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POST-16 SKILLS TRAINING
Submission to the Education and Skills Committee by the Federation of Awarding Bodies
January 2007
1. Executive Summary
1.1 This submission is made by the Federation of Awarding Bodies, the trade association for vocational awarding bodies, on behalf of its members.
1.2 It revisits the case which has been made in respect of employers' views on vocational reform and considers evidence which suggests that a more evolutionary process may better reflect their desires and needs.
1.3 It is suggested that action needs to be based on a proper analysis of the nature of the problems to be approached and that the genuine voice of employers needs to take precedence over top down policy and central planning. Indeed there is an anomaly in using a 'planned economy' model to implement what is supposed to be a demand-led approach.
1.4 SSCs need to be more focussed and consistently effective. Providing this is the case, they need proper funding to meet their strategic purposes. They need to involve key partners fully in their work and draw on all relevant information regarding employers' qualifications needs.
1.5 The nature of rationalisation needs to be better understood. It should focus on the purposes of qualifications and their fitness for these purposes. This needs to be combined with a clear communication of these purposes to employers and learners through the titling and grouping of qualifications.
2. Introduction to the Federation of Awarding Bodies
2.1 The Federation of Awarding Bodies (FAB) is the trade association for vocational awarding bodies and works to open up a dialogue between awarding bodies and the different regulatory and stakeholder organisations. Our activities are focussed on achieving a vocational qualification system that meets the differing needs of learners, employers, education and training providers and awarding bodies as well as offering good value to funding bodies and taxpayers.
2.2 The Federation seeks to be pro-active on policy and development issues on behalf of its members and has a number of strategic working groups through which it forms its views and positions. In relation to this inquiry the two most relevant parties are the Skills for Business Network Issues Strategic Working Group and the Framework and Credit Strategic Working Group. The Federation has been extremely active in shaping the debate around the developing Qualifications and Credit Framework. FAB is represented on the main programme board of the DfES Vocational Qualifications Reform Programme, and along with the Joint Council for Qualifications, delivers the strand of that programme concerned with the preparatory rationalisation of vocational qualifications.
3. Our Submission
3.1 Scope This submission addresses itself to the questions: · What should a 'demand led' system look like? · Do the qualifications which are currently available make sense to employers and learners? · Is the Qualifications and Credit Framework succeeding in bringing about a rationalised system? Is there a case for further rationalisation?
4. Context
4.1 The Federation believes that a number of reports commencing in the early 1980s with the theme of competence and competition have convincingly made the case for a link between the skills and qualifications of our workforce and economic prosperity. Increasingly the case has been argued for the UK to aspire to be a high skills, high wage economy and for social equity to be approached through the same agenda. We feel that the arguments have been well made and do not need to be reiterated.
4.2 The Leitch Report is the latest offering to repeat this theme. The Federation has already welcomed the principles and main proposals contained within this report. We believe that it is correct that the responsibility of skills development should be shared between employers, individuals and the Government. The key focus should, as described, be on economically valuable skills and there should be a further shift from supply-led to demand-led skills development programmes. We were particularly pleased to note that it acknowledged a need to develop a flexible, responsive system based on existing structures and reforms already being undertaken.
4.3 We also support the key role of fully established and funded SSCs, in rationalising the skills system, placing employers at its heart.
4.4 We do however have some concerns that current rhetoric misrepresents the nature of the exiting situation and problems. With this comes some associated misunderstanding regarding the nature of the required interventions which, unless corrected, could lead to well intentioned but flawed interventions.
5. The Vocational Qualifications Landscape
5.1 The UK's vocational awarding bodies are a strong, independent, self-funding sector offering valued services to individuals and employers. They already have strong links with many of these employers and they are able to sustain and deliver key aspects of the Government's Skills Strategy with no direct support from public funds. They have links with the employment sectors they serve which in some cases go back for over a century through the craft guilds, chambers of commerce and professions.
5.2 Awarding bodies are constituted in a variety of ways. Over two thirds have charitable status or are companies limited by guarantee and ten per cent have Royal Charters. Many awarding bodies have been in operation for over 25 years.
5.3 The Federation of Awarding Bodies (FAB) is a voluntary trade association through which vocational awarding bodies co-operate in areas of shared interest and in the development of the system.
5.4 Vocational qualifications inform an employer of any knowledge or skills held by the prospective employee that may be of relevance to their employment. There is a whole range of vocational qualifications representing the UK's rich and varied economy. Awarding bodies design and operate rigorous assessment processes so that employers and the public can have confidence in the abilities of individuals awarded certificates.
5.5 For some individuals, a vocational qualification is a preferred alternative to academic qualifications; for others it is achieved in addition to an academic award as evidence of their effectiveness in employment.
5.6 A comprehensive and trusted vocational qualifications system is vital to the operation of an effective labour market. Individuals have opportunities to progress and demonstrate their achievements through independently validated qualifications. Employers have clear benchmarks for individuals' abilities and potential, this enables them to plan their recruitment and training with confidence.
5.7 DfES statistics (chart A) show the growing importance of vocational qualifications. In 2004/5 a total of 574,000 NVQs were awarded, an increase of 17% on the previous year. In the same period a conservative estimate shows that around one million vocational qualifications were achieved.
Chart A - taken from "Vocational Qualifications in the UK: 2004/5" (published by DfES, 23rd February 2006)
6. Meeting Employers Needs
6.1 The case for vocational qualifications reform is frequently made on the platform of meeting employers' needs and expectations, and this is entirely correct. However we do not believe that employers' views have been accurately represented in many of the justifications for change which we have seen.
6.2 The economy of the UK is rich and diverse, supporting a wide range of employment from the traditional kind to the new and high tech industries. Employers quite reasonably expect to be able to access qualifications that support the needs of their workforce, including the many specialist areas in which the UK excels. Unsurprisingly the result is a range of qualifications which matches our skills base.
6.3 Does this richness lead to confusion as is often claimed? Apparently it does not. Recent research from the Institute of Directors shows that two thirds of directors were familiar with the range of vocational qualifications in their sectors, while 70% thought that there was the right number or even too few vocational qualifications in their sector (chart B).
Chart B - data taken from the Institute of Directors report "Vocational qualifications: current issues, Government responsibilities and employer opportunities" by Dr Richard Wilson, January 2006.
6.4 Nor is the number of awarding bodies the problem it might appear. Many awarding bodies serve a single market sector and have a well established brand or reputation in that sector. Most sectors are served by just a handful of awarding bodies.
6.5 A central study to understanding the operation of the awarding market is PriceWaterhouse Cooper's 2005 report to QCA on 'The Market for Qualifications in the UK'. This research shows customers choose awarding bodies on the basis of fitness for purpose, responsiveness, and to a lesser extent, cost.
6.6 A critical finding of this report, which remarkably in our view does not appear in any summary, is that over 90% of employers responding to the survey thought that current qualifications met their business needs (Para 8.65).
6.7 Recent work by FAB and the Joint Council for Qualifications as part of the DfES Vocational Qualifications Reform Programme has led to some insight into the way in which qualifications are counted and presented. The research indicates that the often quoted figure of 5,000 accredited qualifications is misleading, both in terms of the strategic policy view on reform, and in terms of presenting the qualifications framework to employers and the public.
6.8 At a very basic level, identical qualifications offered in the market by several awarding bodies are unhelpfully represented as unique qualifications. Many individually listed qualifications differ from each other only by one or two units. They are in effect optional routes within the same qualification and would be better shown as such. Linked qualifications across levels of the framework similarly appear as discrete and unrelated. One example of such anomalies in counting is that there are 17 distinct Key & Basic skills qualification titles available for learners but these are counted as 442 separate titles on OpenQuals, the qualification regulators database. A better organisation of the presentation and reporting of the framework would probably show the bulk of its content as occurring in a few dozen linked qualification suites.
6.9 Awarding bodies have routine contact with employers in the development and delivery of qualifications, this procedure stretches back decades. Most employers routinely refer to qualifications in terms of those which existed when they themselves qualified. It takes many years to establish widespread understanding and acceptance of any qualification. There is evidence that the most damaging factor to the understanding of qualifications is frequent change at the instigation of Government and regulators.
7. A Central Role for SSCs
7.1 We have written in response to the Leitch report that we agree that SSCs should have a key role in rationalising the system, placing employers at its heart. However, it is critical that SSCs exercise this leadership role and are given an appropriate remit. The remit suggested by Leitch to severely curtail the number of qualifications would be a damaging error, partly because of the factors stated above, and also for reasons which will become clear later.
7.2 We have concerns relating to the effectiveness of some SSCs and would therefore strongly endorse the recommendation that SSCs should be given a clearer, more focused remit. We also recommend that through licensing arrangements more should be done to manage the performance of those which are failing. It is critical that SSCs are sufficiently funded to maintain this clear strategic focus.
7.3 We are unconvinced of the proposition that there should be a new commission to represent employers on skills issues. As proposed, the commission would be directly accountable to government and the devolved administrations, providing these with a further tool for centrally determined interventions which have not always been desired at the point of delivery. There is a risk that this will disenfranchise those best suited to determining the needs of local employers - that is, the learners and employers themselves.
7.4 The structure proposed would seem to tighten further the arrangement under which SSCs are contracted to Government and are constrained to work within tight policy frameworks. The influence of policy, funding, arrangements for qualifications, the emphasis on Train to Gain, and tight regulatory controls on the design of qualifications has hampered their ability to act independently or to innovate. The Leitch recommendation that all post 19 funding should be channelled into Train to Gain and Apprenticeships (both expensive and complex programmes, albeit meeting the precise needs of some employers) is an illustration of how the freedom of SSCs to develop their own solutions could be hugely limited.
7.5 The capacity of Sector Skills Councils to deliver is also hampered by uncertain finances and mixed levels of support from employers in their sectors. Many programmes of work, such as those relating to specialised diplomas or the development of new occupational standards, have revealed weaknesses in capacity and expertise.
7.6 On this point the extension of powers to SSCs, as proposed by Leitch, raises difficult questions. The role of QCA in accrediting qualifications, as enshrined in the Education Act, cannot be set to one side. Creating a further layer of accreditation through the SSCs is not the best way of ensuring a system which is fleet of foot, flexible and innovative. The proposals that SSCs should draw up a shortlist of which qualifications should attract public funding and therefore take a lead role in the accreditation of new qualifications, carries considerable risk. We do not have absolute confidence in the capacity and expertise of SSCs to engage fully in with this complex area. They would need to develop the necessary processes, with checks and balances, to meet employer and learner needs.
7.7 Identification of qualification provision and curricula for a full range of employers' workforce development needs is not a simple step from knowing employers' skill needs. It requires expertise from a variety of partners. Providing appropriate learning and progression routes through a sector cannot rely solely on provision concerned with the immediate demonstration of full workforce competence to industry standards; again SSCs will need the help of key partners in developing their positions.
8. What Constitutes Rationalisation?
8.1 The awarding bodies' contribution to the early stages of the DfES Vocational Qualifications Reform Programme has highlighted some important issues around what constitutes a rational system which meets the needs of employers and learners. These five issues are outlined in the following points.
8.2 Transparency The purpose of qualifications is critical to understanding what is on offer; what do they do and for who are they intended. It does not help users to be presented with an unstructured list which does not make these purposes clear.
The important characteristic of a rational qualifications system is not the number of qualifications, but the fitness for purpose of the qualifications and the clarity with which this is presented. The way in which qualifications are titled and counted is central to this clarity and needs to be improved to help users of qualifications to find their way round, and to provide regulators and policy makers with a coherent view of the whole system.
8.3 Types of Qualification The qualifications provision we have has evolved over time to meet a range of employer and learner needs. For reasons explored above this can sometimes appear complex and confusing, though there is evidence that in any particular sector, employers do understand the qualifications available.
There has been some discussion that in the future we should be looking to have just one 'type' of vocational qualification which, through its content and assessment, would assure that the holder is competent to industry standards. A cursory inspection of career patterns shows that individuals use qualifications for a variety of purposes including preparing to enter employment, qualifying in employment, preparing for job change and continuing professional development. Qualifications provide ladders and bridges that enable movement and progression and do not simply denote an arrival point. A variety of entry and progression routes is important in the real world to employers seeking to meet their requirements for a skilled workforce.
A rational qualifications system requires not just one type of qualification, but a variety of qualifications fitted to the particular purposes which qualifications serve. Accordingly, the work on the titling of qualifications needs to be founded on a clear understanding of the uses of qualifications.
8.4 Volumes Low volumes are not always an indication that a qualification is not justified. Some qualifications may provide significant specialisms (such as nuclear decommissioning or munitions clearance); others may provide a progression route which is important to some learners, albeit a minority of any cohort.
It is important to understand the purpose which the qualification is intended to serve and whether it is succeeding in meeting that purpose. Where there is a clear justification for a qualification but take up is low, it may be that action is required to improve take up.
8.5 A Market in Qualifications Some qualifications are offered by just a single awarding body but it is common for several awarding bodies to offer similar or identical qualifications. Many awarding bodies serve a clear market sector and have a well established reputation in that sector. Most sectors are served by just a handful of awarding bodies.
If the steps outlined above are taken, the involvement of several awarding bodies does not lead to a proliferation of qualification titles, but does offer users a choice, allowing market forces to act. Research has shown that customers choose between awarding bodies on the basis of fitness for purpose, responsiveness, reputation, and to a lesser extent, cost. Users often wish their awarding body to offer a full range of titles matching their needs so that they can deal with just one organisation. Others clearly buy from a range of awarding bodies and use this as an opportunity to negotiate on price and support levels.
The Federation of Awarding Bodies believes that the balance of benefit lies in an open market for qualifications, with strong regulation of standards. It also recognises that 'cherry picking' of high volume qualifications to the detriment of more specialist areas can be a problem in some sectors. It would therefore be reasonable to expect any awarding body entering a sector to offer a balanced portfolio of qualifications which contributes to meeting the range of requirements of employers in that sector.
8.6 The Development Model The most highly planned qualifications in the current framework are NVQs. The content and structure of NVQs have been specified by SSCs and their predecessors, the NTOs. Yet NVQs have been identified as those most likely to be low take up qualifications.
We cannot be confident that a centrally planned model, albeit predicated on employers' needs, could be sufficiently good at predicting actual demand for qualifications to be the sole basis for designing and developing qualifications provision, especially as these needs change over time. Indeed, to meet the intention to be flexible and responsive there must be a combination of a strategic steer from SSCs with discretion for awarding bodies to develop specific awards based on their own market intelligence and employer links.
Business models for successful product development stress a component of controlled risk taking in bringing products to market, understanding that it is not possible to predict with precision those which will meet a genuine need and generate high volumes. This is countered by rigorous review once products are in the market to remove those which under perform.
The balance between pre-specification and discretion will vary, with SSCs having a particularly close interest in qualifications intended to establish occupational competence in their sectors. In general though, the aims of raising the relevance and uptake of qualifications are likely to be served by giving awarding bodies a degree of discretion in developing qualifications, encouraging them to develop innovative provision whilst being quicker to remove weak qualifications which fail to establish themselves.
9. The Way Forward
9.1 In supporting current policy and the SSC role in expressing the employer voice, we would observe that the most effective SSC arrangements have been those where the leadership role has been exercised through a process of effective partnership. The use of multiple sources of information on employers' needs will lead to a more thorough and robust understanding of these needs, and awarding bodies and providers have extensive contacts with employers. Recent Institute of Directors research indicates that employers are more likely to turn to awarding bodies or providers to discuss their qualifications needs (twice as many in the case of providers). Partnership with awarding bodies is essential in converting these needs into attractive, deliverable qualifications.
9.2 Action needs to be based on a proper analysis of the nature of the problems that need to be approached, and the genuine employer voice needs to take precedence over top down policy and central planning.
9.3 Awarding bodies have a clear interest in a system of successful, valued qualifications and are keen to play their part in the delivery of the skills agenda, individually and through the Federation of Awarding Bodies.
10. Recommendations for Action
10.1 The case for radical, as opposed to evolutionary change, in vocational qualifications, based on the justification of meeting employers' needs, should be properly explored using the available evidence, including that presented in this submission.
10.2 The nature of the rationalisation of qualifications should be properly understood. More appropriate ways of representing the qualifications on offer for the purposes of policy review and in order to improve clarity for employers and other users should be looked into. In particular, the simplistic rhetoric that there are too many qualifications and the number must be reduced should be challenged.
10.3 The role of frequent government-directed change to qualifications in damaging employers' understanding of qualifications needs to be considered.
10.4 It needs to be asked whether the model which is being used to pursue a demand-led system is in itself anomalous. The combination of extensive government-led direction and a 'planned economy' approach to provision seems to run counter to a market determined philosophy.
10.5 The variability of SSCs in retaining their strategic focus needs to be explored, as does their effectiveness in representing employers' views, drawing on all relevant sources of information on qualifications, and involving key partners and stakeholders.
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