What Is a Material Change for an Independent School?
Many leaders tell us that the decision to grow is the exciting part. A waiting list, a new building or a request from a local authority to take pupils with different needs all feel like signs that the school is doing well.
Some of these changes, though, cannot happen until the Department for Education (DfE) has approved them. This guide explains what counts as a material change, why approval comes first and what to expect from a material change inspection.
What counts as a material change?
A material change is a change to the details on which your school is registered. According to Ofsted's inspection information for non-association independent schools, material changes are:
- a change of proprietor
- a change of school premises
- a change to the age range of pupils
- a change to the maximum number of pupils
- changing from single sex to co-educational, or the reverse
- starting or stopping boarding provision
- starting or stopping admitting pupils with special educational needs and disabilities (SEND)
Admitting children under the age of 2 is also a material change, and it needs a separate early years registration with Ofsted.
Why approval has to come first
Schools cannot put a material change in place until the Secretary of State has approved it. Operating beyond the terms of your registration is a serious matter, and inspectors who find it on any type of inspection will report it to the DfE.
The reason is simple. Your registration reflects what the DfE has been satisfied your school can do well. A change to pupil numbers, ages or needs changes what the standards ask of you, from toilets and outdoor space to the curriculum and staff expertise.
What does not count as a material change?
A change of chair of an existing proprietor body is not a material change, although you must still tell the DfE. The DfE does not routinely ask Ofsted to inspect when a school opens a new building on its existing premises.
A change of proprietor is a material change, but the DfE does not normally commission an inspection for it. Ofsted checks proprietor details during every type of inspection.
How do you apply?
You apply to the DfE using its guidance on making a material change, which sets out the information you need to provide. The DfE may then ask Ofsted to carry out a material change inspection.
It is wise to apply well before you plan to make the change. Building works, recruitment and admissions all depend on approval arriving in time.
What happens at a material change inspection?
Ofsted normally gives 2 calendar days' notice. The lead inspector then holds a planning call with leaders, normally by video.
Inspectors focus on the standards affected by the change. They consider all its implications. If you have applied to take younger pupils, for example, they look at whether the accommodation, furniture and playground suit that age group, and whether the curriculum and teaching expertise are in place.
Inspectors always check the safeguarding policy and how it is implemented, and that the policy is published on your website. They also meet the proprietor.
How is the outcome decided?
If any standard relevant to the change is judged unlikely to be met, the overall outcome is that the school is unlikely to meet the standards. Inspectors judge exactly what you applied for and cannot agree to reduce numbers or narrow the age range during the inspection.
Ofsted does not recommend whether the change should be approved. The DfE decides, and the inspection report is always published.
Good practice
Schools that handle material changes well plan them as a project with a clear timeline. They update every affected policy, check the premises against the new numbers or ages and recruit the expertise the change needs before the inspection. The proprietor understands the plan and can explain it.
From Our Experience
We often see schools treat a material change as paperwork, when inspectors treat it as a question about readiness. A special school planning to admit pupils with a new type of need, for example, will be asked how staff have been trained and how the curriculum will adapt. Schools that recover well from a setback here usually go back and plan the provision, not just the application.
A common misconception
"We are already full, so taking a few extra pupils is fine." Your maximum number of pupils is part of your registration. Going beyond it without approval is a material change made without permission.
Questions for leaders and proprietors
- Is anything we are planning this year a material change?
- Do our premises suit the new numbers, ages or needs?
- Have we updated every policy the change affects?
- Do we have the staff expertise in place before the inspection?
- Have we allowed enough time for approval before the change starts?
Frequently asked questions
Can we start the change while we wait for approval?
No. Schools cannot put material changes in place until the Secretary of State has given approval.
Do we need approval for a new classroom block on our site?
The DfE does not routinely ask Ofsted to inspect when a school opens a new building on its premises. Check the DfE's guidance, because a change of premises is a material change.
Does Ofsted open Parent View for a material change inspection?
Not normally. In exceptional circumstances, such as significant changes to capacity, age range or the needs the school caters for, the lead inspector may seek approval to open the surveys.
What if our change has already happened?
Inspectors will report this to the DfE, which decides what action to take. If you think this applies to your school, seek advice quickly.
Our Perspective
A material change is a chance to show that your school can grow without losing what makes it good. Planned well, the inspection simply confirms that the children who join will get the same quality of education and care as those already there.
How Can Jarvis Education Help?
Our independent school inspection support includes help with material changes. We review your plans and premises against the affected standards, help you prepare the application and carry out a health check before the inspection, so you go into it knowing where you stand.
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