Raising Expectations: enabling the system to deliver (Joint DCSF/DIUS consultation) →
Raising Expectations: enabling the system to deliver (Joint DCSF/DIUS consultation) →
Raising Expectations: enabling the system to deliver (Joint DCSF/DIUS consultation) Consultation Response Form The closing date for this consultation is: 9 June 2008 Your comments must reach us by that date.
THIS FORM IS NOT INTERACTIVE. If you wish to respond electronically please use the online or offline response facility available on the Department for Children, Schools, and Families e-consultation website (http://www.dcsf.gov.uk/consultations). The information you provide in your response will be subject to the Freedom of Information Act 2000 and Environmental Information Regulations, which allow public access to information held by the Department. This does not necessarily mean that your response can be made available to the public as there are exemptions relating to information provided in confidence and information to which the Data Protection Act 1998 applies. You may request confidentiality by ticking the box provided, but you should note that neither this, nor an automatically-generated e-mail confidentiality statement, will necessarily exclude the public right of access.
Please tick if you want us to keep your response confidential. Name Tricia Hartley Organisation (if applicable) Campaign for Learning Address: 19 Buckingham Street LONDON WC2N 6EF If your enquiry is related to the policy content of the consultation you can contact James Addy on: Telephone: 0207 925 6209 e-mail: James.Addy@dcsf.gsi.gov.uk If you have a query relating to the consultation process you can contact the Consultation Unit on: Telephone: 01928 794888 Fax: 01928 794 113 e-mail: firstname.lastname@example.org
Please tick the box that best describes you as a respondent. Young person (under 18) Parent or carer Adult learner Teaching staff Professional working with young people Headteacher/college principal/leader of educational institution Local authority School General Further Education College Private sector organisation Sixth Form College √ Voluntary and community sector organisation Tertiary College Work-based learning provider Large employer Small or medium-sized employer Other (please specify) Please Specify:
Chapter 2: Local authorities commissioning provision to meet the needs of young people 1 Do you agree that transferring funding from the LSC to local authorities to create a single local strategic leader for 14-19 education and training is the right approach? Yes No √ Not Sure Comments: We agree that coherence across the 14-19 phase is important, and therefore support proposals to involve Local Authorities as key players. However, we are concerned about the following aspects of the current proposals: 1. the potential for creation of a ‘postcode lottery’ which widens inequality of opportunity between LA areas/ subregions for young people 2. conversely, the potential to reduce the autonomy of individual schools already working highly effectively on 14-19 collaboration with local post-16 providers, if responsibility sits at LA level 3. the capacity of LAs to take on these duties within a relatively short time- frame 4. the cost and impact on effectiveness of yet more structural change in the sector, together with the added bureaucracy of many separate sets of administrative arrangements across the country 5. we welcome greater continuity 14-19, but these proposals achieve it at the expense of discontinuity at 19. This is unhelpful, particularly for those young people who may take a little longer to achieve, and for employers, whose workforces comprise both young people and adults.
Chapter 3: Operational models for commissioning 2 Do you agree that the model we have proposed for transferring funding to the local authority is the best way to give local authorities effective powers to commission, to balance the budget, create coherence for providers and retain the national funding formula? √ Yes No Not Sure
Comments: We broadly support the model but believe that if transfer to Local Authorities is to take place it should cover all 14-19 funding, including 16-18 apprenticeships and 14-19 academy funding (currently funded directly by the Department). A single 14-19 budget is needed to support this. Do you agree that there is a need for: 3 a) Sub-regional groupings of local authorities for commissioning? √ Yes No Not Sure Comments: We agree that sub-regional groupings will help ensure coherence, create more cost-effective commissioning vehicles and help reduce local variability. 3 b) Authorities to come together regionally to consider plans collectively? √ Yes No Not Sure
Comments: Regions make good sense as the unit for planning, and we welcome Regional Development Agencies’ proposed roles. 3 c) A slim national 14-19 agency with reserve powers to balance the budget and step in if needed? Yes √ No Not Sure Comments: We agree there must be a national agency with powers to step in, but are concerned how ‘slim’ it can be while maintaining effectiveness. We feel the agency should have a strong & responsive advice & support role for LAs, which may require additional resource - perhaps by building in extra capacity in the early days which might taper later once LAs are confident in their new role. We are unsure why a new agency needs to be created to undertake the national role, with the substantial cost and disruption this will involve: we would favour retaining the LSC in its present form to do this, but with changes to its remit and powers.
4 Do you agree that we have described the way that these bodies would function in broadly the right way? Is the balance of responsibilities between them right? Yes √ No Not Sure
Comments: We would favour a bigger role for the national agency and a somewhat reduced responsibility for LAs, at least initially – but would favour retention of LSC in a new partnership with LAs and regional/ subregional partnerships. We are unsure what the implications of the proposals are for the relative autonomy of individual schools currently to work with local providers to offer the most effective mix of provision for local young people. We would favour a model that allowed schools to retain this, mediated by LAs and the regional planning process, and fostered sharing of effective practice between schools, LAs and regions.
5 Do you agree that there is a need for a single local authority to lead the conversation with each provider? √ Yes No Not Sure Comments: This makes sense in some ways, as providers – particularly small ones, including VCS providers like many of the organisations we support - may not have the capacity to deal separately with each LA. However, it is vital that sub- regional groupings are organised effectively along travel-to-study lines, as many post-16 providers cater for young people from across wide geographical areas.
We remain concerned about disruption of effective individual school-provider relationships, as above. We are also worried that large groupings for commissioning may disadvantage small providers and result in young people missing out on the full range of opportunities for reasons of ease of administration. Issues of how LAs can best deal with specialist providers and those with huge geographical spread – Newcastle College is the most obvious example – remain to be addressed. 6 Do you agree with the proposed approach for Learners with Learning Difficulties and/or Disabilities?
√ Yes No Not Sure
Comments: It is vital that the hard-won rights of learners with learning difficulties and disabilities are preserved, and that quality of provision for these learners is assured regardless of accident of geography. 7 a) Do you agree that local authorities should be responsible for commissioning provision for young offenders in custodial institutions? Yes No √ Not Sure Comments: There is already substantial discontinuity in offender learning. Young offenders need greater coherence of provision, tracking and support. We are unsure how the model would work to ensure this, but strongly agree that one ‘home’ organisation dealing with young offenders wherever they are located has the best chance of success.
7 b) Do you favour the ‘host’ funding model, or the model where ‘home’ authorities are charged? Host Home √ Not Sure
Comments: Our inclination is to support a ‘home’ authorities model that would parallel the HE system – however, this is a technical issue on which we have no great expertise. 7 c) Are there planning or legislative levers other than funding systems which would create the right responsibilities and incentives to promote the best outcomes for this group of young people? √ Yes No Not Sure Comments: Much broader curricular and pedagogical issues must need to be considered in planning and legislation to ensure the best outcomes for young people. Most particularly, the opportunity afforded by the proposed raising of the learning leaving age in 2013 for us to review the effectiveness of the current system in meeting the needs of all young people must be grasped, and examples of good practice - including from initiatives like the Increased Flexibility Programme, the ending of which is a matter of regret - shared much more effectively across the country.
Chapter 4: Management of the system Do you agree with: 8 a) Proposals to ensure that informed learner choices should be a key part of shaping the system? √ Yes No Not Sure
Comments: We believe very strongly that informed choices by young people should be a key part of the system – but feel that the crucial word here is ‘informed’. If we are to avoid a cycle of privileged young people having access to the full range of choices while looked-after and other traditionally disadvantaged young people do not, we must improve the effectiveness of IAG for both young people and their parents/ guardians. 8 b) The proposed approach to a common performance management framework based on the Framework for Excellence?
√ Yes No Not Sure Comments: We have some concerns about the Framework for Excellence, and in particular the continuing emphasis on qualification outcomes at the expense of value added and other indicators – however, we do agree that a common performance management framework is important. 8 c) The local authority role in commissioning to improve quality? Yes No √ Not Sure
Comments: We have some reservations about this in the light of the very limited capacity of most LAs at present to engage with the quality agenda in post-16 learning. We feel that this responsibility should be introduced on a tapered basis if at all, with strong support from the national agency (or preferably retention of LSC – see above.) 9 Do you agree with the proposals for managing changes to 16-19 organisation and adjusting the arrangements for 16-19 competitions and presumptions? Yes No Not Sure Comments: We do not have sufficient current expertise on competitions and presumptions to respond to this question.
Chapter 5: Funding Are you content with the proposals: 10 a) To retain a national funding formula based closely on the existing one? √ Yes No Not Sure
Comments: 10 b) For funding to flow to institutions on the basis described? √ Yes No Not Sure Comments: Broadly yes, but we have no specialist expertise in this field. 11 Would you support a move to a single national 14-19 funding system? √ Yes No Not Sure
Comments: We believe it is vital that the government creates a single 14-19 budget to underpin the creation of a credit-based 14-19 qualifications system (as suggested in the 14-19 Qualifications Strategy consultation paper). In line with the raising of the learning leaving age to 17 in 2013/14, we would urge the government to introduce an integrated 14-19 funding system and a credit- based 14-19 qualifications system in 2011/12. Today's Year 6 will be the first cohort having to stay on in learning in 2013/14. When this cohort reaches Year 10 in 2011/12, a flexible 14-19 funding and qualifications system will be important to ensure that we can accommodate the needs of all young people at 17. We cannot allow funding and qualification inflexibilities to turn this cohort off learning and become truants rather than NETs (Not in Education or Training). 12 Do you agree with the proposals for capital funding? Yes No Not Sure Comments: We have little involvement in capital funding so would not wish to respond. Chapter 6: Implementation 13 Do these proposals about timescale and transition appear reasonable? Yes √ No Not Sure
Comments: We are unsure that LAs can develop the levels of expertise they need within the timescale allowed. We remain concerned that the transition to a ‘slim’ national agency, alongside the inevitable attempts by LAs to recruit existing LSC staff to build up their knowledge base very quickly, may have a destabilising effect and prove costly. Chapter 7: Reforming the post-19 skills system to secure better outcomes for adults 14 Do you agree with the proposal to create a new Skills Funding Agency to replace the Learning and Skills Council post-19?
Yes √ No Not Sure Comments: We would prefer to see the LSC retained, with an advisory and support role for LAs pre-16 and a broader learning & skills role post-16. This would have the following advantages: 1. retaining the continuum approach to learning that will underpin the lifelong learning culture on which we depend to realise the Leitch ambitions, rather than establishing completely separate pre- and post-19 systems 2. ensuring continuity of service & support during the transitional period 3. massively reducing transfer, TUPE, recruitment and setup costs for new agencies, allowing maximum funds to be spent on learners 4. retaining expertise of LSC staff within the publicly-funded system rather than losing this to consultancy, private firms or to careers outside the sector 15 Do you agree with the proposed role of the Agency?
Yes √ No Not Sure
Comments: Its role is too exclusively skills-focused. The current DIUS consultation on Informal Adult Learning demonstrates that lifelong learning comprises much more than simply vocational skills leading to full qualifications that meet the needs of employers, and that a rich variety of other types of learning is needed to complement VQs, to build confidence and provide routes into these, and to contribute to health, wellbeing, cohesion and social justice. Retaining one agency with responsibility for overseeing the whole of post-19 learning would allow effective links to be fostered between these areas. Chapter 8: Funding and commissioning 16 Do you agree with the funding and commissioning role proposed for the Skills Funding Agency?
Yes √ No Not Sure Comments: We would prefer to retain a body that oversees both adult and young people’s learning and has a broader focus than simply current vocational skills needs. 17 Do the proposals in this chapter reflect the right balance of strategic commissioning and individual customer choice? Yes No √ Not Sure
Comments: This is a difficult balance to achieve, but issues around respective responsibilities for planning vs funding must be teased out if the system is to work effectively. Establishing bodies with no planning remit but funding responsibilities has been shown to be counterproductive and should be avoided in future. Chapter 9: Sponsorship of the FE system 18 Do you agree with the proposals on performance management and the performance intervention role of the Skills Funding Agency? Yes No √ Not Sure Comments: We believe a body that can support performance improvement and intervene if necessary is needed, but we would prefer it to have a much broader strategic approach to what is meant by performance in the context in which each provider operates.
19 Have we got the right approach to sponsorship of the FE sector as a whole? Yes √ No Not Sure
Comments: Government documents still tend to present the FE sector as having a largely ‘remedial’ role, working primarily with young people and adults who have not succeeded pre-16. While FE does this well, it does so much more which does not appear to impact on government consciousness. Government also has a tendency to tie the FE sector up with red tape and impossible funding regimes and then criticise it for lack of flexibility! We would like to see the government’s sponsorship of FE running much more parallel to its relationship with HE – as a partnership of equals in constant discussion and negotiation, each with its own distinct role and areas of expertise, working for the benefit of young people and adults across a broad spectrum of learning.
Chapter 10: An integrated system: other functions of the Skills Funding Agency 20 Do you agree that each of the functions in this chapter should be performed by the Skills Funding Agency? Yes √ No Not Sure Comments: See our broader reservations above about the role of the proposed agency. Chapter 11: An integrated system: how the Skills Funding Agency fits into the wider skills landscape 21 Do you agree with this description of the wider skills landscape within which the Skills Funding Agency will operate?
Yes √ No Not Sure
Comments: Once again, while we recognise the vital importance of the skills agenda and have long worked to enhance learning opportunities in the workplace, we are concerned that an excessive focus on skills without recognition of the broader social and cultural context in which this work takes place will ultimately cut off the branch on which the skills system sits, reducing throughput of potential learners in the system and limiting the potential of the system to contribute to broader agendas such as regeneration, cohesion and social justice. 22 Have you any further comments?
Comments: We would urge government to review responses to Parliamentary questions recorded in Hansard on the amounts spent in recent years on reorganisation of bodies in the learning and skills sector. Government should assess realistically what has been achieved from this before embarking on further structural change, which may prove ineffective in improving the experiences and opportunities available to learners, may destablise the system (something which concerns government when applied to HE but apparently less so for FE) and extremely costly, using up resources which would be more usefully spent on learners.
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