Response ID ANON-TEB1-7S8E-K

Submitted to Schools national funding formula

Submitted on 2016-03-12 20:59:59

Introduction
A Name
First name::
George
Last name::
Constantinides

B Email address
Email address:
g.constantinides@imperial.ac.uk

C Response type
Please select your role from the list below::
Governor
Please select your organisation type from the list below::
Maintained school
Organisation name::
Langham Primary School
Local authority area::
Essex

D Would you like your response to be confidential?

No
Please give your reason for confidentiality::

Principles for a reformed funding system

1 Do you agree with our proposed principles for the funding system?
Yes
Please provide any further comments::
1. A funding system that supports opportunity.
This principle states that "reliable and robust data about pupils characteristics should determine the resources their schools receive". It is important not only that
the data are reliable and robust, but that there is an evidence-based approach to using data that achieve the desired impact.
2. A funding system that is fair
This principle states that "funding should be determined by a single, national formula which uses objective and robust measures of pupil and school
characteristics". It is important to note that there are characteristics that are "local" but yet not those of a particular pupil or school including, but not limited to, the
different local costs of employment already noted in the consultation document.
3. A funding system that is efficient
This principle states that "Greater consistency of funding across the education sector would make it easier for head teachers, governing bodies, multi-academy
trusts and local authorities to compare their spending and outcomes with other schools and areas and identify ways in which they could improve." This is true only
if "outcomes" is defined in a way that provides for measurable quality of education. As such, this principle must be underpinned by serious consideration of the
assessment principles currently in operation. For primary schools, I have serious concerns about these (see
http://constantinides.net/2015/09/20/assessment-of-primary-school-children-in-england/).
4. A funding system that gets funding straight to schools
I do not see this as a principle. Schools will continue to need to pool funds for certain purposes.
5. A funding system that is transparent
Agreed
6. A funding system that is simple

A quote often attributed to Einstein is of relevance here: "Everything should be made as simple as possible, but not simpler."
7. A funding system that is predictable
Agreed

The structure of the funding system

2 Do you agree with our proposal to move to a school-level national funding formula in 2019-20, removing the requirement for local
authorities to set a local formula?
No
Please provide any further comments::
I think all the laudable aims of the policy can be achieved with a "soft national funding formula" as outlined in Paragraph 3.3, so I do not see the need for
hardening of this formula, which removes local discretion - which I believe should reside with Schools Forums.

Building block A: per-pupil costs

3 Do you agree that the basic amount of funding for each pupil should be different at primary, key stage 3 and key stage 4?
Yes
Please provide any further comments::
I believe there is a case for a different rate of funding for EYFS in primary (or infant) schools, currently lumped into KS1 funding rate.

Building block B: additional needs factors

4a Do you agree that we should include a deprivation factor?
Yes

4b Which measures for the deprivation factor do you support?

Pupil- and area-level
Please provide any further comments::
I agree with using the various factors available to us, e.g IDACI and FSM / Ever6 FSM, but we currently have a golden opportunity (which will disappear as a
result of the introduction of a national funding formula) to use a boundary discontinuity methodology to determine their weighting in a scientifically rigorous
manner. I believe the DfE should make use of this opportunity.

5 Do you agree we should include a low prior attainment factor?

Yes
Please provide any further comments::
The removal of the statutory EYFSP is likely to make primary school prior attainment funding extremely problematic. I do not believe that the baseline EYFS test
will provide meaningful data in this regard. I would urge a rethink of the baseline EYFS testing and - if that does not happen - a close monitoring of the correlation
between baseline EYFS scores and school-reported SEN Support rates. There is a danger that this factor will become meaningless and poorly distributed after
the end of statutory EYFSP results.
When evaluating the relationship between high needs and schools block funding, you should reconsider the requirement of schools to contribute the first 6k of
funding from their notional SEN budget. This requirement provides a perverse disincentive for schools - especially small schools - to accept children with high
levels of special educational needs.

6a Do you agree that we should include a factor for English as an additional language?
Yes
Please provide any further comments::

6b Do you agree that we should use the EAL3 indicator (pupils registered at any point during the previous 3 years as having English as an
additional language)?
No
Please provide any further comments::
There is a counter argument that EAL funding needs to be very significant but for a short period of time, e.g. EAL1 but at 3 times the rate. There is a risk that by
using EAL3, a small quantity of funding is "spread out" over too long to make a significant impact. I would be looking for appropriate evidence from the
educational research literature here before coming to a final decision.

Building block C: school costs

7 Do you agree that we should include a lump sum factor?
Yes
Please provide any further comments:
Lump Sum is absolutely essential for fair allocation of funding. Paragraph 2.38 of the consultation states
"We believe that a national funding formula should take account of costs that do not vary in direct proportion to pupil numbers"
I believe the term "take account of" is too weak, and I would strengthen this to a principle:
"We believe that a national funding formula should *fairly reflect* costs that do not vary in direct proportion to pupil numbers."
When I surveyed schools in Essex several years ago over their fixed costs, I estimated a total fixed costs in the region of 150k, so it comes as no surprise to me
that the modal LA choice of lump sum is in this region. It is essential that this value is maintained.
On methodology, I note that Paragraph 2.40 states "figure 5 shows there is no particularly strong relationship between the average size of school in local authority
area and the lump sum value". I would suggest that you consider correlation between standard deviation of school size and lump sum value instead. If all schools
in an area tend to be small or large, then lump sum value makes no difference to fairness - it is when they differ in size that it makes a significant impact.

8 Do you agree that we should include a sparsity factor?

No
Please provide any further comments::
If the lump sum adequately reflects the fixed costs of a school, and is not underfunded, then there is no clear reason to introduce a sparsity factor as a separate
element.

Building block C: other school costs

9 Do you agree that we should include a business rates factor?
Yes
Please provide any further comments::

10 Do you agree that we should include a split sites factor?

Yes
Please provide any further comments::

11 Do you agree that we should include a private finance initiative factor?

Yes
Please provide any further comments::

12 Do you agree that we should include an exceptional premises circumstances factor?

Yes
Please provide any further comments::

13 Do you agree that we should allocate funding to local authorities in 2017-18 and 2018-19 based on historic spend for these factors?
Yes/No - Business rates:
Yes
Yes/No - Split sites:
Yes
Yes/No - Private finance initiative:
Yes
Yes/No - Other exceptional circumstances:
Yes
Please provide any further comments::

Building block C: growth

14 Do you agree that we should include a growth factor?
Yes
Please provide any further comments::

15 Do you agree that we should allocate funding for growth to local authorities in 2017-18 and 2018-19 based on historic spend?
No
Please provide any further comments::
It would seem fairer to base this on GP registrations and existing pupil data trends, as there may be areas of the country where historical trends are unlikely to
continue.

Building block D: geographic costs

16a Do you agree that we should include an area cost adjustment?
Yes

16b Which methodology for the area cost adjustment do you support?
general labour market methodology
Please provide any further comments::
The general principle I would use is that the existing banding is too coarse and does not reflect significant variations across the "rest of England" band.

Factors not included in the formula

17 Do you agree that we should target support for looked-after children and those who have left care via adoption, special guardianship or
a care arrangements order through the pupil premium plus, rather than include a looked-after children factor in the national funding
formula?
Yes
Please provide any further comments::

18 Do you agree that we should not include a factor for mobility?

No
Please provide any further comments::
I have some sympathy for the concerns over mobility funding as it currently functions. However, I think there is a place for determining - once other factors such
as low prior attainment and FSM, etc. have been taken into account - the residual disadvantage through pupil mobility, which should be funded accordingly.
Again, an evidence-based approach should be used here.

19 Do you agree that we should remove the post-16 factor from 2017-18?
No
Please provide any further comments::
There has been a dramatic change in post-16 funding in recent years, and this factor is probably being used by LAs to smooth out this change which is causing
real difficulties for many excellent schools. I would therefore support LAs being allowed to maintain this factor in 2017-18.

Transition to the reformed funding system

20 Do you agree with our proposal to require local authorities to distribute all of their schools block allocation to schools from 2017-18?
No
Please provide any further comments::
I would instead suggest that Local Authorities are required to follow the instructions of their Schools Forums on this matter. Schools Forums, with elected
representatives from local schools, are ideally placed to determine the appropriate level of retention.

21 Do you believe that it would be helpful for local areas to have flexibility to set a local minimum funding guarantee?
Yes

Please provide any further comments::

Funding remaining with local authorities

22 Do you agree that we should fund local authorities' ongoing responsibilities as set out in the consultation according to a per-pupil
formula?
Yes
Please provide any further comments::

23 Do you agree that we should fund local authorities' ongoing historic commitments based on case-specific information to be collected
from local authorities?
Yes
Please provide any further comments::

The education services grant

24 Are there other duties funded from the education services grant that could be removed from the system?
Please provide your comments::

25 Do you agree with our proposal to allow local authorities to retain some of their maintained schools DSG centrally in agreement with
the maintained schools in the schools forum to fund the duties they carry out for maintained schools?
Yes
Please provide any further comments::
This is essential, especially for small schools.

Equality analysis
26 Please provide any comments on the equality analysis.
Please provide any further comments::