The broader context:
The Early Years Foundation Stage (EYFS) has been in place since 2008 but was revised following a far-reaching review (the Tickell Report) in 2011. This led to a rethink of the curriculum and learning goals attached to each subject area and specified where the optimal levels of development should be levelled.
The 2020 proposed EYFS reform is somewhat less radical – more of a tweaking around the edges – in order to clarify the goals so that progress can be more readily observed and reported and to reduce teacher workload by releasing professionals from the need for prolific evidence-gathering. Strangely the end-of-stage assessment is being revised before the curriculum and appears to be a direct response to the current problems with transition between Foundation Stage and Key Stage 1 which may be causing delays in progression as children take longer to settle. But rather than extending the most appropriate early years pedagogies into KS1 so that young children feel immediately at home and able to continue their learning in school, the reverse has happened as the proposed EYFS becomes more structured and formalised around the learning behaviours expected of older children. This seems at odds with much research in this area[1]. However, it is good to know that the government is investing £100m to improve outcomes, particularly in early communication, language and literacy development for disadvantaged children, which is to be welcomed if this means investment in extra support for children from many different cultures, families and abilities and with a range of communication modes that are contextually relevant.
Neither the three Characteristics of Effective Teaching and Learning[2] nor the seven areas of learning[3] are being changed but the content and descriptors for the seventeen Early Learning Goals (ELGs) which denote the end point assessment for each area of learning are being revised. Every child is assessed against these ELGs and determined whether they are ‘emerging’ or ‘expected’ to achieve a ‘good level of development’ (GLD) in all three prime areas plus the specific areas of literacy and mathematics. The proposed framework has dropped the former ‘exceeding’ level in a bid to reduce the admin burden.
Photo by Ruth Churchill Dower for Earlyarts
Problems in curriculum design:
There are several ways to design curricula and assessment frameworks depending on the governing structures, economic policies, industrial maturity and diversity of cultures in a country[4], but they are largely driven by one of two main purposes. There are those designed as developmental models, focussing on the processes and strategies in teaching and learning that will support the broadest possible development underpinned by clear pedagogical principles for children’s agency and achievement and are driven by educational values for knowledge rather than skill-based outcomes as the destination for every child. They have a view of the child as an independent, unique agent whose being is as important to nurture as their becoming, which itself is not a fixed point but full of potential (e.g. Te Whariki, or the Reggio Emilia approach) with more flexibility to respond to individual children’s needs and characteristics.
Others are designed as deterministic, performance models where the optimum learning outcomes are stated as a given in order to reach an overall destination, so teaching revolves around constant assessment of how children are progressing to meet specific ‘known’ targets and identifying what support is required when progression is not on target. Unfortunately this approach can add to the stress of teaching (especially with such large numbers of children in the current ratios) in reducing professional intuition and judgement, restricting children’s interests and capacities for learning to those identified areas and encouraging ‘teaching to the test’. These are the disadvantages of a curriculum that views the child as an asset of the future, where their education is an economic and social investment to prepare them for becoming an adult.
The EYFS is in the latter camp and, since its destination is to ensure every child is prepared to start school with the expected skills and knowledge of a five-year-old already embedded, specifies the types of activities required for children to achieve this. More experienced and better resourced settings will ensure a broad and balanced approach is taken to the EYFS that is inclusive and enables a depth of learning across all areas, recognising the different rates of development, cultural contexts and socio-economic opportunities and challenges that their children and families face.
There are pros and cons to both models but evidence suggests that developmental models enable children to achieve higher levels across all areas of education because curricula encourage more holistic teaching and learning strategies. And that, it seems to me, makes complete sense when we are supporting the physical, social, cognitive, sensory, emotional, spiritual and aesthetic growth of children who make connections, see patterns, recall memories and express themselves through many different modes, often at the same time because these dimensions are all connected. Much early childhood development (ECD) research demonstrates how young children are multimodal – they learn who they (and others) are through their senses, their bodies, their imaginations, their experiments, their relationships and attunements to people, objects and the environment around them. Ignoring this body of international research in curriculum design means children’s natural desire for holistic and connected learning remains frustrated and unfulfilled. For this reason, it is worrying to see mathematics and literacy given such a dominant, pedestalised position in the proposed framework.
The other, perhaps more important, reason why a deterministic framework is not necessarily appropriate for younger (or any age) children is due to its exclusivity and, therefore, exclusion. If rigid learning outcomes are determined from the start, this presumes a cultural type has been determined as ‘normal’ by those who have designed it and anyone who falls outside of that type is, by extension, ‘abnormal’ from the start. My own reading of the proposed EYFS suggests this norm has been embedded into the learning outcomes, and the types of activities suggested to achieve these are reinforcing largely mono-cultural, stereotypical ideals of the ‘normal’ child. It disinvests in children who need to learn differently (such as children with neurodiversities or who communicate without words or develop at different rates) and gives the message that different learning needs are considered less desirable as a starting point for achievement in English primary schools. This affects everything for a young child as it shapes a particular frame or perspective through which they are taught, observed, communicated with and expected to achieve from the beginning when they do not fulfil the ‘ideal’ outcomes. The onus and responsibility is placed on the child to change, rather than the environment, policies, financial and educational strategies that drive what is valued in early childhood (see Burman (2017), Murris (2016) and Roberts-Holmes (2019) for a more comprehensive narrative on these issues).
There are of course areas where progression to particular levels should be welcomed as a mark of healthy growth, such as the biological order of the development for young bodies (including the brain, nervous, cardio-vascular and sensory systems), moving from gross to fine motor development, including balance, coordination, proprioception, vestibular and sensory awareness, prolific synaptic growth, and so on. Or the development of emotional maturity as children realise they are independent of their carers and start to initiate and navigate their relationships. Or the development of many forms of embodied and verbal communication and expression as children become more confident and skilled to explore their worlds. Evidence shows that language acquisition (phonology, syntax and vocabulary) happens mainly between 1 to 4 years and serves as the backbone to later literacy development[5]. For this reason, having the Prime Areas of Learning focussed on physical development, communication and language, and personal, social and emotional development (PSED) makes sense. But my view is that there is a continuum along which children may move (in both directions and in a non-linear way) depending on their social, cultural and emotional contexts and some judgements about the measure of their cognitive achievements made too early in their lives can be detrimental to their emerging identities and future opportunities.
Whilst we may need a set of standards that enable natural progression such as the above to be measured, and differences identified and supported, the content of those standards surely has to provide space for the many variations of who a child might be at age 4 or 5, rather than what sort of child (or adult) the government wants it to be (or become). One could be forgiven for asking why they have proposed these standards for what an ideal five-year-old should look like? What is missing that might better reflect the learning capacities of the contemporary child now? And whose norm for childhood is this reinforcing? These are questions on the lips of many educational professionals as the revised framework prompts debate about how it will help them to support the many children who will now start their EYFS journey in a deficit position. These are children who will never be able to achieve the stated outcomes, and therefore always in a position of being marked as behind, abnormal, dependent on others, somehow made in the wrong mould and in need of re-shaping to a different, perhaps unnatural mould, due to being different to this ‘norm’. Are they less than ideal as humans if they cannot achieve these predetermined outcomes? With 28% of all children still not achieving the GLD despite 95% of settings being rated as Good or Outstanding by OfSTED[6], are we setting them up to fail?
Photo by Rachel Brooke for Earlyarts
Pedagogical shortcomings:
That said, in the proposed framework the changes to most areas of learning are welcomed in so far as they clarify the expectations, but it might be helpful to identify some of the shortcomings. Play-based or hybrid (mixing informal and formal methods) approaches to learning appear to have been removed entirely, despite these being two of the foremost powerful pedagogical strategies shown in research especially in early literacy, C&L. PSED and EAD. Kress (1997), Davies (2014) and Ollson (2009) identify the synathaesthic, somatic, spatial and other sensory learning being facilitated by play that is often invisible. There is a complete dearth of references to meaningful learning happening through contextualised play, where it becomes relevant for every child in their own culture and environment, especially those under three who don’t appear to have been given huge consideration in this framework. Wohlwend (2011), Brėdikytė (2011), Bruce (2005) and Vecchi (2010) document the many modes of perception and recall, learning and communication, facilitated through play including gestural, mimetic, ludic, spatial, narrative, collaborative, symbolic, material, dramatic and aesthetic. These modes nurture the skills required for language, literacy, mathematics, science, geography, history and artistic expression at much deeper levels and can often only be observed over a longer period, as the recent evidence review by the Working Together Coalition identifies:
It is evident in recent evidence reviews (Pascal, Bertram et al., 2017; Payler et al., 2017) that when a child is given freedom of expression within stimulating environments that support rich dialogues and cover a breadth of learning (numerous displays, abundance of graphical resources representing different modalities and materials, musicality and music), emerging symbolic languages such as writing and mathematics emerge, reflecting children’s growing competencies and understanding.[7]
The predominance of focus on spoken communication as a key skill across several areas of learning, and the word-dominant approach to teaching that is suggested (e.g. in several areas, it is suggested that teachers should read to children who will then learn by passive listening) is also of some concern. It may serve to isolate children who communicate without words and frustrate children who need to be physically engaged in their learning, whose optimum development is dependent on having opportunities for embodied experiences to explore literacy, maths, and science (Olsson, 2009).
Equally there is an emphasis on control, mastery, regulation, accuracy and precision throughout all the goals. For instance, Physical Development incudes an aim to ‘develop the habit of exercise’ (i.e. controlled, repeated movements) which is good to deepen the neural connections required for balance, posture, proprioception and coordination (Daly and O’Connor, 2016) but misses opportunities to explore the joy of movement in response to the ideas and forces within and around children. Literacy involves only two dimensions (reading and comprehension) according to the proposals, where children demonstrate progress by ‘listening and talking about stories’ read by teachers. There is no mention of the other dimensions involved in learning about language and communication that are prominent in many cultures such as somatic and sensory interaction, gestural body language and movement, musicality and singing, or emotional and social attunement through tactile communications.
Again, the area of Mathematics appears to have removed the focus on contextualised problem solving or expressing mathematical ideas through creative play, which can bring numbers to life in a meaningful way for young bodies and minds. Nor are there any references to the obvious links to children’s musicality, though which the exploration of patterns, repetition, rhythm, shapes, counting and measures provides an ideal platform for understanding complex mathematical concepts (Churchill Dower, 2020).
What is positive is the renewed focus on history, geography and natural science in Understanding the World although, again as with nearly all the areas including Expressive Arts and Design, the aim to support spoken language and vocabulary is stressed above other important possible learning content. The pedagogical connections between the sciences and the arts are not explored, and neither are there any references to children’s citizenship and belonging to local and global communities in a digital age, or the potential for environmental and climate change.
All that said, there is a clear message throughout that all areas of learning can be facilitated through different arts processes – mainly stories, rhymes, poetry, role play and singing. Whilst I would like to think this reflects a recognition of the importance of arts and creative opportunities in multimodal learning and intrinsic human development, I suspect these references are more driven by the desire to promote a language- (as opposed to communication-) rich environment.
Photo by Ruth Churchill Dower for Earlyarts
Expressive Arts and Design under the microscope:
My main focus is of course on Expressive Arts and Design (EAD) which has been rewritten in response to practitioner concerns about its lack of clarity. However, our research for Arts Council England (2018) suggests that these may have been borne more of a lack of training and confidence in arts skills than anything else and a desire to know what artistic progression looks like in young children[8]. The revised EAD seems to be more prescriptive than before and limited to developing arts skills as opposed to children’s broader cultural and creative development or their aesthetic capacities as artists in their own right (not just using arts as mechanisms for learning in other areas). It could certainly go further to identify other key art forms that can help to promote emotional and social attunement, celebrate multiple cultural identities, and better reflect the contemporary and diverse home learning contexts children are growing up in.
Art forms that early educators are familiar and confident with such as puppetry, modelling / sculpture, mark making, photography, music making, dance and other artforms are missing and yet a plethora of evidence demonstrates their vitality as mechanisms for children’s development, self-regulation (which is about stress reduction rather than behavioural compliance), belonging and expression (Churchill Dower, 2020). Further studies show the generative effects of arts processes not only in opening up many creative channels for expression but also to express them in a reciprocal relationship, i.e. to be listened to and seen/heard/felt/sensed/taken seriously on many levels (Churchill Dower, 2020). Or, as Grosz (2008, p22) puts it, ‘Art is…an unliveable power, an unleashed force that transforms the body along with the world.’
In immersive early years arts sessions, transformational events often happen when the focus is taken off what is considered to be ‘wrong’ with a child (and how to fix it) and instead shifted on to what engages them, inspires their ideas and drives their imagination. Eisner (2005), Sternberg (1999), Wright (2010) and Grace (2017) have illustrated that in these situations many children otherwise considered to have a communication disability have created, expressed and explored copious amounts of complex, rich and highly imaginative communication. Wright explains that an immersive arts environment such as whole-body drawing ‘integrates sensorimotor and other forms of thinking, reasoning, feeling and learning, which emerges through the ‘thinking body’. This is known as somatic meaning-making [and] involves exchanges between the psyche (mind), the soma (body) and the soul’ (Wright, 2010:80). These embodied or somatic expressions become less inhibited once trust and confidence have been established in relationship with others (people and materials), often within an improvisatory environment that nurtures children’s agency and often with sustainable, generative effects on longer term wellbeing.
There also seems to be a strong link between the nurturing of imagination and the ability to access potential and agency. Vygotsky (2004) proposes that a child’s imagination begins to form as they create theories about the world in order to fill the gaps in their narrow window of experience. Images are created from make-believe, ideation, embodied sensations or possibility thinking (Craft, 2002). These images or ideas, when expressed, can appear to adults as nonsense but make perfect sense to the child as they construct a ‘new reality that reflects their world view’ (Vygotsky, 2004:11).
Brėdikytė (2011) and Runco (2014) maintain that the arts provide limitless, unusual possibilities for this image-making to happen beyond the realm of language and these possibilities are especially evident in play when children ‘represent examples of the most authentic, truest creativity’ (Vygotsky, 2004:11). Of course, young children’s natural penchant for improvisation does not operate by conventional rules of communication. Because the aim is to play, explore, enjoy the feeling and express the fun and connection this creates, their expressions are often articulated not in order to be understood but for the purposes of curiosity, theory-testing, exploration of possible lines of enquiry, recognition of potentiality in things and possibility-making. Improvisation therefore could be a valuable teaching strategy for spontaneous, embodied literacies and multimodal expression but is at odds with the culture of conformity and representation in the proposed EYFS.
Through arts-based methods, children can test out whatever they are feeling or wanting to communicate, for which words simply cannot provide a satisfactory outlet (Wright, 2010; Brice Heath and Wolf, 2005). According to Kudriavtsev & Nesterova (2006, in Brėdikytė, 2011:52), the development of the imagination should, therefore, be considered the most important school readiness strategy, enabling every young child to create ‘a bridge’ between knowledge and understanding, thinking and expression, emotional awareness and possibility.
Nevertheless, as mentioned earlier, one of the main obstacles to developing this area further is the current lack of arts training and experiences of the positive joys of arts immersion for early educators. Unfortunately many practitioners receive next to no training in these art forms, and yet are expected to teach, assess and nurture high level skills and knowledge. We would be outraged if our early years educators were not well trained in numeracy and literacy. Why is the same importance not placed on their arts-based training as well, which is shown throughout research to have deeply significant and long-lasting impacts across many aspects of learning as well as enhancing mental health and wellbeing?
Specific Recommendations:
This area of learning should not be altered from the existing version. If it is, EAD should be called simply, ‘Being Creative’.
The rationale that these ELGs 'can particularly support children’s language and vocabulary development outcomes through role play, making up their own stories and singing' is not acceptable as it undermines the importance and vitality of children's creative and aesthetic abilities in their own right, and gives the message that the arts can only be justified as having instrumental benefits for 'more important' areas of learning.
The emphasis should be on children’s imagination, experimentation and participation in artistic ideas and self-expression across a broad range of art forms, to learn specific techniques, create alone and in groups, gain knowledge of different art forms and artists, and use a range of small and large scale resources to express familiar experiences as well as new ideas. In addition, the use of technology is now widespread in music, dance, story, design and other art forms and should not be excluded here.
We would also stress the interconnectivity of the arts and all areas of learning (especially PSED) and the importance of the use of improvisation and imagination to express aesthetic ideas as well as knowledge of technical skills.
The proposed ELG - 'Creating with Materials' - should retain its original title 'Exploring with Materials' to avoid an interpretation of this being about creating products only. The same with the goal to ‘Perform songs… etc’ (rather than ‘represent ideas…’). These revised wordings promote a view that arts education should be measured through visible creations, products or performances which is reductive, subjective and reveals a misunderstanding of how young children use their creative and aesthetic modalities to process their thinking, ideas and knowledge about the whole world around them.
A performative measure serves only to access the ability to recall a learned skill rather than scaffolding their intrinsically aesthetic dimensions or their natural creative processes. It creates an ambiguous expectation (not to mention performance anxiety) for educators and children that success in these ELGs is only based on the outcomes of technical arts mastery, which is only a part of what being creative is all about. Plus, it serves to reinforce the lack of mastery where goals are not met rather than the wonderful limitless possibilities the arts offer for the creative journey.
We strongly suggest the wording should reflect the multimodal processes through which children may explore and express their creativity, such as;
'Through visual arts, dance, drama, sensory exploration, puppetry, music, mark-making, singing, photography, modelling, gestures or vocalisation, children should be able to express or communicate knowledge about the fundamental characteristics of different art forms, e.g. colour, texture, shape, form, function, dynamics, pitch, rhythm, levels, speed/tempo, theme (or story), plot, character, dialogue, action, as well as recognising contrasts between different art form characteristics. Children should be encouraged to use improvisation and imagination to express their aesthetic ideas, and educators should facilitate creative methods by which to enhance both the content and the characteristics of effective teaching and learning such as creativity, curiosity, experimentation, invention, making connections, critical thinking, decision making, problem solving, working collaboratively and mastery.'
We are not at all sure what is meant by ‘try to move in time with music’ and how this can be assessed as being met if rhythm isn’t equally understood throughout all areas including physical development, language, literacy and mathematics. But rather than having more specificity of goals, this area of learning should be just as focussed on exploring vital creative processes at this age as it is on technical skills, recognising the quality of which requires some investment in training.
Finally, if EAD were one of the goals included in the GLD assessments, this would have a dramatic effect on how educators engage with the arts subjects and the arts sector. It would serve to change assumptions about EAD and UW being somehow less important areas of learning than others.
In fact, Grosz names art as ‘not frivolous, an indulgence or luxury, an embellishment of what is most central’ but ‘the most vital and direct form of impact on and through the body, the generation of vibratory waves, rhythms, that transverse the body and make of the body a link with forces it cannot otherwise perceive and act upon.’ (Grosz, 2008:23)
Photo by Ruth Churchill Dower for Earlyarts
After all, what is the purpose of education?
At the end of the day, I return to the question of what is the purpose of education and, if the framework is not fulfilling what research identifies as being the most optimal environments, pedagogies, values and content for learning, then perhaps the more poignant question is what can we do to change this?
Certainly, respond to the consultation and use our ideas and those of others (quoted in the footnotes) to inform your responses. As well as specifying changes to the content of learning, perhaps identify the most effective, enabling conditions for learning and the most useful pedagogical strategies (ways of teaching and learning) that might support a less narrow interpretation of the text and more expansive possibilities for generative, collaborative practice. This might include the possibilities to work alongside skilled professionals in real contexts to extend learning potential, such as artists, musicians, scientists and designers. Discussion of these processes are glaringly omitted in a single paragraph stating the definition of teaching as that of the primary sector[9] – without any reference to the importance of relationship building and attunement, scaffolding and extending learning or nurturing children’s agency.
But perhaps we could go a step further and ask, if a deterministic, performance-driven framework is so at odds with the ways we want to teach in early years and the ways children want to learn, and puts education professionals in a troubling position to teach against their values (resulting in the current mass exodus and recruitment challenges) then should we consider a more radical approach in the removal of the Early Learning Goals in their entirety? The evidence shows that developmental frameworks have just as much, if not more positive impacts on academic attainment and all-round health and wellbeing, not to mention happier children and teachers. It is something to think about.
Ruth Churchill Dower is the Director of Earlyarts, an award-winning research and training organisation informed by neuroscience, early childhood development, positive mental health and the arts. As well, Ruth is a PhD student at Manchester Metropolitan University, exploring the role of dance as an immersive space for rich, wordless communication between young children who don't speak and their parents, educators and other professionals. An accomplished musician, actor and storyteller, Ruth is passionate about fostering creative environments, pedagogy and leadership that empower children's learning. Ruth loves running, mountain biking and flying her paraglider.
Ruth’s new book, Creativity and the Arts in Early Years builds on international research and practice with new ideas for developing creative pedagogies and can be ordered here: https://earlyarts.co.uk/creativity-and-the-arts-in-early-childhood
References:
Brėdikytė, M. (2011) The zones of proximal development in children’s play. Doctoral Dissertation. University of Oulu, Finland.
Brice Heath, S. and Wolf, S. (2005) 'Focus in creative learning: drawing on art for language development.' Literacy, 39(1) pp. 38-45.
Bruce, T. (2005) 'Play, the universe and everything!' In Moyles, J. (ed.) The Excellence of Play. Second Edition. Maidenhead: Open University Press, pp. 256-267.
Burman, E. (2017) Deconstructing developmental psychology. Third ed., London: Routledge
Churchill Dower, R. (2020) Creativity and the Arts in Early Childhood, supporting young children's development and wellbeing. London: Jessica Kingsley Publishers.
Craft, A. (2002) Creativity and early years education: a lifewide foundation. London: Continuum.
Daly, A. and O'Connor, A. (2016) Understanding physical development in the early years: linking bodies and minds. Abingdon, Oxon;New York, NY;: Routledge.
Davies, B. (2014) Listening to children: being and becoming. London;New York;: Routledge, Taylor & Francis Group.
Eisner, E. W. (2005) The arts and the creation of mind. New Haven, [Conn.];London;: Yale University Press.
Grace, J. (2017) Sensory-Being for Sensory Beings: Creating Entrancing Sensory Experiences. London: Routledge Ltd.
Grosz, E. (2008) Chaos, Territory, Art: Deleuze and the Framing of the Earth. New York: Columbia University Press.
Murris, K. (2016) The posthuman child: educational transformation through philosophy with picturebooks. London: Routledge.
Olsson, L. M. (2009) Movement and experimentation in young children's learning: Deleuze and Guattari in early childhood education. London: Routledge.
Roberts-Holmes, G. (2019). ‘School readiness, governance and early years ability grouping’. Contemporary Issues in Early Childhood. Advance online publication. Retrieved from doi.org/10.1177/1463949119863128.
Runco, M. A. (2016) 'Commentary: Overview of Developmental Perspectives on Creativity and the Realization of Potential.' New Directions for Child and Adolescent Development, 2016(151) pp. 97-109.
Sternberg, R. J. (1999) Handbook of creativity. Cambridge: Cambridge University Press.
Vecchi, V. (2010) Art and creativity in Reggio Emilia: exploring the role and potential of ateliers in early childhood education. Abingdon, Oxon, England: Routledge.
Vygotsky, L. S. (2004) 'Imagination and Creativity in Childhood.' Journal of Russian and East European Psychology, 42(1) pp. 7-97.
Wright, S. (2010) Understanding creativity in early childhood: meaning-making and children's drawings. London;Los Angeles, [Calif.];: SAGE.
Endnotes:
[1] See Pascal, Bertram, Rouse, (2019) Getting it right in the Early Years Foundation Stage: a review of the evidence, London, Early Education.
[2] Characteristics include: playing and exploring - children investigate and experience things, and ‘have a go’; active learning - children concentrate and keep on trying if they encounter difficulties, and enjoy achievements; and creating and thinking critically - children have and develop their own ideas, make links between ideas, and develop strategies for doing things.
[3] Prime Areas include: Communication and language, personal, social and emotional development (PSED) and physical development. Specific Areas include: literacy, mathematics, understanding the world and expressive arts and design.
[4] See: Starting Strong, Curricula and Pedagogies in Early Childhood Education and Care - FIVE CURRICULUM OUTLINES, Directorate for Education, OECD, 2004 - https://www.oecd.org/education/school/31672150.pdf
[5] Pascal, Bertram, Rouse, (2019) Getting it right in the Early Years Foundation Stage: a review of the evidence, London, Early Education. (p27).
[6] Early Years Foundation Stage Reforms – Government Consultation, 2019, DfE (p6).
[7] Pascal, Bertram, Rouse, (2019) Getting it right in the Early Years Foundation Stage: a review of the evidence, London, Early Education. (p47).
[8] See: Churchill Dower, R. and Sandbrook, B. (2018) 'Early Years Arts and Culture: Current practice and options for future development.', Arts Council England: https://www.artscouncil.org.uk/publication/early-years-arts-and-culture
[9] Early Years Foundation Stage Reforms – Government Consultation, 2019, DfE (p8).