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Government review into funding of qualifications at level 3 and below: Don’t kick away the ladder of opportunity for learners!

Paul Eeles, Chair of the Federation of Awarding Bodies
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We must not let the government’s rationalisation of qualifications kick away the ladder of opportunity for learners

The chair of the Federation of Awarding Bodies, Paul Eeles, argues that Ministers should seek more independent advice in deciding the future funding of qualifications:

Probably everyone reading this article, at some point or other, has attended at least one education awards ceremony.

What makes these occasions so inspirational, is that they lend visible support to the idea that qualifications help transform the lives of individuals.

It is not just the glowing pride expressed on the faces of parents, tutors and students; but the fact these awards can often kick-start a whole new chapter in someone’s life.

The hairdresser, butcher, auto-mechanic and the lab-tech have all had to gain recognised qualifications in order to ply their skilled trades. That is after all what being qualified means.

The same is true in the regulated professions. Who wants to take advice from a quack doctor or a legal adviser who is not proficient in the practice of medicine or law?

As consumers, we take the existence of these different qualifications for granted. Of course, we expect government to watch our backs and ensure that the qualifications system is fit for purpose.

It’s one of the main reasons why Britain has such a healthy qualifications marketplace; and why so much of our awarding and assessment expertise is exported abroad.

Across the UK, there are four statutory qualification regulators, who subject awarding and assessment bodies to the most stringent of recognition conditions.

Regulated awarding organisations, like those recognised by Ofqual in England, must deliver the highest quality of service to learners and employers or face the ultimate sanction of being financially fined or potentially forced to close.

It is against this already quite heavily regulated industry that the government is currently reviewing, in stages, qualifications eligible for public funding in England from Entry Level to Level 3.

GCSEs and A-Levels are excluded from these reviews, as are over 50,000-degree courses offered by higher education institutions. In the government’s current sights are post-16 technical and vocational qualifications at Level 3 and below that are eligible for government funding. The majority of these qualifications will be provided by further education colleges and independent providers, awarded by regulated AOs.

The word ‘eligible’ for public support is important here; because of 12,100 qualifications at Level 3 and below that can currently access public funding, 42 per cent of them have not drawn down a single penny of taxpayer’s money since 2015. And when accounting for low enrolments of qualifications (perhaps because these courses support learners with special educational needs or serve niche occupational sectors), the actual number of Level 3 and below qualifications that are widely available and funded by the public purse is below 4000.

Following on from the Wolf and Sainsbury Reviews, the Department for Education has continued to repeat some of the well-worn mantras about vocational qualifications:

  1. “There is little demand for many qualifications”
  2. “Too many qualifications are of low quality”; and
  3. “The landscape is confusing for students and employers”

I want to deal with each of these issues of demand, quality and confusion, head on:

1. Demand for qualifications reflects a complex economy

One of the major reasons why we have nearly 13,000 qualifications on the Register of regulated qualifications at level 3 and below today is because at some point in the last decade or so, learners, providers and employers have demanded them. It is a complex and very costly process to develop any type of qualification.

The idea that awarding bodies would develop a qualification in order to access public monies, is a factious argument to make. Regulation is another key driver, hence the growth of qualifications relating to complying with health and safety legislation.

The UK’s open, service orientated economy, is literally made up of thousands of different occupations; including many niche industry sectors. Is it really that surprising then to find a large array of different qualification choices?

Of course, if there are qualifications that no longer meet the primary purpose for which they were originally developed, then it makes sense that AOs would want to cease offering them. But this is a house-keeping exercise that should be encouraged as part of a dynamic dialogue between the awarding industry and government.

Ministers’ and senior advisers’ willingness to talk up the “lack of demand” for these qualifications seems more like a crude device to justify the wholesale rationalisation and manipulation of an already well-functioning market. If the latter aim is the case, then government should say so explicitly.

Engaging in reform on the basis of simply rubbishing what already exists only undermines the achievements of many tens of thousands of learners – both past and present.

The evidence shows that the majority of qualifications at Level 3 and below for young people and adults help support their career progression and, crucially, social mobility. They provide learners – including those that have been failed by the schools’ system – with a stepping stone to future success.

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Qualifications at Level 3 and below help older learners re-skill and re-train for a new career. Any new measure of learner progression will need to be sensitive to the geographical context and individual circumstances of students.

Requiring that a Level 1 qualification developed for those with special educational needs or some other social purpose, should have a direct line of sight to employment, is not as appropriate as requiring a Level 3 in aromatherapy to be a qualification route to a very specific career.

What the Federation of Awarding Bodies will simply not countenance – with potentially such a crude top-down approach being undertaken by government as a result of this qualifications review – is to stand by, while the ladder of opportunity is kicked away from millions of our fellow citizens.

2. Quality is what regulators are for

The second claim in the review is that too many of these qualifications lack quality. If that is really the case then why hasn’t the government given regulators like Ofqual more power and resources to assure a programme of continuous quality improvement? The whole purpose of regulated qualifications is to provide the public with confidence that a qualification is fit for purpose.

Placing the blame for “poor quality” of regulated qualifications solely at the door of AOs is to put the cart before the horse. In the second stage of the consultation review, the Department for Education should set out more clearly what regulatory powers, if any, Ofqual will need to resource in order to deliver on its statutory remit to secure public confidence in both general and vocational qualifications.

Members of the Federation of Awarding Bodies already work with employers to ensure that vocational and technical qualifications lead to career progression. Ultimately, an attack on the quality of qualifications is to call into question the quality of regulation.

It is hard to fundamentally disagree with the principles for funding qualifications that government is currently consulting on. The overriding principle, however, should be one of flexibility.

Moreover, we need a qualification system that is built on real market choice, empowering educators and learners, to make informed decisions about which qualifications are best for them.

Trying to secure the success of new T-levels, for example, by restricting the market for applied generals or other qualifications that may be seen to be competing with them is a really retrograde step. It robs both educators and learners of choice.

If students, colleges, universities and employers already value these qualifications and it is clear they have real currency, then the government should not be trying to cease funding them.

3. Confused.com

The third reason given for a major cull of qualifications below Level 3 is that the landscape is confusing. Of all the various mantras in recent years, this is perhaps the most ill-informed. As Tom Bewick, chief executive of the Federation of Awarding Bodies, has pointed out in an article for FE News, it is simply nonsense and economically illiterate to suggest that AOs produce too many qualifications, or that the current marketplace is confusing.

As Tom explains, all consumer and product markets are by definition quite complex. Yet, government does not restrict the number of goods available on our supermarket shelves or package holidays on travel websites. Instead, it ensures that – via appropriate forms of regulation – that food and service product standards are adhered to.

Ofqual performs a similar role to protect the interests of learners, although it stops short of artificially trying to manipulate the size and shape of the qualifications’ marketplace.

Indeed, we believe that it should be left to colleges, parents and students to dictate how many qualifications are needed, not Whitehall officials trying to second guess learners by prescribing to them what they themselves believe is best.

Evidenced-based decision making

Ultimately, the next stage of the Level 3 and below qualifications review will come down to whether government believes in real learner choice or not. We will be encouraging officials to examine closely the evidence that our members will be submitting; and consider the potential adverse impact of some of their proposed changes.

At the Federation, we are also consulting with members on a proposal to inject more independence into the process of deciding which qualifications should be eligible for public support in future.

We’ve floated the idea of establishing some form of commission or independent reference panel to make recommendations to the Department for Education.

Other government departments already take account of this kind of evidence-based decision-making by consulting with experts before complex funding decisions are made.

This includes the Migration Advisory Committee (MAC) which advises the Home Secretary on how many non-EU immigration visas to issue each year; and the National Institute for Clinical Excellence (NICE), which advises the Health Secretary about which drugs and treatments the taxpayer should fund on the NHS.

The point about both of these examples is that they help engage all the key interests in decision-making. By injecting a more independent approach to deciding the future funding of qualifications we could secure the prize of longer-term policy-making. Such an approach could benefit the needs of learners and deliver better value for money.

Paul Eeles, Chair of the Federation of Awarding Bodies and chief executive of the Skills and Education Group.

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