Consultation on the Curriculum and Assessment (Wales) Bill
Evidence submitted to the Children, Young People and Education Committee for Stage 1 scrutiny of the Curriculum and Assessment (Wales) Bill.
Organisation: National Advisory Panel for Religious Education Wales (NAPfRE)
1. The Bill’s general principles
1.1 Do you support the principles of the Curriculum and Assessment (Wales) Bill?
Yes
1.2 Please outline your reasons for your answer to question 1.1
(we would be grateful if you could keep your answer to around 1500 words)
Yes, NAPfRE agrees that the following key principles for developing legislation to support the new curriculum and assessment arrangements are appropriate and the panel fully supports them:
• Helping all learners to embody the four purposes;
• All children and young people, including those with severe, profound or multiple learning difficulties, are entitled to a high-quality broad and balanced education throughout the period of statutory education;
• Promoting learner progression; and
• Encouraging stimulating and engaging teaching and learning, which supports learners to make connections across different aspects of their learning.
However, the panel does have some concerns, outlined below.
The panel agrees that these principles should be the driving force of this curriculum in order to ensure that ALL learners receive equal opportunity to the highest quality education in Wales. It is vital for the spiritual, moral, cultural, mental and physical development of all learners to be considered and provided for in all school level curriculum design. The legislation for this is still in effect and through the four purposes can be achieved. However, the panel feels that SMCMP development should be more explicit in the curriculum guidance.
For example, there is no mention of SMCMP in Chapter 2 or Chapter 3 of the Bill, under ‘General Implementation Requirements’, and the only mention of it that we can find is in Chapter 4, Part 5 of the Bill, under ‘Post-Compulsory Education in Maintained Schools’. The panel feels that this could cause confusion and risks some schools not embedding meaningful opportunities for SMCMP development within their individual school curriculum.
The majority of the panel supports areas of learning and experience and the new approach of what matters which they feel will support learners to make connections across different aspects of their learning. However, the panel feels strongly that RE (RVE) should not be lost within this approach, and providing appropriate and specialised professional learning will be a key factor to ensure this does not happen.
1.3 Do you think there is a need for legislation to deliver what this Bill is trying to achieve?
(we would be grateful if you could keep your answer to around 500 words)
Yes. Existing legislation would be out of synch with certain aspects of the Curriculum for Wales (2022) approach. However, the panel feel that some of the changes to legislation need further consideration, for example:
1. The change of name from RE to Religion, Values and Ethics (RVE);
2. The change of SACREs to SACs;
3. Imposing on VA schools a duty to offer two RVE curriculums; and
4. The broad and vague description of philosophical convictions;
In addition to these aspects of the legislation that have already been amended, some members of NAPfRE feel strongly that the following section of the Curriculum and Assessment (Wales) Bill is considered.
Chapter 4, Part 5, section 62 and Schedule 2 states:
Teaching and learning provided under this section—
(a) must reflect the fact that the religious traditions in Great Britain are mainly
Christian, while taking account of the teaching and practices of the other principal
Religions represented in Great Britain, and
(b) must also reflect the fact that a range of non-religious philosophical convictions
are held in Great Britain.
The panel has questioned whether this should be ‘Wales’ rather than ‘Great Britain’ in order to better reflect the new curriculum approach? If not ‘Wales’, then perhaps ‘United Kingdom’ would be more appropriate (if historically accurate and not problematic), as ‘Great Britain’ sounds very colonial. This whole section should be future proofed to take account of the evolving nature of religion and worldviews in Wales and the wider world, so that this legislation is not outdated from the outset.
It is vital that the principal religions in Wales are taken account of in teaching and learning, as well as other religions and worldviews within local areas, to support community cohesion. Whilst it is necessary to consider changing the wording, this will need very careful attention so as to avoid unnecessary risk of any negative impact going forward.
2. The Bill’s implementation
2.1 Do you have any comments about any potential barriers to implementing the Bill? If no, go to question 3.1
(we would be grateful if you could keep your answer to around 500 words)
The new name for the subject, ‘RVE’ is misleading and unhelpful. It does not adequately describe the scope of the subject or reflect the rigorous, academic nature of the subject.
Parents losing their right to withdraw their child/ren from RE (RVE) could cause unnecessary conflict in schools.
Imposing on VA schools in particular, the duty to provide two curriculums for RVE will have significant budget and staffing implications for the schools and LAs.
Potential conflict between existing and new groups on SACRE regarding voting rights.
Funding for professional learning has been reduced this year which is very disappointing and could be disastrous for RVE.
2.2 Do you think the Bill takes account of these potential barriers?
(we would be grateful if you could keep your answer to around 500 words)
No.
In the case of the new name (page 152 of the explanatory memorandum) it states that ‘RVE’ reflects the proper scope of the subject. This is not true at all. The name is misleading and not in line with current UK and international thinking or direction of travel with regard to RE.
In the case of not including the parental right to withdraw across the board in all types of schools, despite the attempt to avoid conflict by imposing on schools with a religious character the duty to offer two RE (RVE) curriculums, the panel feels that some parents will still have issue with this.
In the case of VA schools having to offer two RE (RVE) curriculums, this will create excess workload and could disrupt the culture and ethos of those schools with a religious character, which could have disastrous consequences, including some that may affect the health and wellbeing of learners and staff. Schools with a religious character should, by their very nature, be different. There are varying views on what solutions could be offered on this issue from the panel.
In the case of having ‘new groups’ on SACRE with possible voting rights which would be disproportionate to their local representation, this will create inequality and could cause conflict between the members of group (a) and the new group (aa). This needs to be looked at very carefully to ensure fairness and balance.
In the case of reduced funding for professional learning, in order for RE (RVE) not to be ‘lost’ within a humanities curriculum, PL is key. It is essential for all RE (RVE) to meet the statutory requirements in law and without PL this is vey much at risk. It is vital that appropriate and specialised PL for RE (RVE) is provided/available for schools in order to ensure that RE (RVE) teaching and learning is high quality, stimulating and engaging.
3. Unintended consequences
3.1 Do you think there are there any unintended consequences arising from the Bill? If no, go to question 4.1
(we would be grateful if you could keep your answer to around 500 words)
An unintended consequence could well be that teachers and parents will misinterpret the scope of the subject due to the new name, which could lead to inappropriate teaching and learning at best, and illegal teaching and learning at worst. E.g. indoctrination of a teacher’s own perception of the ‘right’ values and ethics. This could lead to legal challenges against the non inclusion of the right to withdraw.
Some parents may also choose to home school due to the removal of the right to withdraw in some schools.
Extra budget implications on schools and LAs due to having to offer two RE (RVE) curriculums in VA schools.
Changing the law to require Agreed Syllabus Conferences to have regard to curriculum guidance could undermine local democracy (elected members on SACRE and ASCs).
4. Financial implications
4.1 Do you have any comments on the financial implications of the Bill (as set out in Part 2 of the Explanatory Memorandum)? If no, go to question 5.1
(we would be grateful if you could keep your answer to around 500 words)
NAPfRE members are concerned that funding has been reduced significantly due to covid -19 restrictions on education in Wales and that this may have a negative impact on professional learning for RE (RVE) going forward. It is vital that specialist PL for RE (RVE) is provided for schools in order to ensure that RE (RVE) teaching and learning is high quality, stimulating and engaging, that it meets the statutory requirements in law, and to ensure that RE (RVE) is not lost within an integrated curriculum.
5. Powers to make subordinate legislation
5.1 Do you have any comments on the appropriateness of the powers in the Bill for Welsh Ministers to make subordinate legislation (as set out in Chapter 5 of Part 1 of the Explanatory Memorandum). If no, go to question 6.1.
(we would be grateful if you could keep your answer to around 500 words)
Table 5.1 section 5.
Powers for Welsh Ministers (WMs) to make Regulations to add, remove or revise the identified areas of learning and experience, mandatory elements and cross-curricular skills.
5.2 The Welsh Government will consult on the content of the subordinate legislation where it is considered appropriate to do so.
These powers outlined above pose a risk to RE (RVE) and other subjects in that they could be removed as a mandatory elements of the curriculum in future, without consultation.
NAPfRE members feel strongly that there should be different levels of scrutiny for different changes. For example, if a word needs amending to reflect new or current practice it would be appropriate to do this without consultation. However, removing a mandatory element of the curriculum must always be consulted upon, regardless of whether the Welsh Government considers it to be appropriate to do so, or not.
Is the specific legislation for RE and SACRE classed as subordinate legislation? If so, what further impact might this power have on this legislation?
6. Other considerations
6.1 Do you have any other points you wish to raise about this Bill?
(we would be grateful if you could keep your answer to around 1000 words)
Some of the NAPfRE panel are concerned that from an exam point of view, if schools are free to teach a wide variety of religious and non religious perspectives throughout the learning journey, including at progression step 5, that examiners would not have the expertise to mark all responses, and the mark scheme would then have to include such a wide range of indicative content, that it would be vast and unmanageable. This needs careful consideration.