Organisation and Policy: Influencing Public Policy: Selected Policy Papers |
A NIACE Response
Published March 2000
The National Institute of Adult Continuing Education (NIACE) welcomes the opportunity to respond to the DfEE’s consultation paper on compulsory teaching qualifications for teachers in further education. NIACE is a registered charity (no. 1002775) and company limited by guarantee (no. 2603322). NIACE’s broad aim is to advance the interests of adults as learners and as potential learners. Our strategic plan commits us to "support an increase in the total numbers of adults engaged in formal and informal learning in England and Wales; and at the same time to take positive action to improve the quality and quantity of opportunities; and to widen access to learning opportunities for those communities under represented in current provision."
NIACE (the National Institute of Adult Continuing Education) welcomes this consultation paper and warmly supports the Department’s direct approach to driving up standards.
In addition to it’s individual members, NIACE has more than 220 corporate members drawn from all local authorities’ adult and community education services, a large number of Further Education colleges, Universities, Training and Enterprise Councils, broadcasters, voluntary organisations and trade unions. Our closest links to the government are through the DfEE and the office of the Welsh Assembly, although the Ministry of Defence is also in membership, as is HM Prison Service at the Home Office, DfID and DCMS.
As well as advocacy, research, development and consultancy, NIACE works to secure informed debate on topics relating to adult learning through an extensive programme of conferences and publications. We co-ordinate the annual UK Adult Learners’ Week each May. Of relevance to this paper is NIACE’s commitment to improving the quality of learning opportunities for adults, wherever they are learning.
The Minister’s letter, dated 10th February, states that the paper was produced following detailed discussions between the DfEE staff and "key partners involved with, or associated to, further education". NIACE was disappointed not to be included in these discussions, since adult learners constitute a significant majority of the beneficiaries of further education.
The White Paper, Learning to Succeed, makes clear that the role of the new Learning and Skills Council will include funding the provision made for adult learners in part-time, community based and neighbourhood settings in order to enhance social inclusion and to widen participation. The statement in paragraph 4 of the consultation paper is that the LSC’s quality improvement strategy will include our expectation that all staff in "post-16 education and training" will hold appropriate qualifications. This continues the promise in the White Paper to consult on "the development of a range of qualifications for all post-16 teaching and training staff." NIACE supports this intention and considers that the discussion paper applies to all staff, whether they work in a further education college or not. The assertion in paragraph 6 that the paper covers "teachers in the FE sector" is misleading, given that there is no definition of the "sector." Again, NIACE makes the assumption that the "FE sector" means all those in post-16 education and training. Care will need to be taken in future documents to make the scope of the requirements in a much clearer way.
NIACE has two key concerns about the document. First, the paper fails to define "further education" and NIACE considers that this results in the risk of a misleading and unhelpful narrowing of focus. The full range of teachers, mentors and tutors needs to be taken into account, particularly those working in prisons and those in community based settings, managed by voluntary organisations or in co-operative endeavours, as well as those in further education. The scope of the consultation needs to be defined to include them. NIACE argues that all teachers in the post sixteen sector should be included and not just those in FE colleges.
Second, only FENTO, as the NTO for further education colleges, is named. NIACE is particularly concerned that PAULO, the national training organisation for community based learning and development is included in development work. PAULO was recognised in January this year. Other NTOs such as THETO, NCVO and ENTO also have a key role to play, which needs recognising, as do the learning and teaching contexts these NTOs encompass.
C1) Do the skills, set out in Annex A cover in aggregate what a teacher working across a full range of responsibilities should be able to cover in a full first teaching qualification?
Yes, NIACE agrees that these skills are broadly those that would be helpful to a teacher in a first teaching qualification. However, we recommend that:
| G2 at initial level should include commitment to subject knowledge and skills. |
| G1(d) the words "and subject" should be added. |
| B3 at all levels needs to include the skills and knowledge involved in facilitating learning with community organisations which could be described as "community consultation," "capacity building" or educational development work. |
C2) Is the split between the skills an appropriate use for delivering the introduction, intermediate and threshold qualifications distinguished above?
Yes, given the statement that teachers will be expected to perform at different levels according to the training stage. However, for teachers working in community-based adult learning settings some of the "facilitating learning" roles (eg: B3 see above) will be needed at all levels.
C3) Should all qualifications be required to contain elements covering key skills ?
Yes, in theory, but there are a minority of specialist teachers who may be prevented from achieving a teaching qualification through lacking some elements of key skills. For example, an effective and successful mother tongue language teacher or the profoundly deaf British Sign Language tutor. There will be inevitable problems in expecting all levels of key skills at all levels of teacher training could exclude some valuable subject specialists. It may be helpful to encourage key skills at all levels, but have some exceptions at initial level.
C4) Is an immediate qualification of the full City and Guilds 7307 type the right point at which to pitch such a requirement?
Yes, NIACE considers this appropriate. At intermediate level, we consider only to level 2 Key Skills in Communication, and at threshold level, Communication and IT at level 2, bearing in mind that there are resource implications.
D5) Should all full-time FE teachers be required, in principle, to have a threshold qualification?
Yes, NIACE supports the proposal, but suggests that accreditation of prior learning (APL) should be possible.
D6) Should existing possession of a PGCE, B.Ed or Cert.Ed (FE) provide automatic exemption?
Yes, in principle, NIACE supports this proposition, but the qualification has to be relevant for the area in which the teacher is working. If not, provision for top-up modules should be available. For example, NIACE is aware of many teachers who are appointed to teach adults without having done any professional training to help them move from teaching children to teaching adults. The pedagogy is different and adult teaching is a different professional challenge from working with pupils.
D7) Should credit be given to existing possession of a City & Guilds or other qualification?
Yes, NIACE has always supported specialist training for teachers of adults. In many ways the C&G 7307 qualification in its two parts has a sound track record. We would also wish to see other qualifications properly mapped against the C&G 7307 so that more choice was possible. Some specialist subject areas have their own curriculum for teacher training which needs to be taken into account and for which some credit should be given. For example, Teaching English as a Foreign Language, English as a Second or Additional Language, fitness teaching or basic skills.
D8) Is two years an appropriate time within which new full-time teachers should be expected to achieve a threshold qualification?
No, NIACE believes that three years would be more appropriate. If a new full-time teacher can complete a threshold qualification in three years it will mean an extensive part-time programme. The first year of learning is always very challenging. To start such a course during the first year allows the teacher to complete the two year programme in the middle of Year 3. In addition, initially, there will not be enough Cert.Ed (FE) course capacity and this will allow the whole programme to be better paced.
D9) Should there be any exemption from the threshold requirement for existing unqualified full-time teachers? If no, what criteria should operate?
NIACE suggests that there should be no exemption from the threshold requirement provided that credit can be given for prior experience (as mentioned in D5 above).
NIACE is disappointed to read in Section E that only teachers working in FE colleges are the subject of the report. Given the range of the learning and skills agenda this narrowing of focus is unfortunate. The proposals should be amended to bring in teachers who are not working in a college, or are working in a college as well as an adult education service. In the latter case, ‘a portfolio’ teacher working in a college and a community centre is common. A fourth bullet point should be added at paragraph 22
| people who also teach in continuing education, adult education, ‘extra mural’, ‘voluntary’ or community-based settings. |
This error in the document calls into question the scoping exercise undertaken by FENTO, in paragraph 23, and the conclusion in the paragraphs thereafter. NIACE is aware of many full-time and part-time teachers of adults who do not work in a college of FE.
E10) Should all part-time teachers be required to obtain the same level of qualification as full-time teachers? If so, how should arrangements for credit, exemption and timescale compare with those for full-timers?
NIACE believes that the way to answer this question is from the point of view of the adult learner. Each student should be able to expect his or her teacher to have had a period of training in which they have had to achieve national standards in teaching adults. This is the point made in paragraph 24. The only argument against this is cost and administration. A central register would be required (or at least a "DfEE registration number system"). NIACE recognises the scale of the challenge and agrees that in the short term the intermediate level qualification should be held by a part-time teacher provided
| they are not employed to work a full-time load overall (whoever they may hold a contract with). |
| if they are unqualified that it is started in the first year of qualification and completed within three years. |
| over 10 hours a week on one contract: the teacher should be working to a threshold qualification. |
The part-time teacher should expect to hold the C&G 7307 or equivalent within four years of taking up the part-time post. NIACE sees a risk in forcing all part-time teachers to undertake a Cert. Ed in that it undervalues the importance of bringing in ‘fresh blood’ to adult education where teachers have traditionally brought in an important skill or expertise.
E 11) Or should part-time teachers be set a lower requirement, and encouraged to progress further on a voluntary basis? If so, what should that requirement be and what arrangements should there be for credit, exemptions and timescale?
NIACE maintains that all adult learners should be able to expect a minimum level of training in their teachers, and recommends that all teachers employed for regular weekly teaching of four hours or more should be required to complete the Intermediate Stage (full C&G 7307 or equivalent). NIACE recommends the timescale be:
Initial level: within one year
Intermediate: within three years
Threshold: within five years.Funding will need to be made available to support this teacher training institute, including on-course support, so that access to training is equitable with full-time teachers.
Current policy in most LEA-provided adult education is to insist that all part-time teachers undertake initial training. In some LEAs possession of a Cert. Ed for teaching children is not regarded as a qualification for teaching adults. In other LEAs those teachers with a C&G 7307 or equivalent are paid slightly more per hour than those not qualified to teach adults.
E12) Or should distinctions be made between different categories of part-time teachers, for example by function or by the number of hours worked?
NIACE suggests that teachers working for more than ten hours a week should expect to be working towards a threshold qualification. No distinction should be made between someone teaching two hours a week and who is also working full-time, and someone teaching two hours a week who does not work full-time. "Voluntary teachers" should be expected to undertake a minimum level of training, perhaps 30 hours (as in the Initial Certificate for basic skills tutors). In all the above cases, the students have no control whether their teacher is employed in a local university during the day, or unemployed or retired. To them, what matters is that their teacher has a sufficient level of training to do a professional teaching job, as benchmarked against a national standard. The suggestion that a teacher working as an adult education tutor for two hours a week should be less well qualified than someone working as a college lecturer is invidious. Both can make or mar the learning process for adults and both can make a substantial difference for good or ill to peoples’ lives. Both require sufficient training. The "survival kit" (introduction qualification equivalent to C&G 7307 Part 1) should only be seen as a "taster" course for those in their first year of teaching.
F13) Is there a need for a separate set of standards and qualifications for teachers of basic skills?
NIACE supports the conclusions of the Moser Working Group called A Fresh Start in relation to teacher training. However, NIACE also reminds the Department that there has been no public consultation on the final report, only the standards for basic skills and (now) the curriculum.
NIACE believes that there is a definite need for a separate set of standards and qualifications for teachers of basic skills. Other teachers, those working with adults with learning difficulties or disabilities in languages, fitness and English as a second or additional language also need qualifications.
F14) Should part-time and full-time teachers qualified to do the same stage in basic skills teaching?
Both full-time and part-time teachers of basic skills, NIACE believes, must have a minimum of Intermediate level training. This is just the same requirement for full-time and part-time teachers working with students with learning difficulties. Students perceive no difference between full and part-time teachers, and qualification to do the job should relate to the needs of adult learners, not the employment status of the teacher. It will be important to make sure that all Cert. Ed (FE) programmes include specialist elements on basic skills, as well as an element on disability or learning difficulty.
F15) Should a basic skills teaching qualification apply only to teachers who deliver nationally-recognised qualifications, or to all basic skills teachers across all providers delivering basic skills for learners?
No. Basic skills teaching qualifications should apply to all teachers teaching basic skills, not just those delivering qualifications. However, there may need to be specialist modules on basic skills within generic Cert. Ed (FE) courses so that all teachers understand what they should do if they are required to work with students, some of whom may have poorer basic skills. NIACE is concerned to point out that the notion of "basic skills teacher" may be narrowing, misleading and misunderstood. In education and training generally, many thousands of adults are learning basic skills as part of some other purpose (eg. health and safety, hygiene, catering etc).
F16) Should a basic skills teaching qualification apply only to new teachers? If not, what if any criteria should apply in relation to exemption and timescale to existing unqualified teachers?
No, all teachers. NIACE believes that credit should be allowed for prior learning as in all qualifications. The timescale for basic skills qualifications should be the same as for generic qualifications (see earlier questions).
G17) Should agency teachers be subject to the same qualifications requirement as teachers formally employed by colleges?
Yes, NIACE sees no difference in teacher qualification requirements between agency and college employed teachers. From the adult learner’s viewpoint the quality of the tuition does not depend on who employs the teacher.
G18) Should a limit of one attempt at their required qualification be imposed in the case of serving teachers. Are there any exceptional circumstances which might be taken into account?
There is no need to impose such a sanction, in NIACE’s view, because it is unlikely that those failing will want to take the whole course again, (paragraph 32). However, should a serving teacher following an in-service qualification course fail the qualification then there should be no restriction on attempts to pass the qualification. It is more important that everyone reaches appropriate standards than there is some sort of victimisation of those who fail. The only exception to this ‘rule’ would be where the teaching practice is irretrievably below standard. In which case, ordinary quality assurance sanctions will come into force. We need to see all teachers encouraged and enthusiastic about studying rather than terrified of failure. Lifelong learning is about building on strengths. Teacher training should exemplify the best of adult learning.
H19) The endorsement model in Annex B
NIACE sees no objection to FENTO being given the major role in ensuring standards of teachers in further education colleges. However, we would like to see the same expectation on PAULO for teachers in community-based settings.
NIACE notes the conundrum set out in paragraph 40 about inspection, but reminds the Department that all advice given to the Department, including NIACE's own, was that one inspectorate for all provision post-16 was the preferred option. This report recognises that although Ofsted may have extensive experience inspecting provision for children, and young people, and Cert. Ed courses for teaching in schools, Ofsted have little experience inspecting provision for adults and qualifications for teachers of adults. The best solution is also the easiest. The Adult Learning Inspectorate (ALI) should inspect colleges of further education as part of the mixed team with Ofsted, and take responsibility for teacher training courses where they are intended for teachers of adults.(b) Inspection
H20) Do you agree with the proposal that a professional body for further education, established by the sector itself, is the best means of implementing the qualifications requirement? If not, what alternative approach do you prefer?
NIACE strongly supports a professional body for further education, established by the sector itself.
I 21) What steps should be taken at the DfEE, LSC, individual college and other levels to ensure the active promotion of effective continuous professional development?
DfEE level: There should be grants to encourage provides of teacher training courses to include new teachers, particularly part-time teachers. Grants should be routed through the LSC to all education providers, not just colleges, so that teachers can be supported on in-service courses. Funding should also be available for training the trainers.
LSC level: The LSC quality improvement strategy must expect evidence of commitment to teaching standards (and qualifications) in institutional and service strategic plans. Such expectations should be made on all those receiving funds.
DfEE/LSC: Budgets should enable, support and encourage staff development programmes. Cost should not be a barrier for smaller providers and individuals wishing to undertake training.
Education providers: Colleges and other education providers should be subject to inspection monitoring, as mentioned above, in respect of teacher qualifications and training. We also suggest that small providers have access to registers of qualified teachers.
NIACE welcomes the report and urges the government to assist in the development of a national strategy for teacher training in the post-16 education sector. This is of crucial importance in achieving the high quality provision desired by all. However, NIACE urges the government to include in the strategy those teachers working with adults in community-based settings and to consult with PAULO, the NTO responsible for staff qualifications in this other related sector.
Peter Lavender
NIACE
March 2000
