Raising Standards in Post-16 Learning:

(para 8)/Chapter 1

We agree that all suppliers must be subject to the same degree of rigour in relation to quality assurance. However, the consultation document notes that the Common Inspection Framework will form the core of the LSC and ES requirements and expectations. NIACE is concerned to see the reference to the Inspection Framework having a clear focus on learner achievement. While this is vital, it is also important to recognise the wider benefits of learning and learning outcomes other than qualifications. We would want the expectations on providers to relate to the broad learning outcomes relevant to widening participation, personal development and community growth – and not just qualifications.

NIACE warmly supports the notion that the DfEE retain lead responsibility for the development of qualifications for ‘post-16’ teachers and trainers, and that a framework for standards and qualifications for staff in adult and community learning be developed. We look forward to working closely with PAULO to develop these standards.

In our view there is insufficient reference to new suppliers of education and training, and to the voluntary sector and neighbourhood organisations. Such organisations must be supported effectively if the agenda of neighbourhood renewal is to be addressed. This would be a key role for the local learning partnerships and the local LSCs.

It is not made sufficiently clear that the LSC itself will have a key role in quality improvement under the section on the role of the LSC in the main document (paragraphs 5-13 in chapter 2).

The relationship between the local learning partnerships and the LSC will be crucial. The role of lifelong learning partnerships is not addressed fully in the document. Nor are they mentioned in the second funding document. We have made this point in our early response on the latter.

There is insufficient mention of the relationship between the new Best value Inspectorate and the new Adult Learning Inspectorate in LEAs. If LEAs are not to be confused or swamped by the audit culture, care and sensitive planning will be needed.

On the other hand the arrangements for LEAs are spelt out clearly, and their role.

It would be useful for LSCs and the ES to establish benchmarks and performance data for suppliers. However, NIACE cautions against seeing such data as the only proxy for quality for the reasons mentioned earlier: there is more to achievement than qualifications.

Insufficient mention is made of the role of voluntary organisations or LEAs in table 2 in chapter 3.

Insufficient mention of LEAs’ own centres and residential colleges, which is a kind of subcontracting.

NIACE supports the comments made about suppliers and the requirement to have:

including,

No mention has been made of ‘Best Value’ approaches, which LEAs are expected to respond to. It would help if the fuller picture was understood.

NIACE notes the inspection framework is also to be the basis for the self assessment report. It will be necessary to ensure that the Framework is absolutely right for adult learners as it will be for young people.

It is inevitable that those suppliers most used to inspection, data return, and self assessment will have an advantage over those suppliers who have not done this before. Self assessment alone involves a steep learning curve in which suppliers will have to weigh up strengths and weaknesses with limited knowledge of the quality of other provision elsewhere.

Appendix 2: the statement of learner entitlements is a helpful development but should not displace some of the quite sophisticated student charter work already done by some colleges and LEAs and requires further development. It would also be helpful to add in a stronger mention of educational guidance (not just ‘assessment’), and the entitlement to help towards employment, training or further learning opportunities as appropriate. We recommend that all learners are covered by this statement when it has been finally developed and that the Statement is issued by each supplier. The inspectorate should monitor how learners’ entitlements and responsibilities are being delivered, during their regular inspection. Each supplier should develop their own statement starting from the national Statement, which should be seen as a core set of entitlements for all. The local LSC should help new and existing suppliers to keep statements under review as part of the self assessment process.

One of the key issues is to ensure that all learners are aware of these entitlements and this requires a staff development programme. Similarly, many students will find access to the Statement of entitlements difficult; we will need to help suppliers to ensure that such a Statement is translated, simplified and taped, in order to reach students with disabilities.

NIACE fears that nothing will reduce the administrative arrangements for suppliers.

We welcome the intention to proceed carefully with the development of the proposed core information requirements and to take account of different types of provider and the diversity of learners’ needs and objectives. This is crucial if more informal, community-based provision is not to be over-burdened with inappropriate requirements.

The indicators themselves are comprehensive but will need to take greater account of the more episodic and disrupted character of some types of provision (for example ‘first steps’ programmes and some work with adults with learning difficulties or disabilities) particularly in relation to how retention is to be interpreted. Recognised outcomes will need to be sufficiently broad to accommodate learning gain from non-accredited provision and to take account of unanticipated gain.

Sometimes in order to address participation and social inclusion objectives it is not appropriate to collect data in the same format. There is a strong need to recognise this early on. The use of other indicators of achievement other than qualifications and attendance, for example, must be accepted.

While performance tables in relation to young people and their A levels might be useful in some circumstances, NIACE can see no real purpose in comparing figures between groups of qualifications or between groups of adult learners in different parts of the country. Their only usage has been to provide indicators which some think are helpful during inspection. However, these have often been flawed and do not help suppliers to improve quality. It would be more helpful to look at measures of ‘value added’ and the ‘distance travelled’ by learners.

Comparative performance tables are extremely problematic in relation to the diverse and complex nature of adult learning provision, with its vast array of contexts, purposes, providers, curricula and learners. Comparing like with like and contextualising data sufficiently to make it meaningful will be a difficult and contested process.

We welcome the principle of inverse proportionality as a basis for determining the frequency of monitoring visits. Also very pleased to see the intention to support and develop the capacity of (some) suppliers who need to improve their performance. More detail on how this constructive process will roll out would be useful along with a clearer sense of the points of transition between support and sanction.

In monitoring supplier delivery arrangements, the evidence required for assuring contractual and funding compliance, continuity of provision, value for money and financial arrangements will need to take account of the size and capacity of suppliers, particularly in relation to smaller and newer providers.

We think that such arrangements should continue given that strong and positive improvements follow the journeys that providers make towards accredited status.

What matters to adult learners is that there is a rigorous system for accreditation, that it applies to all suppliers equally and that mechanisms for accreditation should not depend on the size and wealth of an organisation. The Investors in People Award (IiP) has proved that organisations can be effective learning organisations if there is a commitment to this from managers. Similarly, NIACE’s view is that such arrangements should also support small and medium sized employers. The same should apply for education and training providers. Like IiP there should be no benefit other than the status of the award and more reasonable inspection monitoring arrangements.

In order to sustain comprehensive quality improvement and an "open, fair and competitive learning and training market" it is essential that approved/preferred supplier status should apply across all post-16 publicly funded provision. We would endorse the intention to incorporate this into the supplier review process in order to minimise the work required of suppliers to achieve this.

NIACE strongly welcomes the idea of extending a Standards Fund to all types of suppliers in order to encourage the development and sharing of good practice across the broad range of provision. In terms of how this is delivered there might be an argument for doing this on a sector basis rather than as one national fund to ensure maximum responsiveness to their particular requirements.

Investment in improving marginal or unsatisfactory provision should take account of

Expertise from within or attached to the LSC in key areas such as

It is essential that suppliers should have as much advance knowledge as possible of the long-term information requirements of the LSC. This will help them to prepare themselves and to have confirmation of the exact requirements that will operate for 2001-02 pending the introduction of the Individual Learner Record system from 2002-03. The same would apply to the new quality and inspection requirements that are also expected later this year.