A NIACE response to the LSC Circular 02/21: Consultation on Guidance to
Support Local Learning and Skills Councils and their Partners in Undertaking
Strategic Area Reviews of Provision Starting in 2003
Published: February 2003
Q1 How do you think the proposed Toolkit might help in carrying out
reviews? Are there ‘tools’ for this process you would particularly
recommend?
Comments:
The toolkit for the review should clearly
state that it is for guidance and not a template to be used by each Local
LSC. However, we believe that some clear guidance may be needed about
minimum levels of provision in those areas that are not subject to
government targets, most particularly non-certificated learning
opportunities for adults. Such provision may be threatened by concentration
of resources on the targets leaving access routes for the most disadvantaged
compromised and general learning opportunities, needed to maintain learning
habits among all groups, severely diminished.
The toolkit should also seek
to ensure that feedback and information about area reviews will be available
in a common format including data (where this needs to be collected
separately). If data and information are not available in a common format it
will be difficult to distill, with appropriate evidence, the messages coming
from area reviews that might inform future policy in planning and funding.
This seems to us an important part of the toolkit’s function. The toolkit
should contain particular advice on how equality and diversity should be
secured.
Q2 Do you agree with the aims and scope of Strategic Area Reviews?
Are there other aspects of provision they should cover?
Comments:
We believe that the focus for area reviews is appropriate although we
believe that there is a need to consider, alongside the volume and type of
education, the participation profile of those engaging in education and
training. It would be excellent if a review of local participation patterns
was a part of the process. We think it should be made clear that the reviews
are a recurring event driving up participation quality and achievement over
time, not one off events providing a snapshot of local provision. We also
feel that not enough is made of the potential in area reviews to assess the
balance of provision nationally as well as locally.
One of the purposes of such reviews should be to give the LSC nationally
a picture of provision across England and the anomalies and commonalities
that exist in this picture. Without this national perspective there is a
risk of a very different range of opportunities being available to adult
learners in different areas. We believe it is important that there is a
national baseline of provision that all learners should expect to have
available to them, which can be built on locally to meet specific local
needs. Our experience in observing the effects of adult education delivered
to local agendas by local authorities and colleges without such a baseline
is very unequal delivery across the country, meaning unequal access for
learners. A national system must be in balance with local autonomy.
We also feel not enough is made of the potential for common messages from
local reviews being an important means of influencing national policy in
funding, planning and quality development.
Q3 Do you agree with the values listed in section 2? Are there other
values that should underpin Strategic Area Reviews?
Comments:
We are in agreement with the values expressed. We assume that the
consultations with learners will include an intention to consult with
potential learners through locally available machinery for community
consultation.
Q4 Does the process give local LSCs sufficient
flexibility? What aspects of the SAR process do you think should be managed
centrally?
Comments:
We believe that Local LSCs should be given maximum
flexibility in how reviews are carried out subject to guidance on major
stakeholders to be consulted, and some guidance on baselines of provision as
mentioned above. However, we think the National Office will need to advise
on the collection of information and reporting arrangements. As mentioned in
the Circular, there will need to be a means to deal with National
Contractors and specialist providers. Consideration of the capacity and
potential impact of National Voluntary Organisations should form a part of
this process.
We believe it is important to ensure that the views of
potential learners are represented in consultation. Continuing consultation
should be expected to include this aspect and not merely to involve
consultation with groups already engaged with the LSC. Use of locally
available consultation mechanisms, citizens’ panels and the like should be
encouraged. It is also important to obtain the views of employees and
efforts should be made to include those from small and non-unionised firms.
We believe there may be some advantages in involving national organisations,
not tied to specific sectors, through their regional representatives in the
review process, to provide some informal benchmarking with other areas as
the process develops. NIACE would be pleased to offer help in this way, but LSDA, ABSSU, BSA and Skill would also be useful sources of advice on
particular areas of provision.
Q5 The guidance proposes a seven-stage process for reviews. Does this
provide the right framework? Are there other actions you would like to see?
Comments:
The seven-stage process appears to cover the range of actions necessary
for review. It is important that the stages involving consultation are given
adequate time.
Q6 Do you think the range of stakeholders to be
involved is comprehensive? How can stakeholders be encouraged to contribute
effectively?
Comments:
The range of stakeholders is lengthy and yet it is
inevitable that it will fail to be comprehensive as players vary in each
area. There is sufficient in the guidance to allow for local flexibility
built on advice. Thought will need to be given as to how consultation
with stakeholders will be organized to ensure that smaller Organisations and
interests are adequately heard and considered, including those not currently
involved with the sector but with much to offer.
Q7 Does the section ‘building on previous work’ give enough scope for
use of previous review evidence?
Comments:
The section makes much of previous review evidence and is satisfactory in
this respect. There should surely also be encouragement to learn from best
practice and national work, as well as previous reviews of the area
concerned. It is not clear how the National Office will enable this to
happen to ensure that Local LSCs have more than practice in their own
locality to inspire and inform the review process.
Q8 Are there ways in which the LSC should work differently, either
locally or nationally, to ensure that Strategic Area Reviews are effective?
Comments:
There should be ample opportunity to network between Local LSCs during
this process. There is much to be done to build staff capacity to undertake
reviews, and Local LSCs should be encouraged to make arrangements for staff
development a key part of the planning process and, in view of the timescale
for review, during the process itself. Well informed and expert staff will
be critical to the review process and the way that it is regarded by
stakeholders.
Q9 Are there approaches to information gathering and analysis you
would recommend, or particular sources of evidence?
Comments:
We are aware that there are areas of work where data is difficult to
obtain. Adult and Community Learning is one such area, and data about
learning outside LSC funding streams will also be difficult to obtain. We
believe that in respect of these areas the LSCs should endeavour to work
with “best available” data rather than dismissing the possibility of trying
to obtain data.
Q10 When developing strategic options, do the 4 points in paragraph
101 provide the right framework for making choices about provision? Are
there other factors for the LSC to take into account?
Comments:
We agree that involving stakeholders early in the review process is the
best way to increase ownership of the process and acceptance of difficult
decisions. However, the interests of the supply side in this process should
be secondary to those of the demand side. Paragraph 102 draws attention to
some of the issues to be faced. An early statement of this focus will be
necessary as a prelude to the review and must establish the Local LSCs’
distance from stakeholders. A view that can be expressed on the balance
between stability and change may reassure stakeholders.
Q11 Does the approach outlined for local consultation meet the
requirements of learners, employers and the local community?
Comments:
In paragraph 114 the list of organisations to be consulted because their
services have a bearing on the LSC’s policies, and provision should mention
the need to tie in with regeneration and neighbourhood renewal initiatives,
and it would be good to include arts and cultural organisations, libraries
and museums in this section as well as those concerned with social
disadvantage. In paragraph 115, substantial changes to ACL provision should
also be reported to the national LSC. There may need to be sub-area
consultation arrangements where the local LSC covers wide and differentiated
areas. Part-time adult learners “travel to learn” distances may be
significantly less than those of young people on full time courses. This
will need to be taken into account when dealing with sub-areas.
Q12 What do you think are the most important
factors for the LSC if it is to implement review outcomes successfully?
Comments:
A clear commitment to the demand side while reiterating an
understanding of the need to minimize disruption to learners
A developed understanding on the part of the Local LSC of the strategy
that needs to be adapted if targets are to be met that can be discussed
with providers. This should include a view of the first steps provision
and general adult learning provision that will be needed in the area to
encourage and maintain engagement in learning
A strategy that links learning in the area outside the LSC’s remit to
LSC funded provision. This is particularly important in terms of
neighbourhood renewal and regeneration
Evidence before
contemplating the separation adult and 16 - 19 provision on the reasons for
such separation
A plan for widening participation alongside actions aimed
at the PSA targets
A clear action plan for all on equality and diversity issues. NIACE is
particularly keen to see an appropriate emphasis on disability.
Other comments:
We would like to make some
specific comments on the issue of the review of provider mission on the
basis of the paragraphs on this in the Circular and the toolkit document
produced by LSDA on the issue. It is clear from the toolkit that work on
mission will need to be carried out with a view to context and policy (both
local and national).
It is also apparent that for institutions the process
of mission review is critical. Taking internal stakeholders’ views into
account is vital as is securing commitment to the vision. This process does
appear quite time consuming if it is to be carried out in an appropriate
fashion.
Institutions will be aware that Local LSC’s, along with locally
determined needs, will have a particular driver in reviewing provision in
the delivery of the government’s targets. In terms of adult learners this
means the level 2 target and the Basic Skills targets. The LSC’s adult
participation target will be of key interest although it is likely to have
less priority than the PSA targets. Providers will be only too aware that
funding follows targets.
Given this context, Local LSCs will need to be very clear at an early
stage about what kind of provision they see as likely to form the building
blocks in terms of area planning. If the concentration is on targets alone,
then mission will follow this lead. No provider will place their institution
in a place where they are unlikely to obtain funding. Yet it is clear that
within the range of providers, different provision exists with strengths and
weaknesses being held within individual institutions and some gaps where new
providers are needed.
If, as the Circular suggests, differentiated missions - and consequent
provision are to be sought than the Local LSC must be prepared to indicate
the different strands it expects to fund for the area prior to mission
review, so that institutions are able to define the context and work with
their strengths. This will hopefully give institutions the confidence to do
this.
The perverse incentive in mission review is for providers to ally their
missions alongside the narrow targets to guarantee funding reducing the
broad raft of provision necessary to meet those targets and to meet local
need outside the specific target areas. The Local LSC will not be well
served by this nor will institutions find it easy to build support from
within for such a process. There is a particular risk here for general
non-certificated adult learning delivered by Further Education Colleges.
In rural areas it will be important to work towards more general missions
than in urban centres where differentiation can more easily be accommodated.
For adults in rural areas, learning alongside 16 - 19 year olds may be
essential.
The second point to emphasise is the need to build capacity in Local LSC
staff. We consider the timetable very challenging if there is to be the kind
of staff development that is needed. It is apparent that while many LSC
staff are familiar with contract management in work based provision, far
less have experience in the Further Education Sector. Engaging in area
reviews with colleges and community based providers - particularly where
challenge may well be required, will need staff with knowledge of Further
Education as well as negotiating skills.
Finally we continue to believe that area inspections of all post 19
provision, as well as 16 - 19 provision are necessary to guarantee a
consistent and appropriate quality of service across the country as a whole.
Strategic Area Reviews are an excellent initiative but would be much more
powerful if backed up by area inspection.