Memorandum submitted by the Public and
Commercial Services Union (PCS)
INTRODUCTION AND
SUMMARY
1. The Public and Commercial Services union
(PCS) is the largest civil service trade union with over 325,000
members working in the civil service and related areas. PCS represent
the majority of staff working in the Department for Education
and Skills (DFES), the Department of Work and Pensions (DWP),
the Higher Education Funding Council England (HEFCE), the Learning
and Skills Council (LSE) and other education Non-Departmental
Public Bodies (NDPBs) that provide policy, funding and transactional
services and support to the wider education and skills sector.
2. PCS welcome the opportunity to respond
to this inquiry and is happy to supplement this written submission
with oral or further written evidence.
3. In relation to Post 16 skills training,
there are a number of issues raised by this inquiry which directly
affect PCS members and on which we will comment further in our
submission:
— The impact of job cuts and the threat
of further job cuts to the LSC's and DfES's capacity to deliver
the Leitch agenda;
— The need for an effective local interface
between Government, employers, individuals and unions to generate
engagement with the skills agenda;
— The need to ensure that the Commission
for Employment and Skills (CES) does not become a rival policy
making body to Government Departments and the need to maintain
Parliamentary and wider accountability for post-16 skills policy;
— The potential for the Leitch recommendations
to add more bodies and further confuse post-16 skills policy,
funding and delivery arrangements.
4. The need to consider carefully whether
the demand-led, market based approach to funding post-16 skills
provision advocated by Leitch will lead to instability across
the Further Education (FE) sector and for other post-16 skills
providers.
CONTEXT
What should we take from the Leitch Report on
UK skills gaps?
5. PCS members working in the DfES and LSC
and other skills bodies are committed to improving the UK's skills
base, we therefore do not wish to see the Leitch Review leading
to further cuts in capacity of these bodies to lead and shape
the post 16 skills agenda.
6. The Government's plans for skills and
education have already been put at risk by massive job cuts in
the Department for Education and Skills (DfES) and the Learning
and Skills Council (LSC). Currently DfES is facing job losses
of at least one third of the workforce. The LSC has recently undergone
substantial change resulting in over 1000 redundancies (approx
25% of the workforce). The Qualification and Curriculum Authority
(QCA) have to deliver appropriate standards and qualifications
on a reduced workforce. Already significantly fewer staff are
coping with unacceptably high workloads. Understaffing has lead
to excessive use and over reliance on consultants, agency staff
and contractors in all government agencies tasked with the delivery
of the government skills agenda.
7. In addition, we have over 100,000 members
within the DWP and Job Centre plus who deliver the government's
agenda on employability and associated access to Basic Skills
training and welfare support. These departments are themselves
currently undergoing substantial efficiency reductions and facing
a crisis of resources.
8. PCS is concerned that Leitch not only
endorses LSC's so-called "stream-lining programme" that
has resulted in the 1000 redundancies and a current staff vacancy
rate of over 500 posts but also effectively calls for further
job cuts. We believe any further loss of staff from the LSC or
DfES' Lifelong Learning and Skills Directorate (LLSD) will damage
their capacity to meet the challenges posed by the Leitch Report.
9. PCS believe that the ambition of the
Leitch review does not match the resources that have been identified
in terms of delivery. If the task is "daunting" then
there needs to be a professional, dedicated and well resourced
infrastructure to support delivery. Instead the Chancellors pre-Budget
Report stipulates further cuts across government agencies damaging
the capacity of these organisations to produce and implement policies
to meet the challenges set down in the Leitch report. The scale
of the ambition of Leitch could be damaged by poorly defined efficiency
targets imposed by the Treasury.
Are the measures that we have available to assess
the success of skills strategy robust?
10. In PCS's view it is imperative for the
government to have clear indicators of success in meeting the
2010 target for employer training laid out in the Leitch Report.
There should be mechanisms in place to provide for employers failing
to engage with this agenda.
11. It is also crucial that there is clarity
about the role of the Commission for Employment and Skills (CES)
in recommending policy, operational improvements and innovations.
There is a considerable risk of duplication of effort and turf
wars between the CES and DfES in particular, but also with the
DWP and the DTI, which would be counter-productive and threaten
to undermine the role of Government departments as the lead policy
organisations for skills, employment and related provision.
12. Whatever form the proposed local Employer
and Skills Boards take they should be properly accountable, not
only upwards to government, but also through local mechanisms.
PCS believes there is no case for using their establishment to
further privatise the skills policy, funding and delivery sector.
It is vital that training remains rooted in public provision and
is not divided amongst a myriad of private, charitable and voluntary
sector providers which would lead to a deterioration in quality.
NATIONAL POLICY
13. The administration of the further education
and skills sector is already crowded with a significant number
of Non-Departmental Public Bodies (NDPBs): which at present have
a total annual running cost of over £500million. Whilst Leitch
advocates the creation of a more streamlined system this should
not be simply seen as an opportunity to cut staff numbers but
instead as an opportunity to develop greater coherence. The danger
is that the Commission and the Employer and Skills Boards threaten
to add to the confusion of organisations without adding any value.
It is also a risk and that damaging staff reorganisations will
take place in existing bodies without proper clarity about the
remit of the new organisations.
14. PCS is concerned that a market led system
of supply and demand as advocated by Leitch will make planning
and human resource management inside delivery organisations extremely
difficult. Year on year targets and course provision could be
unclear and employer demands poorly articulated.
15. It is a high risk assumption that very
little planning is required. Leitch places a great deal of faith
in the unevaluated delivery mechanism of "Train To Gain"
which is also substantially under resourced. It is unclear the
extent to which employers will actually engage with these structures
and planning must continue to play an important role.
16. There is significant and overwhelming
evidence of discrimination in training provision that not addressed
by Leitch. The Women And Work Commission highlighted the entrenched
problem of gender segregation that commences in school age children
and is institutionalized throughout life. It is disappointing
that Leitch remains silent on issues of inequality and it is vital
that the Government ensures some mechanism for statutory control
over equality in provision and outcomes from training.
17. Disability and special needs provision
are also hardly considered. Recently the LSC cut provision to
the most severely disabled adults explaining that education for
this group of staff is not economically beneficial. It is imperative
that some training is delivered as a result of analysis of social
needs and not a simple reflection of employer demands.
18. A system of ring fenced funding would
prevent the most vulnerable groups from falling out of provision
as it is possible that provision will target groups that are not
so difficult to reach.
19. Similarly a national strategy for ESOL
and Basic Skills provision is of high importance. ESOL provision
has recently been cut by LSC despite that fact that English language
is a fundamental skill for employment, again may not be a skill
that employers want to invest time in.
SUPPLY SIDE
Does the LSC need to be the subject of further
reform?
20. The Leitch Report and the Further Education
and Training Bill make clear reference to further restructuring
of the LSC. PCS do not believe that this would lead to improvements
in the performance of the FE Sector. It is crucial that the LSC
is allowed to stabilise as much as possible and focus on the demanding
challenges it faces.
21. PCS would like to see an end to LSC
job cuts and a joint evaluation undertaken with the employer into
the changes to the LSC's role proposed in the Leitch Report. Continuing
with a flawed change programme that is producing redundancies
at a cost to the tax payer does not lead to better policy development
or implementation and weakens the LSC's own skills base in a way
that contradicts the aims of the review.
22. If further staff reductions are made
and transfers to the Commission or the Sector Skills Councils
become necessary it is imperative that the change is managed well,
over a period of time, with clearly defined transitional arrangements,
and with adequate assurances given to staff in genuine partnership
with PCS.
23. The most worrying aspect of the Further
Education and Training Bill is that it removes local LSCs in a
way that appears to move the LSC back towards being essentially
a funding body. The experience of PCS members working on post
16 skills provision since the time of the Manpower Services Commission
has confirmed the need for an effective sub-regional interface
between "Government", employers, unions and individuals.
Local LSCs would be capable of providing this interface effectively,
and we believe that in the context of ensuring greater stability
for the LSC, its management should focus on ensuring an effective
local presence.
24. PCS welcome the Leitch Review's recognition
of the need for monitoring of local labour markets and effective
local provision to ensure that employers are engaged in improving
skills provision. However the Leitch Review's focus on the importance
of local skills provision suggests that the LSC's move to regionalisation
is fundamentally flawed and will lead to new bodies being created
when local LSCs provide an already existing basis for delivering
employer engagement with skills provision at a local level.
25. PCS believe that the creation of another
set of local delivery bodies creates the potential to undermine
coherence further in the skills sector, adding to users' confusion.
Whatever forms the proposed local Employment and Skills Boards
they should be accountable. Their establishment should not be
used as an opportunity to privatise further the sector. Privatisation
would inevitably lead to resources being diverted into profits
rather than being used to enhance skills delivery.
DEMAND SIDE
What should a "demand-led" system really
look like?
26. PCS welcome the Leitch Report's recognition
that employers cannot continue to downplay the economic and social
importance of training. We welcome the call for a statutory entitlement
to skills training and the identification of the pressing need
to achieve greater coherence and stability in how publicly funded
training is delivered. We don't believe however that the Report's
demand led solution will deliver this.
27. The Leitch Review has strengthened an
employer led model of skills delivery at the expense of an industry
wide approach to identifying and developing sector skills. The
role of the trade union movement in the statutory framework of
skills development could be further strengthened including implementation
of statutory rights to collective bargaining on workforce development
and greater levels of trade union representation on the newly
formed bodies. Union learning representatives have a proven track
record in engaging learners and will have a key role in raising
the demand for learning.
28. PCS remain sceptical of developing a
"market place" for skills delivery that is mostly responsive
to employer demand. Experience demonstrates that employers do
not always train their workforce to an appropriate level of skill
fearing that staff will not be retained or that wages will rise.
Leitch relies upon a benign view of employers acting in their
own best interests and the interests of employees, once the system
is changed, which is simply not supported by the evidence.
29. PCS support the TUC view that the Government
must commence preparations for regulations in 2010 in order to
ensure workers will have the right to time off for Level 2 training
in the event of a poor response from employers. Cynicism will
grow about the intended depth of real change if we drift to 2010
without proper review of progress towards targets and responsive
measures where there are shortfalls.
30. PCS welcome the Leitch recommendation
of an increase in public investment in training. However we would
like to see more investment required from employers. The Leitch
Review prioritises employer incentives whilst again failing to
provide any mechanisms for compelling employers to engage in training
and we would urge the government to keep progress on employer
investment under review with plans for intervention identified
should it become necessary.
31. A system of employer demand will not
necessarily ensure that the needs of all sections of our community
are met. It is imperative that there is a government obligation
placed on the Employment Skills Boards and the Sector Skills Councils
to promote equality of opportunity in all government funded training
provision and for mechanisms to be identified for monitoring success
rates.
32. PCS is concerned that the Leitch Report
may lead to institutionalised instability across the FE and wider
skills sector as colleges and other providers compete for funding
through learning accounts. While Leitch states that the majority
of adult skills funding should be through Train to Gain, PCS is
not convinced about the effectiveness of personal learning accounts
or other mechanisms that have their origins in the failed idea
of education vouchers. The well known abuse of Individual Learning
Accounts should give rise to great caution about routing skills
provision funding through virtual Learner Accounts until they
can be shown to be protected against fraud.
33. The Leitch Report's enthusiasm for a
market solution is not balanced against consideration of the risk
of market failure. The approach to FE and skills funding in general
risks becoming too complex and bureaucratic as funding follows
employers or individual "purchasers" of training. We
therefore ask that the Committee look in detail at the funding
implications of the Leitch Report. An inadequate funding model
poses a significant threat to the stability of the FE sector and
will have consequences for the PCS members working in the sector.
LEARNERS
34. PCS welcomes the emphasis on improving
literacy, numeracy and language skills for the unemployed on a
voluntary basis. However any new pathfinder provision should not
form the basis of outsourcing arrangements. We urge the government
to consult directly through its employers with PCS over the detail
of any proposed changes to JC+ that will directly impact on the
staff of DWP, DfES and the LSC.
35. The Leitch Report is an opportunity
for the Government to start to practice what it preaches about
skills. Government departments and NDPB's are far from being the
ideal employers in terms of providing training for all their staff.
Our experience is that comprehensive and effective skills training
is too often reserved for "high fliers" while other
civil servants and government staff are expected to learn on the
job. Government departments also seek to recruit staff with particular
skills from outside rather than train existing staff to take on
new roles. PCS believe that Government has much to learn from
Leitch about adopting a culture of training that will enhance
job security and lessen the need to use expensive consultants
to deliver public services.
36. A significant first step in implementation
of "The Pledge" proposed in the Leitch Review would
be a clear expectation from government that all public sector
employers implement "the pledge." If Train to Gain is
to be the main delivery mechanism for level 2 qualifications then
it must be broadened to include public sector employees. The public
sector should lead the way in increasing level two attainment
by allowing staff an entitlement to paid leave.
37. PCS is represented on the board of Government
Skills-the SSC for central government and will continue to lobby
for effective workforce development strategies within government,
its agencies and NDPB's as well as supporting "the pledge"
as a general entitlement.
QUALIFICATIONS
38. A plethora of qualifications (most unaccredited
and unregulated) already exist. A distinction needs to be made
between:
(a) sector-wide qualifications which benefit
employee as well as employer
(a) bespoke company focused qualifications
which develop precise skills and know-how but tend to be untransferable.
39. PCS believe these need to be better
regulated. Rationalisation should aim to bring all these into
the framework. The fact that there are so many bespoke company
qualifications speaks volumes about a need for more than the employers'
voice in developments. Sector wide qualifications will improve
skill levels across a sector and also encourage movement within
it.
40. The more a culture shifts to valuing
sector wide qualifications the greater the need for effective
regulation and thus for an organizations like QCA. Hence the need
to include QCA staff wherever there is a discussion of the relationship
between any new commission and the DfES.
CONCLUSION
41. In conclusion PCS believe that in order
to fufill the Government's ambitions for Post 16 training, as
laid out in the Leitch review and the Further Education bill,
there needs to be a professional , dedicated and well resourced
infrastruction supporting delivery.
42. PCS believe that the impact of the continuing
job cuts programme to those bodies delivering the agenda, in particular
the LSC and DfES, already damages the government's capacity to
deliver the government agenda on Post 16 Education.
43. There is the danger within the Leitch
recommendations of adding more bodies and further cluttering and
confusing post-16 skills policy, funding and delivery arrangements.
There is considerable risk of duplication of effort and possible
rivalry between the CES, DFES, DTI and DWP. This would be counter
productive and undermine post 16 policy implementation. It is
essential to ensure Parliamentary and wider accountability for
post-16 skills policy remains.
44. There is also a need to consider carefully
whether the demand-led, market based approach to funding post-16
skills provision advocated by Leitch will lead to instability
across the FE sector and for other post-16 skills providers. The
Leitch report's enthusiasm for a market solution is not balanced
against any consideration of the risk of market failure.
45. The Leitch Review prioritises employer
led training but fails to provide mechanisms for compelling employers
to engage in training. PCS urge the government to keep progress
under review with plans for intervention identified should it
become necessary.
46. The proposed system also risks becoming
too complex and bureaucratic as funding follows employers and
individual purchasers of training. It is important that the funding
implications of the Leitch Report are carefully analysed. An inadequate
funding model poses a threat to FE sector stability and therefore
PCS members.
January 2007
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