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Framework for Excellence
A Comprehensive Performance Assessment Framework for the Further Education System
A NIACE response to the Learning and Skills Council Consultation
Published: 20 October 2006
Background
1. NIACE is keen to support approaches which lead to improvements in the quality of education that adults experience. The consultation sets out the way in which the Framework for Excellence model will be developed. This response raises a number of general points and answers the specific questions. The consultation is being led by the Learning and Skills Council (LSC). It is intended that the Framework will be developed by December 2006, published in full in June 2007, implemented in full for all further education (FE) colleges, sixth form colleges and work based learning providers (WBL) from August 2007, and all other providers from August 2008.
2..The Framework is intended to ‘support the choices’ made by potential learners and by employers, help providers to improve, and support accountability. The intention is that the Framework will,
 | be comprehensive and simple |
| be transparent, readily understood and used publicly |
| take into account all aspects of provider activity |
| have common measures of performance |
| assist providers in their own ‘quality assurance activities’ |
| help assess value for money |
| facilitate a proportionate approach to inspection and intervention |
| reduce bureaucracy and the burden of assessment. |
The Framework was signalled in Further Education: Raising Skills, Improving Life Chances, Sections 5.13-5.19 (HMSO, March 2006).
3. The LSC intends to work with Ofsted to align business processes and the grading system and expects the Framework to support the Quality Improvement Strategy set out in Pursuing Excellence (QIA, 2006). The Framework includes seven key performance indicators (KPIs) which are to be brought together to describe a provider’s performance under three dimensions: responsiveness, effectiveness of provision, and financial health. These three elements will be graded and will determine the provider’s overall performance rating. The grades and ratings will be used as part of the LSC’s funding and planning discussions with providers, who will use the seven KPIs in their self assessment and annual reports. The seven KPIs have been referred to as a ‘scorecard’ They will be derived from ‘secondary measures’ and other evidence. Two options are suggested: (1) precise quantitative definitions for the KPIs based on standard data, and (2) quantitative data with additional qualitative measures. The consultation closes on 20 October 2006.
NIACE response
4. NIACE broadly supports all the measures suggested, if it improves the experience of adult learners. In our response, NIACE has considered the proposals against three tests:
| will they work for the benefit of all adult learners? |
| will they enable all providers to participate equally? |
| will they achieve what the Framework sets out to achieve, without unintended consequences? |
Our response includes the questions for consultation.
5. In overview NIACE considers that the Framework has the following strengths:
| The belief that self assessment is central to any quality improvement in the learning and skills sector |
| The desire to focus on those providers least able to help themselves and in greatest need |
| The intention to reduce expenditure on and quantity of audit |
| Specific measures to encourage women with few recognised skills back into education and employment |
| The desire to work towards a single, coherent and integrated system, within which a common culture of self improvement is possible. |
6. NIACE has the following concerns about the Framework:
| Ignored are the needs of several groups who might be seen as priorities in the context of seeking economic survival, community cohesion and social justice |
| The trend towards ever-greater reliance on quantitative information and data, as the basis for measuring and evaluating organisational performance |
| The lack of serious attention given to the wider benefits of learning and other social policy objectives, besides the acquisition of skills, and the role that education might play in addressing these |
| Emphasis on employers’ needs is not appropriate as a KPI for the ‘Safeguarded provision’, and particularly not for PCDL. |
| The Framework is intended to reduce bureaucracy but appears to demand a great deal more. Several of the Key Performance Indicators have, as yet, no agreed or reliable way of being measured across all provision. The risk is that they become so superficial that they have limited value or so detailed that the bureaucratic burden becomes excessive. |
| A central flaw of the Framework is the assumption that meaningful comparisons can be drawn, on the basis of data, between very different types of provision. A modern apprenticeship is very different from a full-time college course, which is very different from a non-accredited evening class. We believe that context and purpose matter. |
| NIACE sees no evidence of the use of research into the real basis on which employers, learners and community groups choose their provision. It is our contention that they do not make their decisions only on the basis of the data the framework intends to collect. |
| The Key Performance Indicator on ‘Responsiveness’ is flawed. This KPI intends to offer a measure on how colleges and providers respond to the needs of the local community, to employers and to learners. Responsiveness to the community is not addressed at all in section 4 of the document and indicates the over-ambitiousness of the Framework. |
Peter Lavender
peter.lavender@niace.org.uk
