Memorandum submitted by the Association of Learning Providers

 

introduction

The Association of Learning Providers (ALP) represents the interests of a range of organisations delivering State-funded vocational learning. The majority of our 472 member organisations are independent providers holding contracts with the Learning and Skills Council (LSC), and Department of Work and Pensions (DWP), for the provision of a wide-range of work-based and work-related learning. Amongst our members we also have a number of consultants, regional networks, and Colleges of FE, alongside nearly 50 charities, giving ALP a well rounded and comprehensive perspective and insight on matters relating to its remit.

 

115 of our members have a declared contractual interest in Foundation Learning and/or Entry to Employment (e2e). Comments from all of our members pertaining to your enquiry were however invited at an early stage, with a draft version of this paper circulated for comments prior to its submission. Our members' responses have therefore very much informed this final version.

 

We believe that we are in an excellent position to pass comment on the aspects of your current inquiry that fall within our remit, and we would be delighted to give oral evidence to the committee should this be required.

 

 

Summary

 

1. The Association of Learning Providers (ALP) welcomes the opportunity to input into the Committee's enquiry on provision for young people not in education, employment or training (NEET).

 

2. Strategies for addressing the skills and employability needs of this group have of course been the subject of much debate for some time, and particularly in view of the current economic conditions - a recession that has disproportionately affected young people and those with low or no skills.

 

3. Many of our members are involved in delivering services to this group and we have been concerned for some time that developments within this area of provision have the potential to work against the very objectives we are all trying to attain. A number of concerns remain, including the appropriateness of Foundation Learning (FL - previously known as the Foundation Learning Tier) , the phasing out of Entry to Employment provision (e2e), and associated funding queries. These are dealt with at greater length in the body of this document.

 

4. On a very general point, we would like to register an ongoing concern as to the language used to describe this cohort of young people, and indeed some of the provision that surrounds them. The term "NEET" itself, whilst descriptive when not used as an acronym, is not one that is widely recognised or used amongst the young population that it describes, and can indeed often be seen as pejorative and thus unhelpful. Similarly, the shorthand of (for example) the raising of the compulsory age for participation in education or training is often described as being "the raising of the school leaving age" which is not at all helpful to many youngsters who are, or are at risk of becoming NEET because of poor previous experiences within the school system. The use of language as a descriptor is important in many respects, although not one which we intend to dwell in great detail on this occasion. We would however ask that the Committee bear this general point in mind during their considerations. We do acknowledge however the difficulty of finding suitable alternatives, in the absence of which we have continued to use the term "NEET" to describe the cohort of young people in question.

 

5. Our specific conclusions, which are expanded upon in the body of this text are:

 

i. Getting information, advice and guidance (IAG) right is essential if we are to really tackle the NEETs issue, and successfully re-engage young people into learning. At the moment the quality of IAG available is very mixed and a real drive is needed to ensure a quality IAG service is available to all young people, whether potentially NEET or not. ALP believes that this is key to identifying those young people at risk of falling into the NEET category and channeling them to the appropriate route to enable them progress and achieve the skills they need for life and work. . (Para 8)

 

ii. We do not believe FL to be a direct and suitable replacement for Entry to Employment (e2e) as, being a purely qualifications-based framework, it does not take sufficient account of the needs of young people for whom qualifications are simply not currently appropriate. (Paras 10-13)

 

iii. There must be an early agreement on how audit arrangements will ensure that structural funding issues relating to QCF implementation will not adversely impact upon training provision - particularly that for e2e - delivered to the required standards and in good faith. (Para 16)

 

iv. The loss of e2e within FL will result in the loss of non-means tested Education Maintenance Allowances (EMAs), a proven tailored system of financial support arrangements for young people to encourage participation and retention in learning of disengaged youngsters. (Para 19)

 

v. The loss of e2e within FL is neither desirable nor being undertaken on the basis of a sound rationale of improvement of provision for NEETs. (Para 20)

 

vi. There must be provision for e2e to be contracted at a national scale after March 2010. Without this, many providers will find resources being diverted into servicing a vastly over-complicated commissioning and funding system instead of front-line delivery. (Para 22)

 

vii. There is a danger that the provision of localised services may be overlooked in the multiplicity of funding and contracting interfaces envisaged by next year's machinery of Government changes. (Para 23)

 

viii. New ways must be found to provide 'employer located' learning opportunities (Paras 26-31)

 

Effectiveness of the NEET strategy

 

6. The Department for Children, Schools and Families (DCSF) has a Public Service Agreement (PSA) target to reduce the proportion of 16-18 year olds NEET by 2% points from 9.6% in 2004 to 7.6% by 2010. By 2007 this figure had actually risen and stood at 9.7%, and whilst the data for August 2008 shows that the NEET rate for 16 and 17 year olds fell very slightly (although not significantly), a large increase in the 18 year old NEET rate led to an overall increase in the 16-18 year old NEET rate once again to 10.3%.[1] The NEET strategy published by DCSF in November 2007 set out a number of ways to improve the situation, although given the current rise in NEET it seems evident that these have not as yet had the desired effect.

 

7. Tracking procedures to give early indication of NEETs or potential NEETS at Connexions were improved as a result of the publication of the NEET strategy, but in the experience of our members the effectiveness of this tracking in being turned into an working "anti-NEET" strategy has had, to say the least, only mixed results at local level, being very dependant on the efficacy of local Connexions offices.

 

8. We believe that at least part of this failure has been to due to Connexions being informally guided towards concentrating on provision for disaffected and disengaged young people, resulting in individual offices varying in which cohort of young people they tend to mainly accommodate. As a result, NEET strategy nationally has not been effectively implemented by Connexions offices. ALP believes that getting information, advice and guidance (IAG) right is essential if we are to really tackle the NEETs issue, and successfully re-engage young people into learning. At the moment the quality of IAG available is very mixed and a real drive is needed to ensure a quality IAG service is available to all young people, whether potentially NEET or not. ALP believes that this is key to identifying those young people at risk of falling into the NEET category and channeling them to the appropriate route to enable them progress and achieve the skills they need for life and work.

 

Foundation Learning and Entry to Employment

 

9. Another strand of the strategy was to ensure the provision of suitable provision "at every level....for every style of learning; everywhere in the country; that enables them to progress; and to achieve the skills they need for life and work."[2]

 

10. Part of this was to reform the qualification framework to make it more fit for purpose, and it was felt that given the characteristics of many of the NEET group it is "particularly important to have good level 1 and entry level provision. Currently one of the most effective programmes with young people who are NEET or at risk of being NEET is Entry to Employment (e2e). e2e is a work-based learning programme for those young people aged 16-18 who are not yet ready or able to enter an Apprenticeship, employment or further learning opportunities."[3] ALP wholeheartedly supports this view of e2e. Indeed, one of the key features of e2e is that it recognises progression into work as a positive outcome. Our members find that securing a job as a result of participating in e2e builds the self esteem and confidence of many of the young people on the programme, enabling them to move onto other learning programmes at a later stage in their working life once they feel competent to do so, often then gaining the qualifications they had turned their back on when younger.

 

Now, however, e2e is planned to be merged into FL as part of an exercise to "build on its success". This has always been difficult to square, because part of the effectiveness of the e2e programme, as suggested above, has always been that it did not necessarily rely on the attainment of a qualification in order to be seen to work - it concentrated in a large part on the attainment of "soft" employability skills, and indeed saw employment (in any form, with or without formal training attached) as a positive outcome for many of its participants for whom study towards a qualification was clearly not appropriate. Although a job without training is currently seen as a positive progression from e2e, this would only be possible in a relatively limited number of instances under the FL. Therefore what is happening is that a very successful programme of delivery that packaged up and delivered employment, soft skills and qualifications (both accredited and non-accredited) in a personalised fashion for unemployed 16-18 year olds, is being subsumed into a framework totally predicated on the attainment of accredited qualifications. Just about the only programme of holistic pre-employment provision for 16-18 year olds (as almost nothing is available to them under welfare-to-work provision) is therefore being abolished at a time when the need to move young people into employment has never been higher.

11. It is also unhelpful in that many potentially NEET young people will not be attracted to the prospect of a qualifications-based programme. (If they did, the likelihood is that they would have stayed on at school or applied to go to College). Therefore by losing a programme which can be directly marketed as a way into employment, and replacing it with an overtly qualifications-based framework, the option of engaging NEETs into learning by marketing employment opportunities is lost.

 

12. FL's Progression Pathways - effectively rules of combinations for the funding of qualifications below Level 2 in the new Qualifications Credit Framework (QCF) - have been through several iterations and now allow for more scope for employment-related outcomes than was originally evident. However it is still not enough bearing in mind what it seeks to replace, concentrating its efforts on those with learning difficulties, disabilities or other special needs, whereas there are a far larger cohort of young people who do not fall into these categories; for whom study towards qualifications is simply not appropriate but for whom almost any form of employment would be. As explained earlier, attaining employment is in itself an important step on the ladder towards re-engaging with learning, but FL fundamentally fails to recognise this. At present it offers nothing to encourage such young people, beyond the maxim that "qualifications make you more employable" - an arguable point in that it is more likely to be skills that make one employable, and whilst qualifications are often used as a proxy for skills, the two are not synonymous.

 

13. ALP has been reassured by Learning and Skills Councils officials responsible for devising FL that e2e will not be completely phased out until a suitable replacement is in place. However, as much hangs on what is seen as "suitable" ALP would wish to be fully involved in any groups and discussions set up to define this

 

Impact of transition to the Qualifications and Credit Framework

 

14. Compounding this problem is the guideline requirement for providers to be delivering at least 30% of their e2e provision in the current year using QCF qualifications. The QCF is as yet not sufficiently populated to allow this to happen, meaning that many e2e participants are already being short-changed relative to previous participants on the same programme. Indeed, the LSC is currently urging all providers to maximise their current claims in order to avoid the possibility of unused contract monies being re-allocated to other, "better performing" providers, despite the fact that delays in approving funding for some QCF qualifications means that provision may not be funded even though it has been delivered in accordance with the guidelines. Moreover, we have been unable to get any assurances that the amounts concerned will not be clawed back even though the inability to apply for funding for the qualifications that are required by FL is not a problem over which the provider has any control.

 

15. This means that e2e - and indeed a wider range of qualifications - is already becoming operationally more difficult and costly to deliver, leading to a situation where "one of the most effective programmes with young people who are NEET or at risk of being NEET" may well be curtailed even quicker than planned as it becomes progressively more difficult and less viable to deliver.

 

16. It is extremely important that during this transition phase towards the QCF, that providers are assured that its impact will not adversely affect their ability to draw down funding for work already delivered within the rules, within provider guidance, to the required standards and in good faith. There must be an early agreement on how audit arrangements will ensure that structural funding issues relating to QCF implementation will not adversely impact upon training provision - particularly that for e2e - delivered to the required standards and in good faith and ALP would welcome the opportunity to discuss with both policy makers and funders how this can best be achieved.

 

 

Education Maintenance Allowances

 

17. One area that has improved immensely over the last year or so is the provision of Education Maintenance Allowances (EMAs), which are a key factor in supporting participants on e2e programmes. Research has demonstrated that the introduction of EMAs has indeed increased retention and achievement on such programmes,[4] The extension of EMAs to work-based learning was welcomed, as was the subsequent removal of means-testing for young people on e2e programmes.

 

18. Some questions remain about EMAs - for example, the relative effect of the 10/wk and 20/wk payments as opposed to the 30/wk payments - but in the view of our members these remain an overwhelmingly positive and beneficial support for e2e learners.

 

19. We are therefore concerned that the subsumation of e2e into FL means young people who would previously have qualified for non-means tested EMAs will now have to undergo means-testing alongside all others. We understand that there may be some issues regarding the potential identification of this cohort under FL once e2e has gone, but believe this supports our case that e2e and Progression pathways under FL are not interchangeable and cannot be seen as either equivalent programmes nor as "building" on each other.

 

20. The loss of e2e therefore not only means losing an effective and popular programme for disengaged and disaffected young people, but it also means the removal of tailored financial support arrangements to encourage participation and retention in learning of disengaged youngsters that have been proved to work. This reinforces our stated view that the loss of e2e is neither desirable nor being undertaken on the basis of a sound rationale of improvement of provision for NEETs.

 

Funding and contract flows

 

21. Significant concerns are abroad amongst providers regarding the proposed changes to contracting and funding flows that will come into force following the dissolution of the LSC in March 2010. In particular many providers feel that the fact that all e2e providers are being required to negotiate contracts at local authority level is very unsatisfactory when much e2e provision is provided on a national scale. This is compounded by the fact that contracting for provision for FL in general becomes unclearly defined once e2e ceases to be.

 

22. ALP has long been arguing that there must be provision for e2e to be contracted at a national scale in order that the economies of scale that can be generated by contracting at this level can be retained. Without this, many providers will find resources being diverted into servicing a vastly over-complicated commissioning and funding system instead of being able to deliver quality front-line services. This does not preclude the notion of localised contracting, but must at the very least sit alongside it.

 

23. In fact, the complexity of the system being implemented is such that there is a distinct danger of specialist and niche provision - particularly that for disengaged and hard-to-reach young people - being overlooked amidst the plethora of planning, funding and contracting interfaces that will now be required.

 

24. For example, the oversight of provision for young people with disabilities and learning difficulties does not squarely rest with any one particular body. Although we acknowledge the argument that local authorities are the most likely point at which such responsibility would rest, should provision be (for example) insufficiently catered for as a result of contracting it is difficult to know who, amongst the local authority, the Regional Planning Group, the Young Person's Learning Agency (YPLA), the Skills Funding Agency (SFA), the Regional Development Agency (RDA) and the National Apprenticeship Service (NAS) should be held accountable. The fact that many providers, particularly independent ones, are finding it difficult to find their way on to local planning groups is unfortunately demonstrative of the real danger that localised quality provision may be overlooked by the new system, and thus lost.

 

25. A number of our members have also expressed concern at the movement of funding within e2e towards qualifications and rapid progression at the expense of programme payments. This makes working with those furthest from the labour market economically more difficult to undertake at a time when it is such people that require the most help.

 

Other provision

 

26. NEET provision is not of course restricted to e2e; nor is the cohort restricted to the disaffected and disengaged. Many providers are concerned at some of the indirect ramifications of the movement of Apprenticeships to "employed status" programmes. There are many "Programme-Led Apprenticeships", which facilitate the first steps in engagement in some more specialised industries and occupations that are in danger of being eliminated completely by the current moves to more clearly identify Apprenticeships. The value of what these programmes provide should not be overlooked and a way must be found to ensure this valued and valuable provision is retained in some form or another. In addition, in some sectors of the economy employed status Apprenticeships only could become a barrier to young people becoming engaged at all. For example, the legal and regulatory requirements surrounding those in the health and social care sectors mean that many 16 and 17 year olds are simply not allowed to take on employment of a nature that would allow them to gain the necessary skills and experience to make a career in this field. Similarly, some sectors require basic levels of specialist skill and competence before even considering employed status, and if provision is not made for employer located learning opportunities to act as a gateway to Apprenticeships then some occupational sectors may adversely suffer.

 

27. ALP believes it essential that high quality level 2 programmes located in the workplace are available in increased numbers both during and following the economic downturn. Whilst the target must be to ensure that Apprenticeships are employed from day one, a realistic short term compromise must be tolerated whilst employment opportunities are reduced because of the economic situation. It is already clear that the recession is already reducing the number of work located opportunities - and that they will reduce further unless steps are taken to prevent this.

28. Not only must existing opportunities be protected, but also new ways found to bridge the gap between school and work. Making practical 'pre-Apprenticeship' opportunities available, ie extra workplace (employer located) provision that can easily be turned into employment once the upturn comes, will be essential. Ways must also be explored to maximise the employer located places that are available. This might perhaps be achieved by making it possible for young people to be moved around, so that one employer place is available for two (or perhaps in some cases more than two) learners. An alternative might be for the providers, with appropriate government support, to employ the young people themselves, seeking additional employer sponsorship wherever possible - hence sharing the risk.

29. The social as well as economic benefits of creating such opportunities to develop these young people so that they are ready to move swiftly into employment when the opportunity arises cannot be over estimated. We firmly believe that if the Government offered a training allowance for these young people the long term cost to the taxpayer would ultimately be reduced, with fewer people claiming long term benefits, and indeed entering the income tax regime.

30. ALP would welcome the opportunity to discuss these ideas further, exploring how they might be developed and put into action.

 

December 2009



[1] http://www.dcsf.gov.uk/rsgateway/DB/STR/d000870/NEETQuarterlyBriefQ22009.pdf

[2] www.dfes.gov.uk/14-19/documents/NEET%20%20Strategy.pdf (Para 18)

[3] www.dfes.gov.uk/14-19/documents/NEET%20%20Strategy.pdf (Para 20)

[4] http://www.ifs.org.uk/publications/4129