Patrick Craven, Director of Strategic Partnerships, City & Guilds

Department for Education’s review of Post-16 qualifications at level 3 and below

Qualifications at every level have value. They are able to transform lives – from the offender who is able to achieve his or her first entry level qualification and break the cycle of reoffending through to the executive who is improving their skills to move into a leadership role.

Qualifications also serve multiple stakeholders; they help people to get their first job and then progress on the job, they provide employers with an easy way to identify people’s skills levels and they provide a way of measuring the success of the education system in equipping people with skills.

The acquisition of skills has become increasingly complex. We no longer move in one straight line, learning a skill before applying it throughout our working lives and then retiring.

The journey today is more like the London Underground, there are multiple jumping on and off points and you are likely to end up heading in a completely different direction to that which you started.

This complexity means we mustn’t look at qualification levels and type in isolation - the system serves a huge variety of different people with different needs at different stages of their lives and any review must take into account all of these needs so that certain groups aren’t disadvantaged over others.

Principles of a qualification

At City & Guilds Group we fundamentally believe that there are universal principles that can be applied to all qualifications, of every type and at every level.

Once agreed these principles should then form the basis of all further reviews of qualifications, without the need for additional principles to be applied specific to level, type or uptake as this would only add complexity into the system.

Purpose and objective: Qualifications should have both a value in and of themselves (to provide learning) and also a broader external relevance (to connect that learning to an outcome).

The purpose of a qualification is to recognise the knowledge, skills and attributes that a learner has gained through its study and demonstrated through its assessment. This purpose must be evident to give the learner a clear expectation of what the qualification will deliver and to give education providers and employers a clear understanding of what the learner can do.

A qualification’s objective should help people progress – either into further study, employment or progression within the workplace or to progress knowledge in a particular industry or subject area. One of Ofqual’s General Conditions is that all qualifications have an objective and we believe the DfE should stick to this condition rather than attempt to introduce new terminology which creates confusion in the system and undermines public confidence in Government bodies’ decisions.

As we recommended in our Sense and Instability 2019 report, the DfE should focus on embedding outcome and impact-focused success measures within policy design which will help to determine whether a qualification’s objective is going to meet the needs of its many stakeholders. This should then be measured as part of the qualification review.

Relevant content: A qualification’s content should be relevant to its purpose and up to date. Content for related areas of study should draw from a common curriculum foundation so that there is consistency and confidence in the outcomes.

Rigorous and valid assessment: Assessment should be valid in relation to its content and purpose, should maintain a consistent standard over time and should be rigorously quality assured to ensure good quality and high confidence in outcomes. Assessment methodology should be fit for purpose within the intended objective of the Qualification and the nature of what is being assessed.

Appropriate size: Qualifications should be an appropriate size in relation to their content and purpose. This should provide a realistic indication of the average amount of time it will take a learner to study in order to achieve the qualification, and the appropriate shape and size of development that is required.

We think appropriate size is a more suitable measure than ‘minimum size’ which is not a guarantor of quality. It should be possible to design a suite of connected qualifications with a range of sizes to meet training needs and offer the correct set of development options for learners. We do not believe that one size of qualification will be adequate for this purpose.

(Technical and vocational qualifications) Support / input from employers: Technical / vocational qualifications should be developed with input from industry specialists or employers and should have the support of employers. They should also be rooted in actual labour market trends so that learners can be confident they are studying for something that will support them to get a job.

We believe the above principles can be equally applied to all qualifications regardless of level, content or type and should be considered as the essential quality measures for all qualifications.

They are also interrelated and must be considered holistically rather than as a checklist or series of discrete characteristics.

Conducting the review

It is not at all clear from the consultation how the review will be undertaken and indeed it was disappointing to hear that the DfE has already announced that it will stop funding certain level 3 qualifications before it has completed its review.

As we outlined in Sense and Instability, there is a worrying lack of evidence-based policy-making in education coupled with a huge amount of policy churn in the skills system.

Once again, we are recommending that in conducting this review the Government must establish better mechanisms for tracking outcomes and needs to establish a value for money framework for evaluating the success of skills policies.

We also believe that employers are best placed to judge the complexity of the range of qualifications offered in their sector and the value offered by these. Employers and sector bodies should be commissioned to lead this part of the review, independent of the lens of government reform initiatives.

Qualifications at all levels

Entry level qualifications: Qualifications at level 1 and below serve a broad range of learner needs and the same principles that we’ve outlined above should be able to be applied to these qualifications as much as to those at level 7.

The review proposes replacing qualifications at level 1 and below with a broader study and we believe this would have disastrous consequences for many people. Firstly there is no evidence presented for treating these qualifications differently to any others. Secondly, removing the qualification element excludes learners at lower levels from the qualifications system. This leaves them without an equitable way of recognising achievement or a way of progressing, increasing the general social and economic exclusion they face.

The role of level 2 qualifications: The qualifications system allows progression to further education or into employment and any review of qualifications must look at the whole system rather than focusing on specific levels in isolation. Level 2 qualifications play an important role in preparing learners to study and succeed on vocational programmes at level 3 and they are also needed in the system to re-engage learners. Importantly, employers in many industries value level 2 qualifications as a valid entry point to employment and they should be given the chance to decide which qualifications have value.

Progression to level 3: There seems a clear intention behind the review to get a greater number of learners studying level 3 qualifications after KS4 and a suggestion that reforming the qualifications system will help to do this.

However, we disagree that the intention can be secured in this way and in fact we believe that a more appropriate objective would be for more learners to progress from the 16-19 stage with qualifications at level 3.

Focusing on the whole system and how it fits together rather than the constant tinkering with individual qualifications would be a far more effective way of supporting progression, raising attainment ambitions and meeting learners’ needs.

Level 3 and T Levels: A clear objective of this review appears to be to remove choice from the system for learners pursuing a vocational or technical route. T Levels have been announced by Government as the ‘gold standard’ and there are moves to get rid of any qualifications that overlap with the new T Levels to force learners down this particular path.

Learners have multiple different needs and removing choice from the system will hugely disadvantage certain groups. For example, the size of a T Level prohibits other qualifications being taken alongside, forcing people to choose a narrow specialism at a young age. This narrowing of choice is not forced on those pursuing an academic pathway and we feel strongly that no door should be closed to learners who are not yet ready to specialise or indeed would benefit from a mixture of academic and vocational learning.

Also, there are those who due to their personal circumstances will be ready for a level 3 qualification but unable to commit to the time needed to complete a T Level. These learners must be given the flexibility and choice to allow them to progress in their chosen area using qualification offers of a different shape and size.

Finally, we dispute the move to remove qualifications from the system that appear to overlap with T Levels by virtue of size or title. Other than increasing the market for T Levels, we see no evidence to suggest that these qualifications should be removed and think that employers are best placed to decide which qualifications have value.

We urgently need a qualifications system that is dynamic yet coherent

In summary, we urgently need a qualifications system that is dynamic yet coherent, is measured against universal principles and allows learners to progress through the system.

Entry and exit points need to remain at every level and learners and employers, as the end users and beneficiaries of qualifications, are best placed to judge the value of qualifications.

Value must not be determined by level but by the qualification’s ability to enable learning and support progression into a job, on the job and into the next job.

A controlled qualifications market regulated against these principles and rationalised on an annual basis to remove low demand qualifications in high demand sectors will produce the coherence and clarity being sought.

If such a market is left to develop and evolve we can measure currency and impact in a meaningful way across future years.

Patrick Craven, Director of Strategic Partnerships, City & Guilds

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