able to gain a clear picture of the intentions behind the standards, the purpose for the standards and how standards will be used. The 'devil is in the detail' and it is unfortunate that this was missing from the document Introduction It is not made clear in the introduction how the standards are connected to improving teacher quality. Professional learning is mentioned but no clear explanation of the relationship intended between the standards and professional learning is provided. A statement is made that the Draft Standards align with the Melbourne Declaration on Educational Goals for Young Australians but no further evidence is given about the correlation between the two documents. Concern was expressed by stakeholders that partnerships in learning which are included in the Melbourne Declaration (for example with parents and families) are not reflected in the Draft Standards. The introduction does not make clear the nature and extent of the extensive consultation with the profession that was undertaken in the formulation of these Draft Standards. Similarly it is not clear the nature and extent of consultation with the profession in the development of the Charter for the Australian Teaching Profession or when the charter was ratified and by whom Purpose The Purpose makes no quality statement about the profession, education or teachers as professionals. The Preamble is silent about the role of teachers in society; the status of teachers; the importance of the role or the changing and evolving nature of the role of teachers. Stakeholders expressed the view that the purpose presents a staged and artificially compartmentalised theory of teaching which is not a true reflection of teachers work or practice or of the profession. The discreet Levels of Professional Capability are presented in a linear and simplistic model, which does not mirror the complexity of teaching and the profession. 6

10 The Purpose states; the standards describe what is required of teachers at four levels. and support the collective responsibility of the profession to ensure that those who teach have the essential knowledge and skills. It is not clear what is intended by this statement, what the collective responsibility means or how it is intended this statement will be put into practice. The Purpose also refers to essential knowledge and skills, inconsistent with the Introduction which refers to knowledge, skills and dispositions. The reader is assured that the Draft Standards are grounded in research and knowledge of successful practice but no rationale is given for the Draft Standards being based on research nor which research and successful practice was used as its basis. Stakeholders hoped that these Draft Standards had been informed by a wide range of contemporary research and existing professional standards however, there is no reference to research undertaken or literature reviewed. The Draft Standards are referred to as a new national set of standards raising the question what were the previous set of national standards, for what purpose they were used and what is the significance of developing a new set of national standards? The paragraph is unclear about the connection to or use for other existing professional teaching standards. Paragraph four of the Purpose refers to a common language for professional dialogue between a number of people and groups. This paragraph makes no reference to parents and families or to teacher education providers who are critical education partners. Paragraph five is unclear about how the standards would be used for teacher registration, performance appraisal or professional accreditation at different levels of expertise. There is no explanation about what a nationally recognised and portable certification is or how the standards would apply in this regard Organisation There is no rationale given for the domains into which the Draft Standards are placed or why the particular domains were chosen as distinct from any others. It is stated the standards within the domains identify the main components of what teachers know and can do. Concern was expressed by stakeholders that teaching is complex and should not be reduced to these two components. The description of components is inconsistent within the document. The introduction refers to; knowledge, skills and dispositions and the purpose refers to; essential knowledge and skills. 7

11 Table 1 was seen to be a useful way of providing information at a glance. Again there are inconsistencies; Table 1 refers to levels of proficiency and the accompanying text refers to levels of professional capability whilst the Purpose Statement refers to levels of expertise Domains of Teaching Concern was expressed by stakeholders that the language used in this section of the Preamble does not appear to reflect the complexity of teaching. The statement teaching activity draws on aspects of all three domains places emphasis on teaching activity which is a simplistic representation of the professional teacher and the complexity of teaching. In the Professional Knowledge section, the explanation of knowledge is presented as passive with little emphasis on understanding or the application or creation of knowledge. Subject/discipline knowledge is prominent in the explanation which would appear to be built on the presumption that knowledge is all about subject content. Concern was expressed that the construction of knowledge presented is not inclusive of, for example, early childhood education. The definition of Professional Practice places emphasis on the cycle of planning, teaching, assessing and reporting and is silent on the place of relationships in practice. Concern was expressed the Professional Engagement section places emphasis only on knowledge and practice Standards The explanation provided does not make clear the reason for particular standards or how teachers would demonstrate the standards. Professional Standards must reflect contemporary theory and best practice. Stakeholders expressed the view that these Draft Standards are not reflective of the complexity of teachers work, the range of learning contexts or the very best of the teaching journey Descriptors It is stated the descriptors provide a continuum of professional expertise throughout the teachers careers. Stakeholders consistently emphasised that, in reality, a teaching career does not follow a continuum in the linear, staged way presented. Concern was expressed that there seems to be a forced differentiation between the descriptors; they are very similar in some instances and distinctions appear superficial. 8

12 Questions were raised about the purpose of the descriptors and the rationale underpinning them. The definition of the descriptors as the identifiable components of the standards implies that the Standards must have defined descriptors. It is not made clear how descriptors would be used Levels of Professional Capability Stakeholders raised many questions about the Levels of Professional Capability. The Preamble does not provide a rationale for establishing four levels of proficiency (why not five or six or three?) or explain the levels with clarity. The labels given to the four levels are not defined adequately creating confusion about at which point in a teachers career they apply. A statement is made about the powerful incentives that professional recognition and accreditation can provide but the intent of this section is confusing. It is suggested that teachers can use standards to plan and evaluate their professional learning and practice but then it goes on to say that teachers must achieve accreditation at some levels and may achieve accreditation at others. These intents are incongruous and present a dichotomy between using the Draft Standards as a supportive professional tool and as a means to formally evaluate performance. The lack of information about the use of the standards in either the Preamble or the body of the document raised serious questions about their intended purpose. It is not surprising that if the Draft Standards are intended to evaluate teacher performance, stakeholders questioned what information would be reported, by whom and where. Concern was expressed about information being made available on the myschool website and the potential for information to be misused. Is there the potential for the website to report the number of teachers at each level in each site? Stakeholders agreed that teachers need to be publicly accountable and able to clearly articulate their work and indicated that the Preamble and Draft Standards would not adequately support the profession in achieving either of these outcomes Question 2 Do the Draft Standards describe a realistic and developmental professional standards continuum? 9

13 Stakeholders expressed the view that the Draft Standards do not describe a realistic and developmental professional standards continuum. The reasons given for this view are: the use of the continuum is inappropriate there is an assumption that teachers' development is linear and can be matched consistently against one Level of Professional Capability the language of the Descriptors does not reflect developmental progression as it moves from Graduate through to Lead that they do not appear to reflect; o the range of teachers roles o early childhood education development o current educational research, theory, curricula and practice o changes in contexts for teachers and learning environments The use of the continuum Stakeholders commented that the Draft Standards are not a breakdown/continuum for professional standards, rather they are an over simplified Bloom s Taxonomy. The use of the continuum in this format forces the Draft Standards to be linear and arbitrary Progression of teachers' proficiency The construction of the Descriptors implies that the progression of teachers skills and practice is linear and will match consistently against one Level of Professional Capability. Stakeholders affirmed that a teachers proficiency would most likely match Descriptors across the range of levels. If one of the purposes of the Draft Standards is to determine a classification, this would prove to be difficult. Another consideration is that the formal assessment of teachers skills and knowledge will only ever represent a point in time. A teachers proficiency is influenced by a number of factors including the complexity of the learner profile in their site and the quality of support and professional development that is available to them. The Draft Standards are silent on this significant causal relationship Developmental progression of the Descriptors Stakeholders expressed the view that any descriptors should have the capacity to be applicable to every member of the profession. The Descriptors in the Draft Standards do not reflect the complexity of teachers' work or their actual proficiency at each of the Levels of Professional Capability. Some stakeholders described the Descriptors in the rubric as 'reductionist', 'biased' and 'monoculturistic'. 10

14 The developmental progression of the rubric does not reflect the growth of essential teacher knowledge. For example, it separates learning and assessment whereas learning and assessment are, in practice, integrated. Assessment appears to be treated as a post script after you do the learning (Biggs, J circa (1993) on Constructive Alignment). The rubric ignores the types of teacher knowledge that include: content knowledge pedagogical knowledge knowledge of learners and their characteristics knowledge of how people learn knowledge of the purposes of learning knowledge of social imperatives. The Descriptors across the four Levels of Professional Capability do not show a logical progression or developmental sequence. Some stakeholders viewed the Descriptors as hair splitting with a focus on minuscule changes at each level rather than the realistic reflection of teacher capability as it progresses from career commencement to the attainment of wider experience and the ability to deal with more complex pedagogical issues. The Draft Standards do not appear to develop the 'thinking teacher' but rather describe a technicians framework. The Descriptors have not captured the character, qualities, personal attributes and relational/social skills of teachers nor do they adequately distinguish what makes an outstanding teacher The range of teachers' work Education is focused on the provision of integrated education and care services from birth to completion of secondary schooling for learners with a diverse range of backgrounds and needs. Teachers provide learning programs in settings outside of the traditional classroom and are often employed in advisory roles to support quality teaching and learning. Stakeholders perceived that the Draft Standards do not adequately reflect the complexity of teachers work and the variety of contexts in which they operate. The practices outlined in the descriptors are not inclusive of quality practices in Early Childhood Education nor does the document recognise teachers who are employed in Early Childhood Services. Similarly the Descriptors are not inclusive of the skills and knowledge teachers are required to demonstrate in meeting the range of particular needs and abilities of learners (eg: special education). 11

15 4.2.5 Inclusion of contemporary theory, curricula and practice Stakeholders expressed the view that the Descriptors reflect outdated practice and seem to be based upon a fill them, show them, test them mentality. This does not reflect research, or contemporary thinking about teaching or the profession. It was not understood why specific curriculum areas such as Australian History and ICT were included in the Draft Standards as they are not Standards for teachers. Stakeholders were critical that the Draft Standards made continuous reference to including indigenous students. This was considered by stakeholders not to be reflective of the diversity of cultural backgrounds/communities that exist in Australia or the existing inclusive practices of teachers. 4.3 Question 3 Do the Draft Standards reflect what you would expect teachers to know and be able to do for each of the four levels (graduate/proficient/ highly accomplished and lead teachers)? Stakeholders expressed the view that the continuum of Descriptors across the Graduate, Proficient, Highly Accomplished and Lead Levels of Professional Capability do not reflect the complexity of the teaching profession, teachers work or what teachers know at each of the four levels. The Draft Standards as presented describe teachers in the classroom. They generally capture some of their work but there is a lot missing which results in a simplistic representation of a highly complex profession. Stakeholders felt that the Descriptors at Graduate and Proficient levels do not accurately portray the level of proficiency teachers attain at the commencement and in the early stages of their career The Descriptors in the Graduate level The Draft Standards define Graduate teachers as having approved qualifications and meeting all requirements for employment as provisionally registered teachers. Concerns were raised that the Levels of Professional Capability presented in the Draft Standards did not appear to acknowledge or value the wealth of experience people bring to the teaching profession. It was noted the structure appears to be based on the presumption that everyone begins at the same place and is part of an homogenous group. In reality Graduate teachers may have years of previous experience in a diverse range of occupations/professions. 12

16 Stakeholders commented that the Descriptors for the Graduate Level of Professional Capability were inconsistent and set low expectations for the newest members of the profession. The Teachers Registration Board, employing bodies and parents expect a beginning teacher to demonstrate practice that equates to the level of Proficient as a minimum. Teachers in their first appointment need to clearly articulate their philosophy and beliefs and apply their knowledge of contemporary practice and current research in their teaching. Some beginning teachers may demonstrate levels of Professional Capability across a range of Standards. Within the Descriptors at the Graduate level the focus is on knowledge but there is little about attempting to apply this knowledge. In the practice of the profession knowing is knowing and doing is doing. For example Descriptor 2.6 states that a beginning teacher should know and understand a range of assessment strategies. Does this imply that they are not required to undertake any assessment of learning until they meet Proficient requirements? The Descriptors in the Proficient level The Draft Standards state that Proficient teachers demonstrate professional knowledge, successful teaching practice and effective engagement with the profession. While stakeholders expressed no concern about this definition, concern was expressed about the need for all teachers to be proficient from their first teaching appointment. For our stakeholders Proficient denoted the starting point in a teachers career. The Descriptors in the Proficient Level of Professional Capability do not reflect more experienced teachers who are continually developing their skills and expertise but are not yet Highly Accomplished. 4.4 Question Four Are there other descriptors the Draft Standards should include? The stated purpose of any Standard should determine the scope and the construction of its descriptors. Stakeholders expressed the view that these Draft Standards seemed to have been established in the absence of this information. For this reason it was difficult to gauge if additional Descriptors would be appropriate, useful or whether required at all The link with other educational initiatives 13

17 Stakeholders were uncertain about the relationship (if any) between the Draft Standards and other standards such as leader or early childhood standards. The number of initiatives occurring at a national level foreshadows considerable changes to how, when and by whom learning programs are provided. It was noted that the Draft Standards do not appear to recognise or reflect these other influences Number of Descriptors Concern was expressed by stakeholders about the large number of Descriptors and the repetition of content within them. In the absence of information about how the descriptors where to be used, concern was raised as to whether the descriptors would be used as a checklist Role of parents and the community in learning The partnerships between parents/caregivers, families and educators should be recognised as an important component of education. This partnership supports the development of quality education programs and students and children s learning and wellbeing. This collective responsibility is reflected in the Melbourne Declaration on Educational Goals for Young Australians (December 2008). Feedback from stakeholders indicated that the Draft Standards appear to convey parents/caregivers, and families as passive participants in their child s education. Stakeholders felt most strongly that the Draft Standards should reflect the development and maintenance of positive relationships and effective and active partnerships between parents/caregivers, families particularly in: o understanding the familial, social, cultural backgrounds and developmental characteristics of children and students o planning and implementing learning programs o assessing and reporting on learning o engaging in professional learning and reflection o contributing to the school/preschool and professional community. 4.5 Question 5 Will it be possible for educators to use the Standards to evaluate teacher practice? The construction of Question Five implies that only educators would be conducting evaluations. A definition of educator was not provided to contextualise this question. Are Teacher Registration Authorities considered to be educators? What is the role of parents/caregivers, and families in supplying evidence as part of this evaluation process? 14

18 Question Five is predicated on the assumption that the Graduate and Proficient Levels of Professional Capability will be used by Regulatory Authorities in all states and territories to: accredit pre-service teacher education programs and; assess teacher proficiency in the transition from provisional registration to registration. Stakeholders expressed significant reservation about the usefulness of the Draft Standards to evaluate teacher practice Impact of the Graduate and Proficient levels on existing standards The Draft Standards and the Descriptors focus on knowledge and skills and do not adequately address other aspects of teaching e.g. relationships, behavior management, research and professional learning. In the absence of a purpose for the Standards it is not clear whether the Proficient Level would be used, in the registration context, for entry to the Register, change of status from provisional to registration and/or for renewal of registration. Stakeholders expressed the view that the Descriptors in the Graduate Level of Professional Capability do not reflect the knowledge, skills and dispositions of graduating teachers Transition from Graduate to Proficient The Draft Standards give no indication about how long a teacher can or should maintain their classification at any Level of Professional Capability. Stakeholders have commented that this may be a disincentive for teachers Assessment and determination of professional capability If determination of a level of capability is via an assessment process, a number of issues were raised including: who determines the classification of a teacher including their level of capability? the degree to which a teacher must meet descriptors in a level in order to be classified at that level (ie: are they required to meet 75% of the descriptors or 100%?) who initiates the assessment? how will the assessment be conducted? what will be assessed? 15

19 the relationship between teacher performance management processes and evaluation under the Standards who is authorised to complete the assessment?. what resources will be available to support each assessment process (ie: release time)? will there be a requirement to formally report teacher classifications at a state or national level? Stakeholders perceived that the Descriptors may be open to a wide range of interpretation which would affect the reliability, validity, credibility and acceptance of any assessment and classification process under these Draft Standards. 4.6 Question 6 Additional Comments Consideration of submissions and reporting of outcomes Information relating to the consultation process on the MCEECDYA website indicates that submissions received will be considered by an expert working group. No further information is provided about: how the 'consideration' process will be actioned whether the submissions/feedback received will be acknowledged how the feedback will inform future iterations of the Draft Standards if the findings of the expert working group will be reported Nomenclature The titles given to the four Levels of Professional Capability were raised in a number of stakeholder forums. It was noted that Graduate is a noun, Proficient and Highly Accomplished are adjectives and Lead is a verb. There should be consistency within the nomenclature. Stakeholders felt that the use of the term Graduate could lead to the interpretation that all teachers at this classification have recently exited a preservice teacher education program. Stakeholders also expressed the view that Proficient infers that some teachers would be teaching without being proficient Further issues raised by stakeholders Following is a list of issues raised by stakeholders that fell outside of the six consultation questions. 16

20 Will the Draft Standards lead directly to an improvement in education? is there an implication that teachers will be streamed and judgments made about them on this basis? what are the implications for teachers who do not achieve the standards? is this demand for National Standards coming from overseas initiatives and are they connected to league tables? what additional resources will be provided should the Draft Standards be implemented? 17

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