Comments on School Starting Age Claire Crawford, Lorraine Dearden and Ellen Greaves, Institute for Fiscal Studies We think that the evidence presented in the DfE document is reasonably accurate and balanced; however, we feel that • The main evaluation of the free school meal pilots should be a key reference, not just a footnote. The full reference is given below. • In this report we found that Universal entitlement to free school meals significantly increased attainment in the pilot areas of Newham and Durham relative to a carefully chosen group of similar pupils in non-pilot areas. Pupils in these pilot areas made between four and eight weeks more progress over the two year pilot period than pupils in other areas at Key Stages 1 and 2 (ages 7 and 11). It would be helpful to emphasise the two-year period in the summary of evidence. • It is also worth noting, however, that the mechanisms through which this increase in attainment was realised were unclear: we found no evidence of significant improvements in behaviour or health (at least not using the measures available to us in the evaluation). • We warned in our report that it was unclear whether the effects on attainment could be replicated in less deprived local authorities (Newham and Durham are much more deprived than most local authorities). The pilot also invested considerable resources in increasing awareness of free meals and encouraging take-up, e.g. by offering taster sessions. It is not clear whether the impact of offering universal free meals will be as strong in the absence of this additional work. • Whilst the evaluation did find that the results were strongest for pupils from less affluent families, the results for this group were not statistically significantly different from those from more affluent families. It is therefore not a given that this policy will reduce socio-economic disadvantage in schools. • The impact report did not (and could not) conclude that take-up increased for already eligible pupils because of reduced stigma, although this is one plausible explanation. Other reasons could include increased awareness of free meals (e.g. parents may not have previously realised they were entitled). • The evidence cited on nutrition cites the impact on consumption at lunchtime, which is more positive than the evidence on consumption overall. The extent to which this policy will have nutritional benefits outside school hours is therefore not certain. References to our work on the subject: Brown, Crawford, Dearden, Greaves, Kitchen, Payne, Purdon and Tanner (2012), ‘Evaluation of the Free School Meals Pilot: Impact Report’, Department for Education, DFE-RR227., https://www.gov.uk/government/publications/evaluation-of-the-free-school-meals-pilot-impact-report.

I know I have written more than enough on this universal infant free school meals. But I just want to emphasise that this policy cost well over a billion pounds, one of the largest one off education spends in recent times, yet it appears to have avoided all but the lightest of scrutiny. No one has asked if the policy offers value for money or published success criteria to identify if it is making a difference, it just seems to have gone through on a nod and a wink. There is no hard evidence to justify the policy, none whatsoever, the implementation was rushed and underfunded with no one looking at the true cost, or the outcomes. We diverted school leaders from far more pressing issues, made schools and LA fund the setting up and the funding levels will likely mean some schools cutting other areas in order to subside this ongoing. This was all ignored in the evidence provided to the committee by DfE which was shameful, incomplete and misleading. There were obvious mistakes all the way through the implementation, yet the liberal democrats have promised to extend the policy to juniors, other parties may be considering the same, yet there is no evidence we get any return on the £billion plus spend, it just sounds appealing. Someone needs to investigate this, to learn lessons, to ensure we don’t make the same mistakes again. If not the Education select committee, then who?

I'm chair of governors of a primary school (160 pupils). We don't have our own kitchen. The introduction of universal FSM for KS1 has cost us well over £3,000 for dishwasher, extra plates etc. And now we have to pay in to waste collection service. This is money we can ill afford from our carefully planned 3 year balanced budget. We did not quality for any of the funds available. I won't go into quality and nutritional values here.

In reviewing the evidence provided by DfE, one can’t help but be shocked at the complete lack of actual evidence offered. Mostly it seems little more than opinion or speculation. This smacks of being forced to justify a policy with anything they can throw at it, in the hope that something sticks. Ministers are equally, if not more culpable, they regularly tell blatant lies about the policy, nick clegg has variously claimed the policy will have health benefits, improve behaviours, will reduce obesity, will improve dental health and create a greater understanding of our country. None of which he can support with any evidence. It’s as though the Deputy prime minister doesn’t understand the difference between correlation and causation. David laws has been no better, the education select committee will well remember how he tried to argue that the universal infant free school meals policy had been proposed by the school food plan, despite the obvious evidence that it wasn’t. The SFP recommendation was “Government should embark upon a phased roll out of free school meals for all children in all primary schools, beginning with the local authorities with the highest percentage of pupils eligible for free school meals” No infants first, No big bang implementation. No statutory requirement. Part of the problem is that there has been little scrutiny of the policy, ministers have been free to get in a quick sound bite and never been forced to justify what they say, no one has challenged the erroneous contention that the pilot report is evidence for introducing the policy. No one has taken them to task for implying causation when none was found. As a consequence they repeatedly placed more weight on the pilot report and the school food plan than either can bear. There are a number of important questions that remain unanswered; Where is the evidence that spending £1billion on universal free school meals will make a difference to these children’s attainment, social skills, behaviour or health? Where is the evidence that the policy offers Value for money? Where is the evidence that £150m capital funding is “the right amount”? Where is the evidence on the total cost of implementing the policy? Where is the evidence that the policy is sustainable and affordable? Where is the evidence that the policy was implementable in the time frame? How can we consider expanding the policy when we don’t know the costs or benefits it brings? This really has been a farce of epic proportions! As I have posted my responses in reverse order as I go along, I will be posting a full response (including links) on this blog page https://freeschoolmealsfactcheck.wordpress.com/2014/12/12/my-response-to-dfe-evidence/

Ministers are aware that some schools have costs above the £2.30 funding, requiring them to cut elsewhere to fund the policy, yet they do nothing in response. No one seems overly interested in looking to see if the policy makes any difference. To date no research has been formally commissioned to see if the policy makes any difference to children. A task made far more difficult as it coincides with the abolition of levels, so there is no easy baseline to compare against. It could well be that at the end of the two year funding, the policy has made a huge difference, or none, but we will never know. No one has even set out the success criteria for the policy, what we should expect, what measurable we should be looking at to see if the policy has made any impact. So we don’t know the total cost and we don’t know the benefits, yet somehow the Business case passed through the treasury as providing value for money. One assumes the treasury did due diligence on the pilot report provided as evidence. The results of this will be interesting given the report does a very limited cost benefit analysis against a couple of interventions, since publication many more Educational interventions have been investigated almost all of which show better results and offer far better VFM. Even using a £220 per child PA, the report states that the policy may not offer VFM, at the current cost of £437 it most certainly does not. The education world is spending a great deal of effort moving towards more evidenced based policies, governing bodies are forced to account for every penny, to evidence that they are providing value for money. This policy doesn’t appear to have any supporting evidence base and nothing to suggest it offers value for money.

Politicians seem happy that the ends justify means with this policy, they celebrate the success without knowing the true cost of getting there. Ministers haven’t investigated the full costs of implementing the policy, they don’t know how much time was spent by staff, or governors, they don’t know how much money was spent above and beyond DfEs £150 allocation and they don’t appear to care about finding out. Every head I have heard interviewed about the policy has talked about how stressful the implementation has been, the amount of time they have been diverted from doing other activities, how this has been implemented despite the efforts of the Dfe not because of it. DfE are fully aware that some schools have solutions in place which are not viable in the longer term. That for some schools the policy is having an adverse impact on the delivery of the school curriculum or has an adverse impact on provision of meals to other groups of pupils. Just consider that point, this has been passed into law, with the knowledge that in some schools it will have a detrimental impact! Ministers have previously refused to acknowledge that some schools are experiencing major problems. However there are now documented cases of schools having to run 4 sittings, schools where PE has been cut dramatically as the school hall is out of service for hours over lunch, Junior children no longer receiving a hot meal because infants are now the priority, Heads diverting their time and working as kitchen assistants, TAs making lunches. Complaints that children’s education is suffering, that Health and safety regulations can’t be met. All these despite the best efforts of school leaders, who in most cases have scrambled to implement the policy in time. But we shouldn’t be surprised that heads met with their statutory duties, that they complied with the law and gave all their infant charges a free meal. That’s what heads do, they get on with it. What we should be asking is, at what price.

The claim that 98.5% of schools would be offering a hot meal option on the first day of term is based on a survey of all local authorities (LAs) in England on the expected delivery of a hot meal option by schools in their area. DfE asked LAs “Will the school be offering a hot meal option”? To which 98.5% replied Yes and 1.5% said No. So far so good But I suspect this is overstated and optimistic, it is certainly not FACT. There are a number of reasons these figures are questionable. The questions were asked of LAs in mid August, when schools are closed. Anyone involved with schools will know that LAs are not always in possession of the facts on the ground, especially during the summer holidays. LAs are unlikely to know the state of every kitchen in its area nor the specific intentions of all the schools The DfE conveniently reminded schools that there is a legal requirement to provide meals, which may well illicit a degree of compliance. The survey was specifically asking about UIFSM readiness, nothing else, no thought seems to have been applied to possible bias as a result of DfE asking this question. Basically If the government rings up and asks if you will be abiding by the law or not, we shouldn’t be surprised if most people answer Yes. But most telling, the question was asking LAs to predict a future outcome, to guess what would happen in schools in September. I know from the debacle in Dorset, there can be significant differences between expectation and the actual outcome. This is made clear in the report “The results are based on LAs’ assessment in August of the expected delivery of schools in their area” So clearly this 98.5 is not the number of schools providing hot meals in September, it is a guess, nothing more. It isn’t even the governments best statistic. DfE also did a wider survey where Primary school senior leaders were asked about the extent their school was on track to deliver the UIFSM commitment. 91% of respondents said they were ready. I suspect this is a more accurate figure as it asked people actually in schools as part of a more general survey. The only fact, is there isn’t any hard evidence on the numbers of schools providing hot meals, which is why I think it is fundamentally dishonest to state the 98.5 figure as fact, but it doesn’t stop ministers. David Laws said in parliament “Some 98.5% of schools served hot meals from the beginning of September” No equivocation, no caveats, to me this is just misleading parliament!

The extra £22.5 transitional funding for small schools again appeared to be an afterthought. Though rightly welcomed, the small school taskforce figures showed that even with the extra funding, many small schools would still have to look to their own teaching budgets to subsidise the policy. It is now a real concern that no mention of the small school funding was made in the recent autumn statement. It looks likely that after the initial one year’s funding it will not be continued, leaving many rural small schools facing serious funding shortfalls. The support given to schools has been useful to a point, a help line is no alternative to a properly funded policy, I am not sure how widely used either the help line or the roadshows were. This want helped by the fact that the school food experts, at least initially, charged for school visits, despite all their funding. I despair at the argument that because the pilot had a fairly short time to prepare, the whole country should be able to cope. My understanding is that the pilot areas had to bid to be included in the scheme, they had to put forward properly worked out plans well before the start date. It was then just a process of enacting those plans (I accept that was still some challenge) The pilot areas had significant specialist support on the ground, not some lame helpline or poorly attended roadshows, and they could call on people to visit schools without charging any fees. I believe it is wrong to extrapolate the relatively benign circumstances of Newham or Durham as neither are representative of the challenges faced by many areas. (Worth noting individual Durham schools had to match their LA funding allocation) The big difference however is the scale, every supplier has been at full stretch working out what is needed, LAs struggled, resources were stretched much thinner and the importantly, the high level of funding received by Durham (£17,000 per school) is simply not there. It is also worth noting that DfE had an implementation report which predicted many of the problems experienced by schools as a result of implementing the policy, but it seems it didn’t learn the lessons. We have seen all kind of implementation problems, many of which could have been avoided if the politicians had not ignored the school food plan recommendations that “Government should embark upon a phased roll out of free school meals for all children in all primary schools, beginning with the local authorities with the highest percentage of pupils eligible for free school meals” A phased roll out would have reduced the pressure on schools, Las and suppliers, especially those experiencing the greatest practical difficulties. As it is a big bang start backed by a legal requirement, has mean schools spending huge amounts of money time and effort rushing to get things ready for September. All of which could have been better spent and spread over time. Schools were only informed of the policy on 17 December 2013, many academies didn’t even have time to apply for funding prior to the closing date, it was all so rushed. It is worth noting that many other departments extoll the virtues of phased introductions of policy, but it seems the decision was political and made without wider consultation.

Implementation Let us start with the fact that prior to Nick Clegg announcing the policy to the Lib Dem conference there was no consultation with any school food experts. The school food plan were not aware it was happening, the authors of the pilot report were not asked and it has been reported that DfE were only informed an hour or so before the announcement. All of which might explain why the Deputy Prime ministers initial announcement was for HOT meals and didn’t include any capital costs for new infrastructure. From that faltering start we have been in a process of crisis management rather than properly planned implementation. ‘Hot’ was dropped, as soon as ministers were informed that some schools didn’t have kitchens, something they were seemingly unaware of. As a result they then had to find extra money for kitchens and halls, settling on £150m, based one assumes on how much the treasury were willing to fund, rather than any proper assessment of need (no one asked schools about their facilities). £150 million for infrastructure may sound a lot but with a new 120 seat hall costing more than £500,000, it doesn’t stretch far. This lack of funding was compounded by the way it was distributed, not based on what each school might need, but to LAs based on historic headcount. So smaller areas like Rutland were allocated derisory amounts (£49665), effectively enough to fit out one new school kitchen, whilst Durham council received £1,290,738 despite already receiving funding to take part in the Free School Meals pilot. Despite the continued protestations from LAs and schools, that the policy wasn’t being funded properly. Ministers continued to insist that the £150m funding was sufficient and adequate. Which is odd, because at the time of the £150m announcement in December 2013, ministers had no clear idea of what infrastructure was needed by schools and therefore can’t have known if £150m was too much or too little, they just blindly asserted it was “the right amount” without any evidence. One thing that should be of real concern is the mounting evidence that DfE instructed LAs to use their designated schools maintenance budgets to fund any shortfall, effectively transferring responsibility for funding the policy onto councils rather than keeping it within central government. We don’t know full cost of implementing the policy to individual schools (I suspect it is substantial), but the Local government association published evidence that their members had to subsidise the policy to the tune of £26 million, separately we have recently seen an additional £25 million of DfE funding made available to LAs, though the applications for this fund may well exceed what is offered. So we have hard evidence that the £150 million was nowhere near enough, despite the DfE assurances that the policy was being fully funded.

Cost of living and economic viability of school meals services Whilst there is little doubt that the introduction of UIFSM will save some parents around £437 per eligible child, we must question if that offers good value. The poorest in society do not benefit from this policy at all, as they already received FSM. The main beneficiaries are those parents who already pay for school meals, for them this is in effect a £437 a year tax rebate. People wealthy enough to afford a meal and already pay for it are now subsidised by the state despite the fact their children gain nothing, as they already obtained any benefits to be had by having a meal. There are a tranche of children who will do benefit; those who currently live in poverty but are not eligible for FSM. But it is questionable if the cost of supporting those capable of paying is justified, just to help this relatively small band. Particularly when comparatively small changes to the FSM entitlement criteria would address the issue for this band, having a massive impact on all children living in poverty, not just those in infants, by including access to pupil premium funding. Whilst the School Food Plan did discus economies of scale, it should be pointed out that its own small school taskforce highlighted the fact for some schools costs will exceed the governments ongoing revenue funding of £2.30, this was in addition to the fact that £2.30 was the 2011-12 mean cost of primary school meals (meaning many will have paid more) and the Newham Pilot started with a cost of £2.59 in 2009 rising to £2.63 in 2011. We should be in no doubt that some schools will run at a loss because of this policy, a fact highlighted by Rob Bailey of APSE in his recent talk to the All-Party parliamentary Group on School Food. DfE concentrate on the economies of scale, preferring to ignore the fact that some schools will be forced into subsidising the policy from teaching budgets, as their costs exceed the government funding.