Memorandum submitted by the Association
of Learning Providers
INTRODUCTION
1. The Association of Learning Providers
(ALP) represents the interests of a range of organisations delivering
state-funded vocational learning. The majority of our 480 member
organisations are independent providers holding contracts with
the Learning and Skills Council (LSC) for the delivery of Apprenticeship,
E2E and Train to Gain programmes, with many also delivering DWP
provision to support the unemployed. We also have circa 35 colleges
and a number of non-delivery organisations, such as the Sector
Skills Councils in membership, which means that ALP offers a well
rounded and comprehensive perspective and insight on matters relating
to its remit.
BACKGROUND
2. ALP is close to finalising a paper, "A
vocational route for the future—the challenges facing the
FE system and the way forward", which takes a longer term
view of some of the issues facing the vocational education and
training sector. In the face of the current recession, however,
there is a clear need to take immediate action to identify how
and where costs might be reduced whilst minimising any adverse
impact on the quality of provision available and two further ALP
papers ("Recession—the immediate impact on Government
funded vocational training" and "FE funding—the
basic principles") proposed how the Government should respond
to the immediate challenges facing the skills sector during the
recession, whilst at the same time retaining the basic principles
for funding that will be key to ensuring the sector is able to
maintain its quality and continue to increase performance.
3. The main thrust of these two papers is
set out below. We believe that the issues covered are relevant
to the inquiry and would welcome the opportunity to discuss them
with members of the Committee.
MAINTENANCE OF
APPRENTICESHIPS
4. ALP believes that it is vital that no
action is taken that might damage the take-up of Apprenticeships
by both individual and employers if we are to retain and develop
a skilled workforce ready and able to take up the opportunities
that become available as the economy recovers.
5. Apprenticeship frameworks have been developed
over many years and provide the foundation stone on which work
based learning (WBL) must be built and funding for Apprenticeship
must continue at the very least at current levels. The opportunity
should be taken to broaden the Apprenticeship "family"
to retain and expand further level two and three (especially level
three) but also formally include level four/Foundation Degree
level, to strengthen the brand and the scope for high level progression
through to HE.
ADULT SKILLS
DEVELOPMENT
6. Support for adult skills development
will undoubtedly be reviewed and we would suggest it is time to
move towards a greater sharing of responsibility for the development
of those in employment, with Government, employers, and in some
cases individuals themselves, co-funding provision for this group
of people. This would release greater levels of Government funding
to support those individuals facing a period of unemployment.
The priority for this unemployed group should be basic skills—developing
them up to their first level two qualification, or in some cases
replacing "redundant" level two qualifications.
7. The need for some in employment still
to achieve similar levels of basic skills should also remain a
priority, but it could be that some of the recent flexibilities
introduced into Train to Gain (TtG) in order to grow the programme
could be withdrawn now the programme has become established, allowing
Government to focus TtG funding on those in greatest need, as
suggested above.
OPPORTUNITIES TO
CUT COSTS
Reducing the number of "intermediary bodies"
(quangos and others) involved in the FE system.
8. One option would be to concentrate "improvement"
support totally under LSIS, which might involve the merging in
of some Becta and LLUK functions/funding. LSIS is increasingly
provider driven by its elected Council of providers, and this
would strengthen further the opportunity to ensure support monies
are properly and effectively targeted at areas of real need.
Reducing the number of quality standards, kite
marks, etc, that providers have to achieve.
9. It is vital that providers have more
say in the development of quality standards and performance indicators.
There should be a simplified system which would reduce both the
costs and the bureaucracy involved, and ALP can still see no reason
not to use the well known, understood and established EQF system,
which can be easily adapted to meet the expectations of both Government
and employers. Ofsted could then be used, as now, for the necessary
external inspection and verification of providers' own self assessment
processes.
Development of a preferred supplier system
10. A preferred supplier system, based on
a rigorous analysis of the provider's track record whilst still
allowing new providers to enter the system, would significantly
cut costs.
Allowing providers to make better use of technology
11. Allowing use of electronic signatures
and archiving etc would allow providers to reduce their costs
without impacting on the frontline—the service given to
the learners and their employers.
FE FUNDING—THE
BASIC PRINCIPLES
12. Whilst it is essential to cut unnecessary
costs wherever possible there are some fundamental principles
that must be retained if the quality and performance of the sector
is to be maintained and grown. These are:
Level playing field
13. From the very start ALP has argued for
a level playing field for FE funding. All funding lines should
be accessible by any provider with the capacity to deliver to
the specification set out by the funder, and there should be no
artificial divisions between different types of organisation,
be they public, private or third sector, when allocating funds.
Learners deserve the best service possible so all funding should
be routed through the providers best able to deliver training
services to the learners/employers.
Preferential treatment
14. Within an open market no preferential
treatment is given to any part or parts of the FE system that
would give them an unfair advantage over other parts of the sector.
Employers contracted to deliver Apprenticeships or Train to Gain
should be required to meet the same standards and criteria as
other providers delivering those services to other employers.
To do anything else would inevitably distort success rates making
any meaningful comparisons of either the effectiveness of the
training provided by the different routes, or the value for money
offered, impossible.
15. Also, when programmes have been contracted
following an open and competitive tendering system, it is totally
unacceptable to offer some providers flexibilities, at a later
stage, that are not available to other providers.
Ring fencing of budgets
16. Recently some new programmes/budgets
have only been available to some sections of the sector (eg 75,000 places
for young unemployed learners was ring fenced for colleges although
it is the independent sector that has the expertise in delivering
services for the unemployed, with many already contracted to provide
these services for DWP). As argued previously, all funding lines
should be accessible by any provider with the capacity to deliver.
The need to further develop an improved demand
led funding system
17. Whilst there have been problems with
the so-called demand led funding system introduced by the LSC,
these have largely resulted from mismanagement (such as extremely
late contracting of provision many months after the start of the
contract year; failure to listen to early advice from providers
that they would be delivering their full contract values; and
providers encouraged by the LSC to deliver volumes over and above
those set out in their contracts). Now is not the time, however,
to move back to a rigid, pre-planned, pre-determined allocation
system. The recent economic downturn came suddenly, out of the
blue, and has resulted in a deep recession that no-one could have
predicted even a few months before. Given this total unpredictability
it is vital that any future FE funding system is truly demand
led, capable of responding to the real time needs of the economy
and employers.
The role of the Local Authorities and RDAs in
16-18 provision
18. ALP believes that both local authorities
(LAs) and RDAs have a clear role to play in identifying the skills
needs of their areas, and in "commissioning" appropriate
provision to address these needs. We also believe, however, that
it is vital that local authorities in particular play no part
in the actual contracting of provision, which should be done by
the Skills Funding Agency (SFA). There are a number of reasons
for this, eg many local authorities are themselves training providers
and there would be a direct conflict of interest if they were
involved in contracting for skills in their areas; many providers
operate multi-regionally or nationally and requiring them to contract
at the local level would represent a serious waste of resources
which would be better directed to the frontline (the learners).
Following representations from ALP, the Government agreed that
the National Apprenticeship Service (NAS) should be responsible
for commissioning all Apprenticeship provision in England. The
NAS will take advice from the LAs on the particular apprenticeship
needs in each area but funding and contracting will remain the
Service's responsibility.
19. The significant transfer of LSC responsibilities
to the LAs for 16-18 learning and skills provision has posed
major challenges for work based learning providers, particularly
those that operate nationally or across regions. One of the challenges
is the lack of visibility of independent providers to LAs and
ALP has been working closely with the DCSF and the REACT team
at the LGA to address this over the past twelve months.
20. Other forms of provision, such as the
Foundation Learning Tier and the Entry to Employment programme
which is so vital for the NEET group of young people in this recession,
will be commissioned by the LAs. ALP has been involved in the
consultations on the draft National Commissioning Framework for
16-18 provision and will shortly respond formally to the
draft document. With a myriad of bodies to contend with, the key
challenge for providers is to build and maintain the right set
of relationships with the NAS, SFA, local authorities and the
LAs' Sub Regional Groups. ALP is regularly told by LAs that our
members are the answer to raising the participation age and the
NEET problem, not to mention the added opportunities of delivering
training to 14-16 year olds, but the key to these opportunities
for providers is a good and effective relationship with LAs at
a local level.
21. There are a few issues holding this
back—not least the potential contracting and commissioning
arrangements, the capacity of providers to engage with the plethora
of organisations needed for this type of operation and the LAs'
understanding of (or willingness to understand) the independent
work based learning sector. ALP is aware of many LAs who have
good working relationships with providers, yet as members have
fed back to us, there are still too many who do not. Not only
are providers often not properly represented on 14-19 Partnerships
and Regional Planning Groups, but one LA we are aware of only
thinks it has two independent providers on its patch, because
they are the only two with bases in the local area! Time is running
short in terms of overcoming these challenges.
6 January 2010
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