Skills and Post-16 Education Bill [HL]

Written evidence submitted by Central YMCA (SPEB01)

R esponse to the Skills and Post – 16 Education Bill.

Central YMCA broadly welcomes the intention and direction of the Skills and Post – 16 Education Bill, particularly the additional significant investment of 42% in cash-terms increase. This bill, in general, is encouraging given that participation in adult skills and lifelong learning is at its lowest level in 23 years. Nine million working-age adults in England have low literacy or numeracy skills, and 6 million adults are not qualified to level 2.

However, we feel, based on our experiences of vocational training and education provision since the early 1970’s, that more can and must be done to increase learner and employer choice therefore facilitating the aspirations of the broadest possible range of young people in terms of background and ability.

We believe that FE and skills provision should secure sustainable employment for individuals while retaining a drive towards improving social mobility or ‘levelling up’. To achieve this, the bill requires strengthening in certain areas.

Our responses in summary:

· The detail of the Local Skills Improvement Plans (LSIP’s) need clarification.

· The de-funding of several level 3 qualifications requires a published staged process.

· The conditions for providers joining the approved list require robust scrutiny.

· The rigour of the Baker Clause, part of the Technical and Further Education Act of 2017, and the promised three- point enforcement needs clarification before further legislative processes take place.

1. The case must be made clearer for Local Skills Improvement Plans

Although we welcome news that learning providers will be given a role within LSIPs, we remain concerned that they are not a solution to the employment engagement issues identified in the DfE’s impact assessment document. Furthermore, there is absolutely no guarantee that LSIPs will be able to articulate employer and learner demand everywhere and so the bill’s provisions on this require scrutiny. We would like to hear a stronger rationale from ministers for proceeding with them including an explanation of how local authorities that are not combined mayoral authorities will be represented, particularly Suffolk where Central YMCA has three training centres and numerous apprenticeship placements, and what role will the current LEP’s have in relationship to LSIP’s?

It is concerning that the bill will require all relevant providers "to co-operate" with LSIPs, yet only subsequent statutory guidance will set out how the LSIPs themselves may engage with local providers and other stakeholders. This could potentially be a one-way street; the sector must co-operate with LSIPs but LSIPs may have no requirement to work with local providers. We feel that it should be made clear that LSIPs should draw on the views of independent training providers, as well as schools and FE colleges, and that the relationship should be outlined in the bill as being a condition of the decision- making process. 

2. The de-funding of several level 3 qualifications.

At the second reading of the Bill the Secretary of State announced that there would be a one -year reprieve to the defunding of some BTEC’s and level 3 qualifications. Central YMCA support the House of Lord’s amendment which proposes a four- year moratorium on these BTEC and level 3 qualifications as one year is simply inadequate for learners and providers to come to terms with the new T Level offer.

The Education Datalab found that young people who took BTECs and Level 3 qualifications were more likely to be in employment at age 22 and at that age were earning about £800 more than their peers taking A Levels. These are qualifications, therefore, with good outcomes and we propose that whilst T-levels are embedded in the education system, quality level 3’s and BTECs should remain for all students to access .

However, many of Central YMCA learners are no-where near achieving a level 3 qualification and over 80% of 16–18-year-olds arrive in our facilities are not in education employment or training. Therefore, the funding of pre level 2 and level 2 qualifications to provide a progression route to level 3 is, in our view, essential to promote social mobility and support the levelling up agenda. We ask again that Ministers consider this.

3. Regulated list of relevant providers

Central YMCA has no issue with new legislative measures to protect the interests of learners if ministers feel more are necessary - for example, we understand why those who run providers on the proposed list of relevant providers should be ‘fit and proper’. However, any conditions imposed on providers should be proportionate. There is some reference in the White Paper to FE Colleges being exempt from the list of relevant providers placing a disproportionate responsibility on independent providers (ITP’s). However, we are fully supportive of a robust and reliable register providing the criteria is clear and fair to all.

We are pleased that the government intends to consult on the specific requirements for registration and will look forward to contributing to the consultation. We also understand the need to protect learners from early closures of providers or the failure to provide quality provision, and therefore student support plans highlighting procedures for the management of provider closure and insurances to provide financial support where required are sensible. However, the criteria should not focus disproportionately on provider failure but more so on quality provision. As no consultation has yet taken place on the conditions attached to a provider being on the new list, we feel that this will require full scrutiny at committee stage.

4. Measures to extend and better enforce the Baker Clause

We welcomed the inclusion of the Baker Clause in the Technical and Further Education Act 2017, and we have worked with the Department for Education on monitoring its effectiveness by producing a report in 2018 on the number of schools linked to Central YMCA centres who were not compliant. There is growing concern that the clause lacks teeth and there is a widespread lack of compliance which is of concern as enforcing the clause gives us the opportunity to improve careers education and guidance. According to the Institute for Public Policy Research, just two in five schools have been complying with the Baker clause and our experience is that in many areas it is far less than this. Central YMCA holds career events every April and May to attract young people to our vocational offer and in our experience far less than 2 in 5 schools open their doors to our tutors and past learners to fully experience the wide array of training and education options on offer. In fact, the single focus by some schools on university entry can be inappropriate for many of the pupils involved and we agree with the Chair of the House of Commons Education Committee when he suggests "directing some of the £800 million currently spent on widening access to universities towards supporting students from disadvantaged backgrounds to do apprenticeships."

We also agree with the Education Committee’s recommendations that compliance with the Baker clause be linked to Ofsted inspection outcomes where schools should not be given a good or outstanding rating unless they comply with the clause.

Central YMCA – overview.

Central YMCA was established in 1844 and is the world’s oldest YMCA. Today, we are one of the UK’s leading health, education, and wellbeing charities, with the goal of helping people to live happier, healthier, and more fulfilled lives. We deliver training courses and apprenticeships from pre-16 to Level 5 in a wide range of sectors including vehicle maintenance, horticulture, child- care, sport and leisure and health and social care. Delivering and awarding qualifications funded by government since the 1970’s we take pride in the achievements of those who access our training as most are from challenging environments in difficult circumstances, particularly those on our Study Programmes of who 84% are not in employment, education or training when they register with us.

November 2021