Education Bill

Memorandum submitted by The Edge Foundation (E 13)


1. The Edge Foundation recommends adding a clause to Part 3, in order to enable further education teachers with "Qualified Teacher Learning and Skills" status to teach in secondary schools on equal terms with teachers with "Qualified Teacher Status".

2. We welcome clause 22 (the qualifications standards objective), provided qualifications are more than a test of factual knowledge alone. Places which outperform England in international league tables (eg Shanghai and Finland) emphasise the application of knowledge as well as skills and abilities such as creativity, problem-solving and teamwork. Ofqual also needs to compare English technical and vocational qualifications with the best offered in other parts of the world.

3. Clause 27 (careers education) should apply to a wider age range, starting not later than the year in which young people reach the age of 13, and extending in stages to age 17 (in 2013) and age 18 (in 2015).

4. While not opposing the repeal of the Diploma entitlement (clauses 28 and 29), we do not want valuable lessons to be lost. Some Diplomas show promise, particularly in motivating students who enjoy a more "hands-on" style of learning.

5. We support clause 36 (establishment of new schools), but seek assurances that nothing in the Bill will inhibit the development of new types of school including University Technical Colleges and Studio Schools.

6. We agree that Ofsted inspections should focus on a smaller number of judgements (clause 40). However, we strongly recommend that Ofsted should also assess how well educational establishments prepare students for their next step. This should start with evidence of the number of young people in education or training a year after leaving school or college.

7. Edge supports clauses 65 and 66 (apprenticeships), but recommends that funding should also be prioritised for Higher Apprenticeships in sectors or occupations prescribed by the Secretary of State.

8. We do not object to the principle of fees for part-time higher education courses (clauses 70-71). However, we seek assurances that fees will vary according to the nature, setting and relative costs of courses.


9. The Edge Foundation is an independent educational charity dedicated to raising the stature of practical, technical and vocational education. The Foundation is sponsor of the Bulwell Academy (Nottingham) and Milton Keynes Academy, and has provided support in cash and in kind to support the development of University Technology Colleges, Studio Schools, a hotel school, and work-based higher education.

10. In this submission, we comment only on those clauses of the Bill which relate to our areas of interest.

Part 3: School Workforce (clauses 7 to 19)

11. Edge supports the changes set out in Part 3 of the Bill. However, we believe the Bill should also make it possible for fully-qualified further education teachers to teach in secondary schools on equal terms with existing school teachers.

12. At present, people who wish to teach in schools must complete an undergraduate degree and then undergo training leading to Qualified Teacher Status (QTS). There is no requirement for teachers in secondary schools to have experience or expertise in any vocational subjects they teach.

13. Separate arrangements apply to people who wish to teach vocational subjects in further education colleges. Prior vocational experience is essential, but a degree is not. Teaching skills are developed and recognised through a four-tier qualification system culminating in Qualified Teacher Learning and Skills status (QTLS).

14. FE teachers with QTLS accreditation may work in schools as "instructors", but not as teachers. Instructors have a lower professional status – and usually a lower salary – than school teachers, even though they perform essentially the same functions. Their promotion prospects are also much more limited.

14. In its report, "The Training of Teachers" [1] , the Children, Schools and Families Committee said –

At the very least, teachers with Qualified Teacher Learning and Skills status should immediately be able to work as a qualified teacher in schools if they are teaching post-16, even post-14, pupils.

15. The Government has asked Professor Alison Wolf to review 14-19 vocational qualifications. Her remit includes work force issues. Professor Wolf is expected to complete her report in late February or early March. If she recommends giving holders of the QTLS the right to work as teachers in secondary schools, the Standing Committee should consider introducing a new clause into Part 3 of the Bill to implement this long overdue reform.

Part 4: Qualifications and the Curriculum (clauses 20 to 29)

The qualifications standards objective (clause 22)

16. Clause 22 requires Ofqual to check that regulated qualifications are set at levels of attainment equivalent to comparable qualifications. This has two effects. First, Ofqual will be able to decide if technical and vocational qualifications (eg BTECs) are equivalent to GCSEs. Second, Ofqual will compare English qualifications with qualifications in other parts of the world.

17. Edge welcomes clause 22 for three reasons.

18. First, clause 22 says qualifications must give "a reliable indication of knowledge, skills and understanding". This gives "skills" the same status as "knowledge" and "understanding", which is essential if we are to raise the stature of practical, technical and vocational education.

19. Second, existing measures of the "equivalence" of GCSEs and vocational qualifications are arbitrary and sometimes illogical. Some vocational qualifications are said to be equivalent to four GCSE passes at A* to C: this is definitely open to challenge. However, the debate has centred on "equivalence" when the real question should be how we provide good quality technical and vocational options as part of a broad and balanced curriculum. We agree with the Secretary of State, Michael Gove, who said –

We have to take action to improve vocational education before people leave school. We have to have courses, qualifications and institutions during the period of compulsory schooling which appeal to those whose aptitudes and ambitions incline them towards practical and technical learning … It’s not either/or but both/and. [1]

20. Third, we welcome the idea of comparing English qualifications with the best in the world. So far, much of the debate has focused on English, maths and science, but it is just as important for us to match the high standards other countries – Germany, for instance – achieve in technical and vocational education.

21. It is also important to recognise that the curriculum – and the qualifications which support it – must develop a broad range of abilities, rather than being limited to a list of facts. In this context, it is instructive that international comparisons of young people’s educational achievements do not focus narrowly on knowledge alone. For example, the OECD’s Programme for International Student Assessment (PISA) measures the abilities of 15-year olds in reading, maths and science. The resulting international league table is often quoted by politicians and journalists.

22. However, it is not widely understood that PISA monitors -

· the capacity of students to extrapolate from what they have learned and to apply their knowledge in novel settings

· students’ capacity to analyse, reason and communicate effectively as they pose, solve and interpret problems in a variety of situations

23. PISA tasks relate to real life, and depend on a broad understanding of key concepts. In other words, PISA is not simply a test of how well young people read, how well they can add, subtract, multiply and divide, or whether they know what photosynthesis is: PISA tests the ability to apply knowledge to a particular task or context.

24. English 15-year-olds perform at or close to the OECD average. Critics seem to assume that other countries do better because their curricula and qualifications are based on knowledge alone. This is not the case. According to the OECD [2] , Shanghai (top of the league table in 2009) reformed the curriculum with the express aim of to ‘transform[ing] students from passive receivers of knowledge to active participants in learning, so as to improve their capacity for creativity and self-development and to fully achieve their potential’. In Finland – which ranked second out of all OECD countries in 2009 – ‘employers sent very strong signals to the schools about the kinds of knowledge, skills and dispositions young people needed in order to be successful in the new economy. Finnish industry leaders not only promoted the importance of mathematics, science and technology in the formal curriculum, but they also advocated for more attention to creativity, problem-solving, teamwork and cross-curricular projects in schools’. As a consequence, ‘Students are expected to take an active role in designing their own learning activities [and] to work collaboratively in teams on projects, and there is a substantial focus on projects that cut across traditional subject or disciplinary lines.’

25. It is essential to reflect these wider skills – and the needs of employers – in the design of the English curriculum and qualifications. By extension, they must also be taken into account by Ofqual when implementing clause 22 of the Bill.

Careers education and guidance

26. Clause 27 requires maintained schools and pupil referral units in England to secure independent careers guidance for pupils in the school year in which they reach the age of 14 (typically, Year 9 of secondary school) until they have ceased to be of compulsory school age (age 16/end of Year 11). Careers guidance must be impartial, and must include information on 16-18 education and training, including apprenticeships.

27. The clause makes it clear that young people must have access to careers guidance from outside their school: it is not enough for the school’s own staff to provide careers guidance. This is welcome, because school staff generally know a lot about GCSEs, A levels and degrees, but little about alternatives such as apprenticeships. [1]

28. As drafted, clause 27 does not apply to academies. Ministers have suggested that an equivalent requirement will be imposed on academies by non-statutory means. However, we consider that the clause should apply to all state-funded secondary schools, regardless of their status.

29. Secondly, the age range is too narrow. Young people should have access to impartial information, advice and guidance well before they choose their options for Key Stage 4. Some schools already operate a two-year Key Stage 3, which means their pupils will be choosing Key Stage 4 options before they have had any impartial advice. The right to impartial guidance should therefore start no later than Year 8 (the year in which children reach the age of 13), or better still in Year 7.

30. Equally, access to impartial careers information and guidance should continue beyond the age of 16. Young people will be required to stay in education or training until the age of 17 from 2013, and age 18 from 2015. The entitlement to impartial careers advice should rise exactly in parallel – that is, to age 17 from 2013, and to age 18 from 2015.

Repeal of diploma entitlement for 16-18 year olds and Key Stage 4

31. Clauses 28 and 29 overturn the previous Government’s expectation that in time, all young people aged 14-18 would be able to access any of the Diploma "lines of learning" (subjects).

32. It was always going to be difficult to deliver the entitlement, especially in rural areas. In any case, the entitlement goes against the Coalition’s view that decisions on courses and qualifications should be taken locally. For these reasons, Edge does not oppose clauses 28 and 29.

33. At the same time, it is important to recognise that Diplomas – or at least, some of them – have shown real promise. Edge followed the implementation of the first five Diploma lines of learning in North Hertfordshire, starting in 2007 and carrying on to 2010, when Diplomas were awarded to the first group of students enrolled on two-year courses.

34. The first phase of implementation highlighted a number of challenges, including low take-up of some lines of learning. It was also a requirement that students move from one school to college to another for part of their course, and this caused logistical problems in terms of the school timetables and transport arrangements.

35. There were, however, positive messages:

a. Diplomas proved successful in motivating students who enjoy a more "hands-on" style of learning. Students also liked having more responsibility for their own learning.

b. The Diploma combines academic and applied learning. Young people welcomed the opportunity to see how knowledge learned in the classroom is used in the workplace.

c. Diploma students are required to have experience of work as part of the programme. This was highly valued as – again – it reinforced the connection between classroom learning and the world of work.

d. Curriculum content was developed by teachers on the ground. This had a positive impact on their own professional development as well as on the quality of the learners’ experience.

Part 5: educational institutions: other provisions (clauses 30-49)

Establishment of new schools (clause 36 and schedule 10)

36. Broadly speaking, clause 36 and schedule 10 create a presumption that new secondary schools (other than those with a religious character) should be academies. Edge sponsors two academies – Bulwell (Nottingham) and Milton Keynes. We are therefore long-standing supporters of academies, and welcome clause 36.

37. Edge also strongly supports the development of University Technical Colleges and Studio Schools. We believe diversity will help to drive improvements in standards across the education system as a whole. UTCs and Studio Schools will also boost the achievement and ambitions of many young people who know they enjoy a hands-on style of learning.

38. Our only reservation is that UTCs and Studio Schools are not explicitly mentioned in schedule 10. We would welcome Ministers’ assurances that the new provisions will not hinder the development of UTCs and Studio Schools across England.

Ofsted inspections (clause 40)

39. Clause 40 reduces the scope of Ofsted school inspections to just four judgements:

· the achievement of pupils;

· the quality of teaching;

· the quality of leadership in and management of the school; and

· the behaviour and safety of pupils.

40. Edge accepts that Ofsted reports should concentrate on a smaller number of priorities. However, we believe there is one over-arching theme that should always be considered when judging a school’s performance – namely, what happens to pupils when they leave school.

41. Clause 26 of the Bill (education and training support services) permits data to be shared between the Department for Education and the National Client Caseload Information System. This will make it possible to publish anonymous data about what young people do after they have left a school or college – for example, the proportion who go on to further learning, an apprenticeship, or a job without training. The data will shed light on the choices made by young people, including trends in (say) applications to university and the uptake of apprenticeship places.

42. These figures should be used by Ofsted to underpin a judgement about how well a school prepares young people for their next step in life. This is extremely important, because the purpose of education is not limited solely to the qualifications someone achieves at 16 or 18. Accordingly, every school or college should be measured, in part, on the proportion of young people who are in education or training a year after leaving that school or college. This measure should apply to all young people who leave a school or college at the ages of 16, 17 and 18.

Part 7: post-16 education and training (clauses 62 to 69)

Apprenticeships (clauses 65 and 66)

43. Edge welcomes the Government’s strong commitment to apprenticeships, which provide an ideal route for a growing number of young people who want to develop vocational skills and knowledge in the work-place.

44. Clauses 65 and 67 alter legislation introduced by the previous Government, the Apprenticeships, Skills, Children and Learning Act 2009, which offered an almost unlimited entitlement to an apprenticeship place. This would in practice be problematic – especially in rural areas, or in sectors of the economy where there are simply not enough paid positions for all the young people who want one. Clause 65 remains true to the overall aims of encouraging apprenticeships, while introducing pragmatic limits to the entitlement.

45. When the 2009 Act was before Parliament, Edge made the case for extending the apprenticeship entitlement to Higher Apprenticeships, which are highly valued in sectors such as telecoms and aerospace. There is a strong case for extending clause 65 to Higher Apprenticeships in sectors to be specified by Ministers.

Part 8: student finance (clauses 70 and 71)

46. Clause 71 enables the Secretary of State to cap the fees part-time students are required to pay higher education institutions. According to the Explanatory Memorandum, "this will ensure that part-time undergraduate students can be treated in a way which is commensurate with the treatment of full-time undergraduate students".

44. On the face of it, this is fair and logical. However, Edge is concerned that new fee arrangements could discourage the take-up of innovative work-based higher education courses.

45. Edge helped pilot new courses through HE@Work, which is now part of Middlesex University. The pilot courses showed it was possible to get recognition for skills and knowledge acquired at work and combine these very successfully with additional learning at a higher level. The result was to improve access to higher education for people who would not otherwise have the time – or perhaps the money – to enrol on conventional higher education courses.

46. While we do not object to the principle of fees for part-time courses, we hope Ministers will provide assurances that fees will vary according to the nature, setting and relative costs of courses.

February 2011


[1] Edge lecture , 8 September 2010,

[2] OECD (2010), Strong Performers and Successful Reformers in Education: Lessons from PISA for the United States

[1] In 2009, YouGov surveyed 712 teachers in state schools. 74% rated their knowledge of GCSEs as good or very good, but only 16% rated their knowledge of apprenticeships as good or very good. Source: YouGov survey for Edge. Fieldwork carried out 2-8 October 2009.