Arrangements for Funding Adult and Community Learning from 2003/04

A draft NIACE response to the LSC Circular 02/16.

NIACE welcomes the publication of this Circular which has been long awaited by the institutions delivering adult and community learning through funding allocated to Local Education Authorities. We have been grateful for the opportunity to contribute to the development of the ideas within the Circular through our membership of the LSCs consultative groups and believe that the continued existence of such groups is important in this developing area of work.

It is good to see in the section on context and background a re-iteration of the Council’s commitment to a wide range of adult and community learning (ACL), including learning for personal development, which NIACE believes, makes a significant contribution to the development of a learning society. However, NIACE recommends strongly that the Council follows this Circular by giving priority to the elaboration of a policy document on the purposes of adult learning, backed by a strategy to secure reasonable provision in each local LSC area.

We believe that the Circular highlights the very real issues that have arisen from conflating a funding stream with a way of working. The term Adult and Community Learning has come to be too closely associated with local authority provision. All institutions working with adult learners outside the national qualifications framework will need to grapple with the issues raised in the Circular. We appreciate the dilemma faced by the Council in needing to secure stability in the system for local authority adult learning services, but believe a policy framework is needed that embraces the totality of this provision as an essential precursor to the development of a funding formula attached to a particular funding stream. This policy will make clear the purposes for which this provision is to be funded.

In this context, and as a first stage in such a process, we particularly welcome the recognition that the issues raised within the Circular are relevant across all sectors funded by the LSC. The LSC’s commitment to breaking down the barriers between sectors currently created by the different funding streams managed by the Council will lead to a better recognition that adult and community learning is not only confined to the LEAs and the bodies they fund. A wide range of organisations funded by the Council delivers such provision, including the WEA, the Specialist Institutions and the long term adult residential colleges, which are not mentioned in this Circular. Much of what is in the Circular - particularly those aspects specifically related to learning outside QCA’s qualifications framework should have direct relevance to provision in other sector institutions, particularly in FE Colleges where a very significant proportion of work with adults lies outside the qualifications framework.

The section on the current arrangements for delivery and the results of the data collection exercise accurately describes the challenges that are to be faced in the move to the national formula. In the section on delivery arrangements we believe that few colleges of FE recover the real full costs of this kind of work from learner fees alone. Many colleges, like many LEAs, recover the direct teaching costs through fees, but we believe that in many colleges the costs of the marginal amount of additional infrastructure necessary for ACL are met through their LEA grant, or from other funding sources or subsumed within overheads.

We think that the timetable of activity necessary for the issue of allocations in February 2003 is extremely challenging, but we appreciate that if 2003/04 allocations are to be based on sound data and due to include a wholesale transfer to formula funding, such deadlines will have to be met. The LSC, given the contents of the Circular and the scale of the task, may wish to revise its views on what it is possible to achieve in 2003/004, while remaining committed to a transfer of most adult and community learning to the national formula over time.

We are clear that a proportion of ACL work does not fit into a funding formula. But in making a judgement on this issue the LSC will also want to take into consideration work of a similar kind is that is being done by other sector institutions. The issue is again not simply confined to the LEA sector. We need to see a policy in place that enables institutions of all kinds involved in innovative development work with hard to reach learners to be funded properly for the very real costs entailed. A funding system that can operate without the sort of burdensome audit that de-motivates learners themselves and the staff seeking to work with them. We believe that a strand of funding for developmental work, available to all providers with the experience and capability to carry it out, and placed under the control of the local LSCs would do much to open up access further.

We believe that it is important to recognise as indicated in the Circular that funding is not the only lever in ensuring a range of high quality provision in learning. Planning, quality improvement strategies, inspection and performance reviews all have their part to play in this process.

We understand the desire for a useable typology to help the LSC nationally and locally to plan provision. We are however, concerned to see the issue considered as subsidiary to a funding model, rather than as part of a worked through policy. A new framework for describing adult learning and an approach to recognising achievement are very significant for the future development of adult learning and we believe that each warrants more reflective consideration in their own right. As it is, we do not feel that the typology outlined in this Circular equips those involved to carry out this task.

We understand that the new guidance to the inspection of ACL issued by the ALI contains some useful material to inform thinking on this question, but any simple typology adopted is susceptible to crude interpretation at the hands of those with limited understanding of adult motivation and patterns of participation. We look forward to an ongoing debate with the LSC nationally, local LSCs and other interest groups in the field on this issue.

We hope that, as with achievement, there will be an opportunity to get planning guidance right rather than rush to implement an inadequately developed framework that cannot deal with the motivations and aspirations of individual learners who are the heart of the LSC’s system. The success of planning in this area will depend on the understanding of those within the LSC system of adult learning offered within communities and its capacity to motivate and encourage learners as well as to provide a wide range of opportunities that contribute to a learning culture in any given area.

With regard to the issues in the circular that relate to sub-contracting and direct funding we appreciate the desire not to impose a national approach on local delivery arrangements. However we hope that the LSC will consider providing guidance to its local offices on both the strategic role of local authorities and the need to make connections between informal learning of the kind delivered through libraries, social services and leisure departments and the more structured educational opportunities delivered through LSC funded provision. It is important to ensure that these connections remain in place even if locally, contracting arrangements cease to be run through the local authority.

NIACE is enthusiastic about the paragraphs on a planning led approach. This seems to indicate a wish to reduce bureaucracy while still maintaining an accountable system. The proposals for the revision of the LEA Adult Learning Plan seem to be moving in the right direction to achieve this. However, as stated before, local planning is only as good as the people involved. We feel that there is still some work to be done in developing an understanding at all levels in local LSCs of the important contribution adult learning delivered in the community can make to targets and to a civilised and inclusive society.

NIACE is wholly supportive of the LSC’s ambition to apply the national funding formula to ACL provision as far as possible. We believe that ACL has nothing to lose from being a part of the mainstream funding system of the LSC. However, it is critically important that the effects of such a move are understood and that accompanying national and local planning systems work well and value the contribution ACL can make to LSC and DfES targets.

We particularly welcome the indication in paragraph 67 that the LSC will seek to develop more equity and consistency in the delivery of adult and community learning to get rid of anomalies in access based purely on where learners live. Local LSCs with an overview of all provision in their areas, together with all the players in the delivery of ACL are uniquely well placed to play a key part in this process. We hope that in such a process the LSC will endeavour to grow provision where it is currently inadequate, rather than cut back where there has been a pattern of more generous funding, particularly considering the history of reduction and underfunding of ACL in most of the country.

NIACE, with a long history of engagement with local authority secured adult education, recognises the challenge that the wide variation in current investment poses when introducing a uniform funding formula. We appreciate that there must be investigation of the reasons for the different relationships between investment and volume of activity. It is particularly important that this relationship should be understood, because the underlying causes of such discrepancies, may include some authorities’ commitment to anti-poverty strategies and the consequent high cost/low volume work designed to attract hard to reach learners.

It is also important that the system is not de-stabilised to the extent that learners’ opportunities are compromised. NIACE is therefore pleased to see that the LSC will take account of the need for stability in the system while remaining committed to a more equitable funding system for non-accredited work wherever it is provided.

We share the LSC’s view that given the limits on available public funding, those who can make a contribution to the costs of their own learning should be expected to do so. If this is to be the case, very thorough investigation needs to take place on current charging policies. It would not be appropriate to simply average out across the country.

We believe that when these higher fee expectations are considered, particular attention should be given to what fees are currently charged in low wage areas of the country as opposed to high waged areas. Because the pattern of delivery is so varied across the country, an averaged fee might mean that applying the same expectation in low wage areas might be too high. This would not necessarily be compensated for by either remission or by the disadvantage element. We wonder whether higher charging services with very high learner numbers may be concentrated in the south of England meaning that the average fee contribution may not represent the pattern in the north adequately. Wages in the public sector are subject to national negotiation and are not solely a matter of local discretion, which may well mean that savings on costs to balance lower fee income may not be possible. This information, alongside other detailed studies of charging not available in a general fees survey, should be investigated before any percentage fee expectation is fixed.

We appreciate the difficulty in obtaining reliable data and believe that the LSC should publish as early as possible the proposed specification for ILR data for ACL for consultation to avoid the data issue running into 2003/4 when authorities will be expected to produce ILR data. This is a matter of extreme concern to those working in institutions delivering ACL.

We are most encouraged by the section in the Circular that relates to future developments. Data will improve with the introduction of the Individual Learner Record in work funded through the ACL budget. We hope that simple data will be collected and look forward to consultation on this issue. We would reiterate the point that the issue of what is to be included in the ILR is now a very urgent one. If the LSC wishes authorities to be able to provide accurate and timely data the specification for the ILR should ideally have been issued before now. The LSC is aware of the low base from which some authorities have in the area of MIS and we really believe that the specification should have been discussed and dealt with much earlier than this autumn.

With regard to the options presented in Annex B, NIACE would wish to express the opinion that so far as options for the Fee Assumption element are currently configured, we would broadly favour Option Three. However, we wish to make a clear proviso that much more work would need to be done to assess the percentage to be chosen (we believe that the 40% example may be very much too high) and that time should be spent on this using solid data.

We would favour a national policy for fee remission, but we would like to see some expansion of the categories to include at least a partial remission for older learners and wider access to remission for adults with disabilities. We see no reason why this should be confined to LEA secured adult learning or indeed non-accredited provision. We would not favour a system of completely locally applied remission and consider the locally determined approach to provision and fee assumptions outlined in option four has the potential to result in the same differences in investment in this area as the current system. We would still wish though to retain local flexibility to decide to waive fees as part of particular promotion projects or targeted development work.

So far as the Achievement Element is concerned NIACE has been working with the LSC and LSDA to develop more robust systems for recognising achievement where there is no external accreditation. This is an area where we believe all the LSC’s levers for planning and improving the quality of provision should be brought into play. We do not consider that the need for auditable evidence on the achievement of individual learners should be the main driver in developing systems to ensure that learner achievement is recognised. To repeat our earlier point, funding is not the only lever in improving quality and levels of achievement. Indeed experience in FEFC provision has shown quality assurance, inspection, and advisory support to be more frequently powerful in this area. We are also aware that much of the learning in question is short term and part time, and needs a light touch in terms of data collection and form filling. We know from our recent research that many learners have reservations about having their learning assessed externally, placing more value on the views of their tutor, their fellow learners and on their own self knowledge.

We believe that there is much more work to be done in this area, which affects virtually all providers in the LSC system. This is not the time to impose systems for recording individual achievement in a way that fits with financial audit by those whose training is in accountancy not education.

We feel very strongly therefore, that Option Three - offering a reduced funding rate to ACL is unacceptable to us. It re-introduces Schedule 2 and it denigrates non-accredited learning and the learners who are engaged in it. We do not know of any reliable studies that indicate that the costs of non-accredited learning, properly delivered to national standards are necessarily lower than examination classes. If there is to be no achievement element in this provision, we would assert that the case for the full funding element to be paid on completion is equally as valid as deducting it from the funding. The burden of proof should surely be on showing that learners have not achieved rather than assuming this to be the case. If providers are quality assured and inspected, then one must assume they are competently delivering learning within which individual learners will reach their goals.

Because of this we would favour Option Two, being chosen for payment of an achievement element at the present time. This offers a sensible way forward, at least in the medium term, for both providers and for the LSC. We do think however that some means will be needed to ensure independent judgements are made on providers systems and we welcome the suggestion that the inspectorates will be included in this process.

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