We have published our response to Ofsted's consultation [hyperlink to record in the ALT Open Access Repository].
Here are two key extracts.
Response to Question 3 (concerning the quality of teaching, learning and assessment)
We think that the absence of any mention of technology supported learning in relation to the quality of teaching, learning and assessment is a major omission that must be remedied, and we were very pleased to learn during IfL's consultation meeting with Matthew Coffey on 18/11/2011 that this problem has been recognised by Ofsted with a view to it being addressed. Our specific concern is that the CIF must take explicit account of the fundamental and seismic changes that are currently taking place in the way that knowledge is created, acquired and distributed.
Essentially the environment for learning has been rapidly changing beneath our feet for the last decade and will continue to do so for the foreseeable future. These changes are every bit as important as (but are probably more far-reaching and definitely more rapid than) those that occurred as a result of the invention of printing, and the CIF needs to be written so that inspectors, learning providers, and teachers are left in no doubt about the significance of the changes for "good" teaching, learning and assessment.
One way to address this would be for the clause "making appropriate and effective use of different learning methods including use of learning technologies" to be added after "staff set challenging tasks, build on and extend learning for all learners", and the clause "equipping all learners to take full advantage of technology and the Internet in their learning and in their lives more generally" after "staff set challenging tasks, build on and extend learning for all learners".
On a different point, it should be noted - and Ofsted obviously knows this - that it is learners that do the learning; teachers cannot "provide learning". For this reason the clause "staff have appropriate skills and expertise to provide good quality teaching, learning, assessment and support for each learner" needs to be adjusted.
Response to Question 4 (concerning leadership and management)
As with our response to Section 3, our disagreement stems from the inadequate treatment of technology in the clause "deploy resources, including staff, accommodation, facilities and technologies to support learning effectively".
Provided that suitable changes are made to how the quality of teaching learning and assessment is judged, so that the effective use of learning technology is explicitly brought into scope, then the weakness of the current formulation would be less important. However, categorising technology merely as a "resource to be deployed" does its importance a disservice (our Section 3 answer above relates); and it also tends to concentrate the user of CIF's mind on technology only as something under the provider's control "to be deployed", rather than as a whole mesh of services and functionalities "out there" that providers need to make good use of.
Thus we suggest the addition of a new stand-alone clause such as "ensure that learning technologies and ICT more generally are appropriately resourced and utilised across all relevant aspects of provision and across all relevant business activities".