Memorandum from Head-Line Communication
Most witnesses to the Select Committee represent
the views and interests of training providers with a "physical"
location. As a provider of quality Open Learning I am anxious
to redress the balance.
The greatest reported abuse of the ILA scheme
is attributed to providers of books, CD-ROMs etc, and the Committee
might understandably concluded that this type of training should
be discounted in future ILA plans. Open Learning can be badI
have seen some which is truly awfulbut my company has the
experience and track record to show that it can also be done well.
Forty per cent of UK homes are now 'net-connected;
good Open Learning is the only way to deliver consistently high
quality training via computer to such large numbers, and the ILA
scheme cannot simply ignore it. However, quality in distance learning
is essential. Effective quality assessment is possible, and the
techniques should be rigorously applied. (See later comments on
We would urge the Department to fully understand
the nature of training accreditation before making it a condition
for ILA support. An example might help. On payment of £3,500
any ECDL training can be "accredited" by the ECDL Foundation.
In practice this means that someone will cross-check the narrative
of the materials against the syllabus and confirm that every element
of the curriculum receives a mention. But simple consumer protection
laws already give that reassuranceif I claim my course
covers 100 per cent of the curriculum when in fact it does not
the Sale of Goods Act offers any consumer a simple legal redress.
"Coverage" is not the issue for students; what they
want is reassurance that after working through the training materials
they will understand the subject matter sufficiently to be able
to pass the exam. Yet on this the ECDL accreditation process is
Actually it's worse than this. The ECDL accreditation
in the UK specifically excludes any accreditation of the training.
To restate this: training accredited by the British Computer Society
for ECDL has passed no scrutiny whatever; the accredited organisation
has merely shown it can conduct examinations. Of course it's not
just ECDL: I urge the Committee to recommend analysis of any accreditation
scheme before accepting it as a criterion for ILA-funded training.
I turn now to more general views as a Learning
Provider to the ILA scheme. Several of the following comments
were the subject of meetings and correspondence between myself
and John Healey, and later with DfES staff in Sheffield in August-November
I had three initial concerns:
that the ILA scheme put me in direct
competition with a government-sponsored body (the ILA welcome
pack to students included a leaflet directing them to Learndirect).
that ILA rules allowed anyone to
call themselves a "Training Provider" and claim £200
in exchange for a cheap book or CD; quality accreditation, such
as the very rigorous University for Industry accreditation system
which we had passed, was ignored.
that the few rules that existed were
abusedstudents of other providers who should have been
charged 20 per cent of course costs were actually given £5
for simply signing a form; when we complained the ILA Centre (ILAC)
advised that payment of student contributions was at the provider's
We had spent around £500,000 building a
leading-edge training delivery system. Any hope of a return on
that investment vanished when we saw competitors with no investment
in the industry bribing potential customers to conspire with them
to defraud the Department.
In general we felt we were poorly served by
the ILAC. Some illustrations might help.
Our webpages offered a link to the ILA website.
In June we discovered the link was redirecting people to the site
of this competing Learning Provider. Although the problem was
admitted, no-one could tell us why it was happening or when it
would stop. So we had to have our webpages rewritten to stop them
sending students to our competitor's website.
The ILAC wrote to us explaining that they were
experiencing a backlog of ILA applications. Several hundred of
our students who made applications still hadn't received their
forms back after more than eight weeks. Eventually I called the
ILAC and was told that such applications over five weeks old should
be deemed "lost"; students should reapply.
The ILAC preferred learners to register via
the website; but online applications generated an incorrect form
(a student signing it would be committing perjury). We reported
this to the ILAC in February 2001. The ILA centre's advice was
that we should correct the error manually and return itwhich
meant the form was resubmitted for signature, causing further
delays. We refused to use online applications until this simple
programming error was resolvedwhich, at the time of the
suspension of the system it had not been.
Rule of three
This problem was summarised very succinctly
by another provider: "it was always clear that the helpdesk
guys had no idea on policy due to the varying replies. Any attempt
to get something in writing from them was also blocked. So we
always made very sure that we stuck with the most sensible and
auditable solution of the three variations on every question answered."
The ILA scheme meant all training (except that
aimed purely at the business market) had to be ILA-fundable to
survive; but to stay in business established, bona-fide trainers
had to fight arrivistes whose only interests in training was its
ability to earn them quick money for no effort.
Although government quoted the "success"
of the scheme in training millions heretofore disenfranchised
by formal education, in practice many received no such real benefit.
The fraud and the scandalous mis-selling had to be stopped, and
I endorse John Healey's decision to halt the scheme without notice.
Yet that decision had a profound effect on our business:
our core business serves people who
have been considering a course of study for up to a year before
committing themselves. ILA incentives distorted that natural flow,
and with its sudden withdrawal we face a bleak year before the
people who received bad materials
will be convinced that online/distance learning is not worth the
media it's printed on; it will be harder than before to persuade
the mis-selling has created a perception
that IT training in particular is "free". In fact, although
a lot of packages are "cheap", good quality is as expensive
as it ever was...
So we watch and wait. Learndirect continues,
with government backing, to promote IT training products (American,
Irish and Scandinavian but not British) both to individuals who
attend the government-promoted centres and to UK plc, via University
for Industry's corporate marketing arm.
It leaves us in a very difficult position. The
new, "human-feel" training system we have developed
in the UK at considerable expense, over many months, looks set
to die through government-created market recession, and in the
face of government-backed foreign competition.
I might suggest that the Committee recommends
appointing another administrator with a better grasp of database
management systems and computer security than Capita appears to
have . . . but that would be a glib proposal which I am sure many
others will make.
I understand the DfES has drafted a more rigorous
code of practice for Learning Providers. This will certainly help
ensure the integrity of the ILA scheme but the rules must be policed.
The following mechanisms can help monitor the behaviour of Learning
The ILAC should send a statement
direct to the student prior to funds release
This will tell a student that a Learning Provider
is about to access their ILA fund. If this accords with their
expectation all well and good, but if it comes as a surprise they
should have a mechanism to block the release of misappopriated
funds before their release to the provider. Moreover a statement
might be a good opportunity to invite students to assess (perhaps
via a questionnaire) how closely the training provider observed
the marketing code of practice . . .
A "Hotline" for students
who discover they have been exploited.
Rapid response is the best way to stamp out malpractice
in the field. A hotline can quickly generate the necessary intelligence,
and help protect the credibility of the system in the minds of
students. However it must be responsive; calls to the ILAC were
felt to be a waste of time.
A procedure for instances of malpractice
It would be helpful if Learning Providers
could give clear advice to frustrated students as to what form
of redress they have if their funds have been misappropriated.
We implemented our own scheme which we would like to have seen
made universalas it was we ended up training people for
Speeding up of processing; speeding
up rectification of fault reports
Delay and errors in the processing
of ILA applications causes confusion and plays into the hands
of fraudsters. Reported faults in the system which go unfixed
for months opens a door to abuse.
Dynamic Quality Assessment of Learning
Provision (ie feedback from students)
The Department's attitude was to leave
choice of provision firmly with the learner. Fine principle; but
a person in need of training is least able to make an informed
choice between alternative offerings. It would be helpful (and
simple) to set up a "Which? report"-style learner review
system whose findings were available for all to see. (I would
be happy to accept the judgement of my students as to value and
effectiveness over that of any assessment panel).
In our view the ILA scheme should apply just
three criteria to would-be training providers:
Quality of Training
The really intractable problem is training packaged
for distance delivery. The dynamics of cognition developed remotely
from the teacher are poorly understood. Much accreditation is
meaningless, especially where it reflects a tendency to be impressed
by the technology. (Summary information which appeared merely
banal in print form seems to acquire a mystical property when
displayed as hyperlinked webpages; however, a book is still a
By common consent meaningful Quality Assessment
of training is difficult, but it is possible. In a recently commissioned
report into the NOF ICT Training Programme for teachers Head-Line
Communication used a standard index of assessment to retrospectively
quantify the quality of training offerings from two distance learning
providers. It proved a valuable, coherent and relatively objective
measure which might offer a useful benchmark for ILA-funded training
provision. Alternatively, in the absence of something new, we
would urge the DfES to consider using the University for Industry's
established QA programme.
Provision of Student Support
A learning provider should be able to demonstrate
clear systems for offering assistance to students after they have
started the course. This is far more of an issue for distance
learning than it is for college-based training. Sending a manual
(or a CD) and telling them to get on with it won't do. Students
need various forms of support (including tutor support; peer support;
technical support; pastoral support) which only a truly committed
training organisation will understand and properly supply. An
organisation who provides books or CDs but offers no backup is
no more a "Learning Provider" than is my local branch
of WH Smith...
Value for money
The onus should be on the training provider
to offer evidence of value by reference to pricing structures
available to and tested in the public domain. For example, Reeltime
College courses can be found in high street training centres where,
on a course-by-course comparison, they achieve higher price points
than our equivalent materials offered direct. Furthermore the
Reeltime College offering is available for inspection in its entirety
on the website, where all visitors are invited to purchase online
at prices identical to the equivalent materials offered as ILA-funded
training by direct marketing. These seem entirely reasonable assertions
which ILA Training Providers selling £5 CDs for £250
The triple criteria of Quality, Provision of
Student Support and Value-for-money offer a complete assessment
scheme on which a purchaser of training can base an effective
buying decision. In my opinion, as a trainer of some 25 years'
experience, everything else is just tinkering at the edges.
I hope you find this helpful in your deliberations.
If I can offer any further help please don't hesitate to contact
Technical Director, Head-Line Communication