EYFS Reforms Consultation Response

Given the ongoing concerns around the reforms of the EYFS, I have decided to publish my response to the consultation here – all 16 pages of it. My response includes a mix of comments taken from a reference document published by Early Education at the time, guidance given at the time from the Early Childhood Maths Group on the maths goals, alongside additional comments of my own.


Consultation Response


Please give us your views on whether the activities described in each of the proposed educational programme summaries support children’s learning and development throughout the EYFS. Please provide your view below, being specific about which educational programme this applies to where appropriate.


The revised Educational Programmes are not written in a way that supports children’s learning and development throughout the EYFS – it is particularly noticeable that the reforms seem to position the EYFS as a phase that is made up of school based settings, and children aged 4 and upwards, when in fact the majority of provision is in PVI early years settings.


Early Education has summarised the research evidence in Getting it right in the Early Years Foundation Stage: a review of the evidence (https://www.earlyeducation.org.uk/sites/default/files/Getting%20it%20right%20in%20the%20EYFS%2 0Literature%20Review.pdf). This summary demonstrates why extensive changes to the EYFS are not appropriate or required. Where changes might be beneficial – for instance an increase emphasis on children’s rights – the reformed EYFS appears even further away from achieving this.


A survey done by Early Education of 3000 practitioners demonstrated extensive support for the EYFS in its current form. Responses showed that practitioners did not see changes to the EYFS as likely to improve children’s outcomes or reduce workload. The idea that it is possible to reduce workload at the same time as introducing significant changes to a phase, alongside a new baseline test, is over optimistic to say the least.


In reference to each specific area:


Communication and Language


It is important and useful to highlight language development as a central part of early child development. However, the first sentence is out of kilter with the recognition elsewhere in the EYFS about the interconnected nature of the three Prime Areas, and how all three are foundational for children’s learning. It is misleading to suggests a primacy for spoken language which is neither developmentally nor chronologically correct. This descriptor overlooks the importance of vocalisations, facial expression and gesture in the earliest stages of a child’s life.


The descriptor should be careful not to exclude those children who are pre-verbal or who may never acquire speech. The description of practitioners “commenting on what children are interested in or doing, and echoing back what they say with new language added” appears to under play what is meant by ‘serve and return conversations’ in the early years. These are about more than “commenting on” what children are doing – they are about a genuine interest in children’s interests. It is about more than “echoing back what they say with new language added” – it is about the use of sustained shared thinking (i.e. open ended questions) as well as the introduction of new vocabulary.


New vocabulary is not best introduced through reading as suggested in this descriptor, with first-hand activities serving only as follow-up practice. This misunderstanding reflects the lack of awareness of the fact that understanding precedes the use of vocabulary in this age group. Children best understand words when they experience them in first-hand contexts, not in the more abstract situations of a practitioner reading them a book.


There is a danger that language development is being viewed in an overly simplistic way because of the current focus on memorisation. In this descriptor it is seen as being about memorising more words and as something that arises mainly out of reading and embedding, rather than also out of child initiated play (where the child’s language will develop from interactions with other children as well as with practitioners).


Physical Development


Outlining how practitioners can support the children in understanding about a healthy diet should be included in this educational programme. Healthy eating is vital in ensuring good physical development and understanding more about a healthy diet is important in combating childhood obesity. It might well be worth including a reference in this section to the fact that exercise is important for our mental as well as our physical health.


There should be recognition here of the importance of physical development and movement for developing sensory and cognitive abilities. Also the idea that children learn through their bodies and senses in active exploration of their world. For example, vestibular and proprioceptive development are crucial for moving and handling, but also for understanding oneself in space and how we develop mental maps and concepts through schematic play.


Physical development includes health and self-care, which should be restored to this section. For example, the development of continence is part of physical development and is affected by self-awareness of bodily processes and the development of the relevant muscles. Being able to dress oneself relies on gross and fine motor skills and proprioception.


Personal, Social and Emotional Development


This section should be first in the list of descriptors. It is fundamental to all areas, including communication and language —it is impossible to communicate or learn language except in relationship with others. When children are stressed, do not feel safe and cared for, their fight-or-flight response impedes brain activity in frontal lobes and impedes learning.


A feeling of belonging and self-worth is vital, because we learn through and with others, and so relating to others is essential. There is an attempt to introduce some concepts relating to self-regulation here such as “set themselves simple goals, have confidence in their own abilities, to persist and wait for what they want and direct attention as necessary”. Children within the EYFS may start to develop these skills with support, but it should not be implied that children will typically have fully developed these skills at age 5.


It is good to see the importance of attachments emphasised here. The term empathy might usefully be included in this descriptor. It would be nice to see more references to babies in all of the descriptors, to underline the (often overlooked) fact that this phase runs from birth to age five, and this might be mentioned in this descriptor to emphasise that point. Most of the descriptors feel as though they are written with a Reception class in a school in mind, rather than the whole phase, of which the majority is in PVI (non school) settings.


The references to learning “how to make good friendships, co-operate and resolve conflicts peaceably” are not relevant to most of this age group, and the current formulation “to form positive relationships and develop respect for others; to develop social skills and learn how to manage their feelings” is better.




The descriptors here seem to over look the emotional aspects of reading and writing (for instance writing as a form of self expression, reading as an act of love between carer and child) and to focus instead purely on literacy as a set of functional elements that are taught in a school classroom. While it is correct that stories help children to develop knowledge about themselves and their world, this is not all that they do – again the emotional aspects of being a reader – that reading gives us pleasure – could be more fully emphasised. The joy of reading is not just passed on by the teacher demonstrating his or her own enjoyment, but by the child experiences contexts in which reading gives them pleasure. The clarity of the message around how practitioners can ‘ignite their interest’ in the act of reading seems to have been lost. The word ‘knowledge’ is included three times in this descriptor which feels like over kill. The word ‘teachers’ rather than ‘practitioners’ is used in this descriptor and this may lead to practitioners in PVI settings feeling that they are being forgotten.


The last sentence of this EP about developing a love of reading should be at the start, not as an afterthought. The reference to teachers is not relevant to the younger age groups and referring only to “reading in class” overlooks the vital role for early years settings in supporting families to develop rich learning opportunities at home, which is an integral part of learning in the EYFS.


Overall, this descriptor is written as if the educational programme for literacy applies only to children who are beginning to read. It needs to be applicable across the whole of the EYFS. It should include concepts of print, mark-making, environmental print, familiar symbols, etc. Both here and in the introduction to CL, it needs to be made more explicit that communication and language (especially oral language) is the root of literacy. Listening comprehension – which is what the ELG is about – is not part of reading – it is part of underlying communication/language and should be reinstated there. Composition in speech is also not Literacy.


Literacy should be seen as a subset of communication and language, rather than the other way around. References to “mark making and writing” would be more appropriate than “handwriting” in this context. Handwriting is a physical fine motor skill, and depends on physical development and is age dependent. It is not necessarily part of writing, which is conveying meaning in text – which could be on a computer, magnetic letters, or through a practitioner scribing their ideas. This descriptor should focus on how reading and writing, as well as being mechanical skills, can be set in meaningful contexts that – as the current descriptor puts it – will “ignite their interest”. Children’s motivation to decode text comes from understanding that it empowers them to access something they want – stories or information. Motivation to write comes from children wanting to record and express their ideas.




The emphasis on number over all other aspects of early mathematics is perhaps the most troubling aspect of all the changes to the EYFS. Despite repeated requests, the DfE and its advisers have not been able to provide evidence for the claim that “number is the basis for all future maths”. What appears to have happened is that people who do not have a firm grasp of the EYFS as a phase, and who are perhaps more experienced in secondary, have advised on this aspect of the reforms from the perspective of working with older learners.


In this descriptor, the learning process that takes place from birth to five has been outlined the wrong way around and this has the potential to lead to confusion for practitioners in what they are expected to do, particularly with younger children in the phase. Curiosity about shape, space, pattern, measure and number are the key concepts on which practitioners should focus in this phase. This descriptor appears to describe EYFS solely from the perspective of a Reception class in school and even then narrows the subject to a simplistic view of conceptual development.


Early years maths should be grounded in children’s practical experiences and opportunities for problem-solving in real world play based situations. The descriptor should focus on how maths is embedded in all aspects of children’s daily experiences and the role of practitioners in drawing out key mathematical concepts and encouraging children to play with mathematical ideas through their daily activities. For instance, the way that mathematical learning is embedded in our setting through snack time activities. Understanding of number will develop far more effectively when grounded in these foundational mathematical experiences.


Research strongly suggests that spatial reasoning is a vital factor in early conceptual development in maths. Why is the DfE ignoring the evidence in the way it has approached this descriptor with the emphasis on number?


Understanding the World


Again this descriptor ignores the joy and curiosity that can be sparked by our early experiences, and instead views them through the lens of learning being about vocabulary, word recognition and so on. This part of learning in the EYFS does not need to be justified by reference to literacy – it is a key right of childhood for children to experience and find joy from the world they live in and it does not need to be justified by reference to other areas. The previous descriptor was much clearer about why this area is so important in early childhood.


The new text is unnecessarily specific about how to achieve the goals it sets – this area is now framed in terms of the experience provided by the school or setting (visits from or to the setting) and being read to. It is not helpful to suggest activity should be focused on “important members of society” (there are many occupations, not just “those who help us”, and many other aspects of community to explore) and or the very limited and unimaginative list of places to visit (“parks, libraries and museums”).


The descriptor fails to capture the broad experiences children will have within their homes and communities and the ‘cultural capital’ that they bring with them when they arrive in our settings. All reference to technology has been lost – this descriptor should reflect children’s emerging engagement with a range of aspects of science, technology and engineering in the world around them. It should be noted that the current goal is about Technology, not Information Technology as the consultation document erroneously suggests. Settings and practitioners need to encourage engagement with STEM in the early years, rather than downplay it. This is also an issue of access and equity as not all children will have access to technologies in the home environment.


Expressive Arts and Design


As explained above, again this descriptor ignores the joy and curiosity that can and should be sparked by our early experiences of art, and instead views the arts through the lens of memorisation and looking at the art which others have produced. Read out of context, it would be hard to see how this descriptor could possibly apply to babies!


Small children have the right to get hands on with art just because it is pleasurable, and because it helps them understand how they can express themselves through forms other than language. The arts are an area of early learning where babies and young children should be free to develop their self expression and not seen as an area where they must ‘learn techniques’ and ‘build knowledge’ before being allowed to get themselves covered in paint or play around with making music.


Again, it is a key right of childhood for children to express themselves and find joy through art and it does not need to be justified by reference to other areas or to memorisation and ‘high culture’. This is a non compulsory phase where children’s happiness should be our over riding priority. The reference to “quality” in this context is particularly problematic, echoing as it does a narrative around “the best that has been thought and said”. The arts in the early years are all about hands on exploration and the joy of ‘doing art’ no matter what the outcome of the art that you do.


General Points re. the Descriptors


Why does the word ‘play’ barely feature at all in these descriptors, given that it is a fundamental human right for children to have the freedom to play and the entire phase is fundamentally about play based learning?


The DfE and Ofsted have repeatedly said that the early learning goals are not ‘the curriculum’. The educational programmes should be the starting point for developing a curriculum in the EYFS and should be written to support an appropriate curriculum for all children in the phase – whether they are babies or about to turn five.


While it is technically correct that the goals are not ‘the curriculum’, the reality (as HMCI Amanda Spielman has pointed out) is that “ Across the whole education sector a mentality of ‘what’s measured is what gets done’ trumps the true purpose of education, and curriculum thinking – the consideration of what needs to be taught and learned for a full education – has been eroded.”


As the evaluation of the pilot showed, what is assessed gets prioritised, what is not assessed is marginalised when teachers are under pressure to deliver results. The ELGs therefore must align with the educational programmes (not the other way round). The test of the assessment should not only be whether it is an accurate predictor of future success, but also whether it ensures all aspects of the curriculum receive appropriate time and attention – the “broad and balanced curriculum” which is enshrined in English law.


Please give us your views on whether the proposed ELGs are clear, specific and easy to understand. Please provide your views below, being specific about which ELGs they apply to where appropriate.


General Points re. the ELGs


The ELGs are supposed to be summative assessments for parents/carers and teachers delivered according to the assessment principles set out in the EYFS Profile 2019 Handbook. Assessments are therefore professional judgements about best fit on the basis of a range of evidence, not binary test items based on how children perform in a one-off situation in the classroom. They should be clear enough to ensure consistency of judgement but should not attempt to present a simple tick-list of items a child must have achieved in order to “pass”.


The evaluation of the pilot found the concept of best fit was applied to the bulleted ELGs in a range of ways, not consistently – should all the statements be met, or just most of them? Does best fit for “knows 10 digraphs” mean knows at least 10 digraphs, or knows 8 or 9 and has achieved most of the other descriptors in the ELG? We know from the misuse of Development Matters as an assessment tick-list that simply stating it should not be used as a ticklist will not prevent it from happening.


The repeated use of the phrase “Children at the expected level will…” needs to be addressed. Does “expected” mean that all children should reasonably be expected reach this level by the end of reception, regardless of age, gender, EAL, etc? If so, these are clearly unrealistic expectations and should be revised to accordingly.


The annual crop of headlines stating that certain groups (FSM, summer born, etc) are failing this benchmark are an indicator that, if not all children are expected to meet these goals by the end of reception, the language used should be changed to indicate that while these may be typical developmental markers, children develop in different ways and that it is not reasonable to expect all children to meet them at a single point in the year regardless of age or other factors.


This is crucial in relation to the expectation that the ELGs should be a sign of readiness for Year 1. If the ELGs are to be an indicator of readiness for Year 1 then every child should be able to achieve them, including the youngest in the year – otherwise the Year 1 curriculum is clearly not appropriate for all children. Attempts to align the ELGs more closely with Year 1 appear to be creating goals which are not achievable by every child. We understand that the Government may be reluctant to review the Year 1 curriculum, but unless they do so this lack of alignment will not be resolved.


Communication and Language


Listening, Attention and Understanding


There is a lack of clarity here that may lead to inconsistencies in assessment. Terms such as “respond appropriately” and “hold conversations” are sufficiently vague as to lead to practitioners applying them in different ways. It is difficult to imagine a conversation that is not a “back-and-forth exchange” and so this part of the wording seems superfluous.


The removal of “a range of situations” and addition of “whole class discussions” makes it likely that practitioners might focus on spending more time on adult led whole class discussions than they had done previously. This in turn could lead to less time being spent on getting the children playing and physically active.


Removing “understanding” as a separate goal might lead practitioners to underplay the importance of non verbal communication as part of this area of learning. If the Government wishes to emphasise the importance of this area, why is it reducing the number of goals?




The introduction of the words “recently introduced vocabulary” here seems to tie in to the focus on memorisation as being seen as central. This is likely to be unclear to practitioners and hard to evidence – how do practitioners know whether a child has learned a word at home rather than in the setting? Vocabulary is not a proxy for the development of clarity or expression in speech.


In the report into the pilot of the reforms from the EEF, practitioners welcomed the removal of the requirement to use “past, present and future tenses”. This has now been put back into the ELGs and a concern would be that it suggests a focus on grammatical correctness, rather than an understanding of how we talk about the past, the present and the future.  The requirement to use full sentences and conjunctions and recently introduced vocabulary seems likely to lead to confusion and over complication. The focus in this non compulsory phase should be on children learning to express their thoughts and feelings, not on using grammatically correct Standard English.


‘With modelling and support’ seems likely to confuse the situation and lead to inconsistencies in application, since practitioners will have to make a judgement on what an appropriate level of support to achieve ‘expected’ will look like.


Personal, social and emotional development




The introduction of this as a new area is likely to lead to confusion, since the research into this area is complex and much of it is inter-related with the characteristics of effective learning. This ELG is very muddled. Giving “focused attention” to their teacher and following instructions is not self-regulation, although self-regulation does support this ability.


I am concerned that the requirement for children to give focused attention to what the teacher says, even if they are engrossed in an activity, is more about compliance rather than a realistic view of this age group.


The use of the word “several” to describe the number of ideas/actions in a set of instructions to be followed is likely to confuse practitioners and lead to inconsistencies. It could equally be taken to mean two or three, or perhaps four or five.


The original ELG is much more helpful than the proposed replacement in relation to self-confidence and self-awareness as it is about what children do and how they do it. The replacement is far too abstract. How will teachers judge whether children are waiting for what they want and controlling their immediate impulses? How often must they see these behaviours?


Managing Self


Trying to bring together areas from three existing ELGs under one heading is inappropriate. These goals are not as clear as the previous iteration.


The terms “independence, resilience and perseverance” are not clear and are likely to lead to inconsistent judgements. The term “know right from wrong” is vague and not as helpful as the idea from the original of knowing that “some behaviour is unacceptable”.


The hygiene and self care goals here would be far more sensibly included under the umbrella term of ‘physical development’. These are part of a child’s overall development and are not necessarily linked to personal choices about ‘managing’ oneself.


The removal of any reference to children understanding the importance of physical exercise for good health is regrettable at a time when obesity is a growing crisis, as this risks becoming another part of the curriculum which then receives less attention. Similarly, the loss of the reference to talking about ways to keep healthy and safe is a lost opportunity to ensure that children are given opportunities to talk about keeping themselves safe in different aspects of daily life.


Building Relationships


What is the word “work” doing in these goal? As Maria Montessori famously said, “play is the work of the child” and it is therefore unhelpful, confusing and tautological to include this word here.


The requirement to “form positive attachments” seems likely to lead to inequity for children from certain backgrounds – due to their history, it is not possible for some children to easily form attachments. Putting this as a ‘goal’ for children to ‘achieve’ seems counter to a philosophy of inclusion and our knowledge of SEND, since it is not about the child ‘trying harder’ but about the child’s personal circumstances.


Children who are introverted, and perhaps those who are only children, might find it more difficult to form “friendships with peers”. In addition, it is unclear how the word “friendships” is going to be defined.


The skill of working in groups with other children has been lost from this ELG, which is now more focused on compliance with the teacher. The ELG on managing feelings and behaviour has been unhelpfully split between the ELG on self-regulation and the ELG managing self, so that the link between understanding one’s feelings, linking that to one’s behaviour and its consequences and the ethical dimension has been lost.


Physical Development


Gross Motor Skills


It is limiting for this goal to have self care removed – physical development in young children is not just about muscle development and control – it is much wider than that. The reference to moving “energetically” is likely to cause confusion since the word is too vague in meaning.


This goal misses out important aspects of physical development such as the development of proprioception and the vestibular system. This goal also seems vague – what is meant by “demonstrate” – how often, how much, and so on? What level of skill at skipping and so on is required to reach the ‘expected’ level of development?


Fine Motor Skills


The reference to tripod grip in “almost all cases” is not developmentally appropriate, particularly for summer born children. In fact it could lead to pressure on children to use a tripod grip when they are not physically ready for it, and in turn lead to problems with posture in later life. This might prove particularly to be the case for children who are left handed and for those who are summer born. The reference is not inclusive for children with disabilities.




The rationale for changing these goals refers to children as “pupils”. This is not a term that would be used by practitioners working in EYFS and it should therefore be removed. Children in this phase are not in formal education, nor are they even of compulsory school age.


The level of detail in this goal mirrors the idea coming in Ofsted’s ‘Bold Beginnings’ report that learning to read is the “core purpose” of Reception. There has been no discussion with the sector about whether it is appropriate or useful to frame Reception in this way. The focus here is again on memorisation – building on the idea that learning is all about memorising things – rather than on the child’s response to what they read. The act of reading should not be uncoupled from the act of meaning making, or we risk returning to concerns from decades back about children ‘barking at print’.




Again the emphasis on “recently introduced vocabulary” risks a lack of clarity – how will practitioners be able to tell which words have recently been introduced? At this age children need to link new vocabulary with direct experience – it does not simply come from a practitioner teaching them new words.


The statements on comprehension might be better placed in ‘communication and language’. In order to show progression in language comprehension, this needs to include children understanding “how” and “why”. This is a better developmental marker than a focus on vocabulary, which could lead to misguided attempts to quantify how many words children should be learning.


Word Reading


Uncoupling reading from overall comprehension again runs the risk of children reaching the expected level but without fully understanding what they are reading. This perhaps mirrors the use of ‘nonsense words’ – words with no meaning – in the phonics check.


The sole reliance on phonetic decoding before engaging with meaning of words and texts, though supported by the current government, is a highly contested area. This does not reflect much current expert understanding of the development of reading. The approach is inappropriately restrictive and attempts to dictate approaches instead of leaving this to teachers’ professional judgement. There is nothing here about using pictures to support the understanding of words and comprehension. Nor is there any reference to enjoyment, which should be fundamental to all reading or we risk ‘turning children off’ the subject.


The first bullet point is inappropriate – this is too challenging for many children, and as clearly demonstrated by the pilot evaluation there is no clear consensus on current expectations in the teaching of phonics to support this. For children with EAL, SEND and summer born children this could be a significant challenge. Also, this will be used as a tick list – adding to workload as well as defining children’s progress as a deficit.


The goal is unclear – the evidence from the pilot suggests it may not be used consistently as the idea of best fit was applied to it in several different ways. This is one of the changes to the ELGs that could lead to a significant drop in outcomes at the end of the EYFS.




This goal is too narrowly defined as a handwriting and phonics task, rather than as a form of self-expression. This mixing up of technique with skill as a writer is a common misunderstanding of what is important in becoming a writer. There is nothing here about children using writing to express themselves, their ideas, their thoughts and their feelings.




I endorse the proposals of the Early Childhood Maths Groups for the revised ELGs for Mathematics as set out below, based on their extensive expertise and research evidence. I would strongly argue for the restoration of the ELG Shape, Space and Measure as a key indicator of children’s future success not only in mathematics but in other STEM subjects.


As demonstrated in the pilot, there is clear evidence that subjects that are not assessed receive less attention. Focusing on a deep understanding of the numbers to 10 is an improvement on the previous focus on counting to 20, but the ECMG proposal for numbers to 12 is preferable.


The goal for ‘numerical patterns’ is unnecessary and will inevitably become another ‘test item’ for children. It would be far better to keep Shape, Space and Measure as it gives children a wider experience of mathematics which aligns better with early child development. Many schematic patterns of thinking are the basis for these aspects of learning so it is crucial to keep them.


This goal should not be about ‘recall’ or rote learning – here we see the focus on learning as memorisation at its most pronounced. It is also unclear for practitioners what is meant by automatic recall – in the pilot teachers asked how fast children were expected to recall facts in order to meet expectations. Quick-fire recall is not an appropriate target for young children as it may lead to anxiety around maths and thus be detrimental to their mental health in the longer term.


There are a number of unclear phrases in the latest versions of the goals including “deep understanding”, “number bonds” and “patterns within numbers”. The ECMG formulation is much clearer and more specific in setting out what children should know and be able to do. Inclusion of evens and odds and double facts are not appropriate for all children at this stage and should not be included.


I support the following revised ELGs proposed by the ECMG:


Number ELG



  • With numbers to 12: count out a number of items from a larger group, match numerals to amounts, compare and estimate numbers, predict adding or taking one.
  • Subitise (recognise a number of items without counting) up to 5 and recognise how numbers are made up of other numbers.
  • notice, copy, continue and create patterns.
  • solve practical problems including: adding, subtracting and sharing.
  • communicate their mathematical thinking in a range of ways.


Shape, space and measure ELG



– make comparisons of length, weight and capacity

– begin to identify the rule in a pattern

– select and combine shapes for a purpose and talk about their properties using mathematical and everyday language

– follow directions and describe positions and routes


Understanding of the World


There is an excessive use of the phrase “what is read in class” here. Reading in class is not the only way that children can learn about and experience the world around them. The EYFS is a phase focused on direct experience of the world and this should be clearer in this goal. We should be starting from the children’s own experiences and interests, in order to better support their conceptual understanding.


The removal of technology from this goal is a negative and appears to be based on the misapprehension that the previous goal referred only to ‘information technology’ rather than the wide range of technologies that are part of our children’s lives.


Separating these two ELGs out from the current ELG on “People and communities” is muddled. The original ELG is better, with a deeper approach and supporting development of British Values and social mobility. In the new version “Lives of people around them… and roles” is about culture and communities yet is put under “Past and present”.


The concept of “past and present” appears to be suggesting that this ELG is focused on the study of history, rather than primarily on helping children understand their place in the world – starting with their family and community, ideas of citizenship (which the research suggests should be more strongly emphasised in the EYFS) and the everyday institutions which form their experiences. Past is personal at this age, and it is not about learning history from books, non-fiction texts, reading in class, etc. This is not at all appropriate for YR, as demonstrated by the findings of the evaluation pilot that “children often struggled to understand the history topics they had embedded into the classroom”. “Past and present” is not an appropriate focus for this ELG, which is an inappropriate attempt to mirror the structure of Y1.


It is pleasing to see the inclusion of the natural world in this goal. However again the reference to “what has been read in class” may act to push practitioners into focusing on reading about the world, rather than direct experiences of it or simply talking about it. It is a shame that climate change has not been considered in this goal.


The reference to technology in this area of learning should be restored, within the wider context of the importance of building early understanding of and engagement with STEM subjects. Children in Reception can engage in a wide range of engineering, design and technology experiences such as woodwork, construction, simple circuit design, coding, woodwork, making films and videos. These activities relate closely to Expressive Arts and Design as well as Understanding the World, but they need to be explicitly referenced as relating to our scientific and technical understanding of the world, not only to design, and they therefore belong in both areas of learning.


Rather than removing the Technology ELG it should be prioritised to ensure children from an early age are being encouraged to engage in STEM activity, and to ensure this kind of activity is not lost from the curriculum. There is a real risk that a largely female workforce in the early years feels less confident to engage with STEM activities through the lack of encouragement and opportunity in these in their own education. Removing the ELG could perpetuate the problem. It is also noteworthy that technology is one of the few ELGs where boys currently outperform girls (suggesting the pervasiveness of gender issues in STEM) and therefore its removal is likely to further increase the perceived gap between girls and boys in the EYFSP.


Expressive Arts and Design


The emphasis here is very much on the output (‘creating’) rather than on exploration and experimentation. This is not appropriate when learning art – the process should always be seen as more important than the product.


Why is ‘being imaginative and expressive’ limited to narrative, stories and songs? It is perfectly possible for children to be imaginative and expressive in all art forms, including when drawing and painting. Similarly, ‘draw and paint’ is narrow and sculpture, collage, etc. could be included here.


The focus on responding to stories here seems unnecessary – why prioritise art in response to stories over art in response to other stimuli? The central idea of children expressing themselves through art has been lost here.


The focus on performance here again seems to prioritise product (outcome) over process (learning). There should be no expectation that children of this age should sing for others as this may cause anxiety for shy or younger children.


Please give us your views on whether the proposed ELGs contribute to a well-rounded assessment of a child’s development at the end of reception year. Please provide your views below, being specific about which ELGs they apply to where appropriate.


See the answers given to Q7 for detail of specific concerns in the different areas and particularly in terms of the narrowing towards a simple view of learning that sees it as only being about memorisation. Not only is this definition reductive, but it is particularly inappropriate in the context of the early years.


The removal of the goal for ‘shape, space and measure’ means that the mathematics goal in particular is not well rounded. The way that certain areas are split away from their original formulation (for instance the removal of ‘self care’ from ‘physical development’) means that the new goals do not reflect a holistic view of early child development.


One of the key concerns is in the excessive detail of many of these goals, particularly in comparison to other countries worldwide, where the early years phase typically runs to age six or seven years, and the goals at the end of the phase are far less detailed and prescriptive. The level of prescription seems likely to cause excessive workload (as has been reported with previous iterations of the EYFSP) and to limit the amount of time that practitioners can spend actually interacting with their children.


What are your views on removing the LA statutory element of EYFSP moderation? Please provide your views below.


In many areas LA moderation of the EYFSP is one of the only pieces of early years specific professional development Reception teachers currently receive. Removing it risks further reducing opportunities to network with peers and for practitioners to develop their knowledge and skills around observation and assessment.


When done badly, LA moderation has been thought to increase workload through unnecessary collection of data. However, this is by no means the norm, and it would risk throwing the baby out with the bathwater to remove this requirement. Better to provide better training and guidance at national level to make clear that neither assessment nor moderation require extensive data collection.


Without some form of external moderation, the EYFSP would very quickly become inconsistent across areas and it is likely to end up being removed as an assessment of this age group due to concerns about inconsistent data, particularly given the introduction of a baseline test.


What are your views on whether removing the LA statutory element of the EYFSP moderation will help to reduce teacher workload? Please provide your views below


Workload is often caused by external forces – these are not solely or even typically from a local authority. These external forces might include senior leaders in a school asking for more detail than is required, or concerns about providing ‘evidence’ for Ofsted inspectors.


By creating an expectation that a specific % of children ‘pass’ the EYFSP – i.e. reach the ‘expected level’ – the DfE itself causes workload.


The early years teams within local authorities are now severely eroded after years of funding cuts, and would be further damaged by removing the one remaining statutory duty. The introduction of the revised EYFS will already be severely compromised by loss of expertise within the LAs which could once have helped roll out training nationally.


What alternatives to LA statutory moderation do you think could help to ensure consistency of EYFSP judgements across the ELGs? Please provide your views below.


Any new system runs the risk of simply replicating the old one – including any workload that it caused. There is an established body of expertise among local authority moderators that should be built on, not dismantled. In addition to external moderation from trained moderators, all teachers in Reception – especially those new to the early years – should have access to appropriate training in early years observation and assessment, so that the standards of professional judgements improve. They must also have access to high quality exemplification materials to support their judgements. This will improve the accuracy of judgements but would not provide a substitute for moderation.


What are your views on the proposal to remove the ‘exceeded’ judgement from the EYFSP? Please provide your views below.


Removing this judgement will make the “emerging”/”expected” divide a purely binary one, and risks further discussion of EYFSP results as though they were a pass/fail assessment, rather than a broad brush measure of children’s progress against a set of benchmarks. This is compounded by the issue of politicians talking about children who have ‘failed’ at being ‘school ready’ when discussing the outcomes of the EYFSP.


Parents may wish to see the ‘exceeded’ judgement retained to reflect situations where a child is particularly advanced in terms of attainment in comparison to the year group. However, it could also be argued that the judgement might lead to pressure from parents to demonstrate that children are ‘exceeding’.


The loss of the ‘gifted and talented’ category appears to have led to the downplaying of the need for provision to stretch high attaining learners and the same might happen here.


Should the requirement in the EYFS framework to ‘promote the good health of children’ also include oral health? Please provide your views below.


Given the issues with children being admitted to hospital for dental treatment, and the fact that most settings now routinely promote oral health, I can see no problem with this requirement. However, one note of caution would be to emphasise that this is not about supervised teeth brushing sessions. We do not want to encourage parents to see their children’s oral health as no longer being part of their responsibility and this could be an unintended consequence of the inclusion of this requirement within the EYFS Statutory Framework.


Please provide any representations and/or evidence on the potential impact of our proposals on people with protected characteristics for the purposes of the Public Sector Equality Duty (Equality Act 2010).


The new literacy requirements are likely to reduce the number of children achieving the literacy ELGs, with particular impact on summer born children, children with SEND and boys.


The literacy requirements also seem likely to discriminate against children with EAL, and to underplay their achievements, particularly the emphasis on vocabulary and language. Children may be conceptually advanced but may not be able to demonstrate their cognitive level in a newly acquired language.


The removal of the Technology ELG is likely to increase the achievement gap between girls and boys in the Profile as this is currently one of the few areas where boys score higher than girls


The new ELG Gross Motor Skills is less inclusive for some children with SEND than the current Moving and Handling ELG, for example with respect to references to hopping, skipping, climbing, etc.


The reference in the ELG in Fine Motor Skills to the tripod grip is not appropriate for all children, especially some with SEND (the qualified nature of the sentence is too ambiguous to be clear as to whether it is intended to accommodate this).


It would be helpful if a specialist SEND group could review the proposals to ensure that the final version of the ELGs did not unintentionally exclude groups of children and to ensure that best fit judgements would allow sufficient flexibility to be inclusive where possible and appropriate.


It is vital that these areas are considered, because otherwise the changes to the EYFS risk increasing the issue of children being seen to ‘fail’ when they are simply younger or have SEND. This could in turn lead to a significant increase in requests to defer entry to Reception, particularly from the parents of summer born children, and to additional pressure to find alternative provision for children with SEND.


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