Working Together

A Strategy for the Voluntary and Community Sector and the Learning and Skills Council

1. The National Institute of Adult Continuing Education (NIACE) works to encourage more and different adults to engage in learning of all kinds. It undertakes research, development, consultancy and advocacy, offers information services and dissemination, and campaigns for, and celebrate the achievements of, adult learners. We are an independent, non-governmental organisation, a registered charity and a company limited by guarantee. Members come from many sectors including colleges, local authorities, universities, voluntary and community organisations, faith groups, broadcasters and unions. NIACE receives core grants from the Department for Education and Skills, the National Assembly of Wales, and through the 1988 Local Government Act. It also has a Memorandum of Understanding with the Learning and Skills Council. The majority of NIACE’s income is earned through research, development and consultancy work. NIACE is a member of the government’s Skills Alliance.
2. NIACE has a strong commitment to encourage partnership between public bodies and the voluntary and community sector. This is centred on the sector’s role in developing, promoting, delivering and supporting adult learning. We see the Learning and Skills Council and the sector as key partners, working together nationally, regionally and locally, towards the provision of a richly diverse adult learning offer focused on the needs and aspirations of the widest possible range of adult learners. This spans a spectrum of opportunity from the most informal learning to advanced level qualification-based programmes.
3. In this context NIACE has, with the voluntary and community sector and Learning and Skills Council partners, arranged a significant number of consultation activities to explore and enhance that working relationship, including three national series of regional consultation meetings. We have also conducted a major recent mapping exercise on the state of Learning and Skills Council/voluntary and community sector relations and worked on a extensive range of research and development adult learning projects with both partners at national, regional, sub-regional and neighbourhood levels.

Overall comments

4. NIACE welcomes this consultation and endorses fully the underlying aims of ‘Working Together’. In particular, we commend the Learning and Skills Council’s commitment to achieving a step change in its relations with the voluntary and community sector, to opening up access to Learning and Skills Council mainstream funding, and to establishing the shared principle of mutual and equal partnership. The intention to implement the government’s compact with the sector is timely and a key to achieving constructive, productive and positive working relationships. It will also fulfil the explicit expectation in the Learning and Skills Council’s Grant Letter 2003/04.
5. The strategy offers much to build on existing good practice to support strong future partnerships. This includes both specific measures and its identification of the necessary shifts in organisational culture. The scope of the strategy (and notably the inclusion of voluntary and community organisations as employers), the encouragement of calculated risk taking, and the clear intention to monitor and evaluate implementation, are all important features.
6. We welcome the recognition of the need for Learning and Skills Council approaches to value and work with sectoral diversity. This is an important principle. The Learning and Skills Council must continue to be mindful of the extraordinarily rich and diverse range of organisations represented by the term voluntary and community sector, and be committed to sustaining that diversity. On a practical level, this is the best way to protect and nurture those attributes, such as greater flexibility, responsiveness and reach, which the Learning and Skills Council seeks. Voluntary and community organisations often function within the intersections between different government policy areas, such as social care, criminal justice and rehabilitation, community regeneration, and democratic renewal. This creates a unique potential to offer adaptable and accessible recruitment and progression routes to people who are not directly interested in learning, for example, to the parents active in a local playgroup who, with the support of the Pre-school Learning Alliance, may become avid adult learners. Engaging with such bodies enables the Learning and Skills Council to retain its focus on its central tasks whilst providing the learning support needed for other policy goals. This is reflected in the Council’s remit letter which argues that local Learning and Skills Councils should “take a holistic view of how their contribution fits within the National Strategy for Neighbourhood Renewal.”
7. There are also additional recommendations we would like to see included in the future strategy and various areas where the Learning and Skills Council’s commitment to action should be either consolidated or made more explicit. These are detailed in the relevant sections. The following comments are offered as general observations and suggestions for strengthening the strategy overall.
8. NIACE urges the Learning and Skills Council to take sufficient time to plan for and resource the strategy’s implementation and the development of its monitoring and review processes. The experience of the government’s compact with the voluntary and community sector demonstrates that excellent consensual agreements can founder without a strong, practical focus on action - and in this case, action across the whole Learning and Skills Council organisation. There is a significant body of goodwill and expectation surrounding the strategy at the moment amongst local Learning and Skills Council staff and the voluntary and community sector that will support implementation if the Learning and Skills Council responds in a timely and committed way.
9. This is accentuated by the need for the strategy to influence the Learning and Skills Council’s structures and processes across the range of its work and not just those that are ‘badged’ as sector-specific or identified closely with the sector, such as community regeneration or adult and community learning. We believe this is essential to ensuring that developments in other parts of the organisation, for example in funding, quality improvement and work-based learning, do not have unintended negative consequences for provision and on the contrary, take account of its needs in order to flourish and be sustained. This is particularly critical in relation to the sector’s more informal and intensive work with disadvantaged adult learners in the context of a strong focus on achieving high-level objectives and key targets, for example, in relation to 16-19 participation, adult basic skills, and Level 2 achievement. NIACE believes that a whole organisation commitment is fundamental to the Learning and Skills Council’s achievement of a “step change” in its relations with the voluntary and community sector and that this should be explicit in the strategy.
10. NIACE would argue that responsibility for driving the strategy forward should be positioned centrally within the Learning and Skills Council to ensure that all aspects of the Council’s work and responsibilities are addressed with equal authority. The current locus within adult and community learning is reflected in the strategy’s strengths (in its emphasis upon adult learning) but also in its gaps or uncertainties, for example, the insufficient references to the Learning and Skills Council’s work with young adults.
11. Aligned to this, NIACE would like to see a clearer emphasis on the importance of achieving greater coherence across the 47 local Learning and Skills Councils in their work with the sector. We recognise that Learning and Skills Council /voluntary and community sector relations are dynamic and evolving at sub-regional level and that diversity is an appropriate consequence of local responsiveness. We also appreciate that greater coherence will be an eventual outcome of the strategy’s proposals. However, we would argue that an explicit commitment to increased consistency along with an adjustment to certain key proposals (the Framework and Action Planning, see Section 1), would signal more strongly the intention to address an enduring concern in Learning and Skills Council engagement with the sector.
12. NIACE recommends strengthening the regional dimension of the strategy. This is particularly important in the light of the appointment of the Learning and Skills Council Regional Directors, the increasing emphasis in government policy on devolution and regionalisation, the emergence of regional concordats and compacts with the voluntary and community sector, and the importance to the sector of planning and funding mechanisms that function at this level, such as the Regional Skills Partnerships and arrangements for ESF Co-financing. The strategy should reflect the growing contribution of regional sector fora and networks in terms of their links with strategic bodies (such as Regional Development Agencies, Government Offices and increasingly, the Learning and Skills Council), and also their role in sector-base adult learning as sources of information, support, training and advocacy. The timing of the strategy offers the Learning and Skills Council an opportunity to embed best practice in its new regional structures and processes as they develop.
13. Whilst the four key roles used in the strategy to define the sector’s relationship with the Learning and Skills Council work well overall, we would suggest an amendment to the fourth element. It is arguable that communication through the sector would be located better within Section 4 (addressing expertise and intelligence), and that communication with the sector should remain as part of a separate section addressing Learning and Skills Council /voluntary and community sector engagement.
14. The strategy’s proposals should be viewed as integrated, complementary and coherent, and delivered accordingly. We recommend that the strategy should argue for the inter-dependence of its proposals in order for it to succeed overall. The named Learning and Skills Council link officer is a case in point (see Section 5, paragraph 3). The commitment to establishing this post is most welcome but the job is at risk of being undeliverable, particularly in the light of Learning and Skills Council re-shaping without improved communication channels within the Learning and Skills Council and between the Learning and Skills Council and the sector, stronger voluntary and community sector second tier organisations, sufficient internal staff training and development, and a whole organisation commitment backed by sufficient resources.
15. Finally, we would argue that the policy underpinning the strategy can only be delivered with the engagement of the whole voluntary and community sector in all its complexity and diversity.

Section 1: aims and rationale of the strategy

1.1 NIACE supports the aims and rationale of the strategy and endorses the underlying principle of mutuality and partnership. We feel this would be clearer and easier to interpret however, if the strategy included a brief account of shared Learning and Skills Council/voluntary and community sector principles and aims and an outline of the mutual advantages of partnership and co-operation based on a shared commitment to quality outcomes. The Draft Regional Compact on Learning and Skills being developed by the local Learning and Skills Councils in the South East Region and RAISE (the voluntary and community sector regional network) offers a useful model for this approach.
Proposal: incorporate a brief list of shared Learning and Skills Council /voluntary and community sector principles and aims and outline the mutual advantages of partnership.

1.2 The proposed actions in this section are all appropriate but, as expressed, they are insufficient to address the identified issues. NIACE welcomes the idea of a model framework for defining and benchmarking Learning and Skills Council /voluntary and community sector engagement and for measuring progress. However, we believe this should include core performance indicators and forms of evidence that would apply to all local Learning and Skills Councils in their monitoring of work with the sector. Additional performance indicators and evidence reflecting local circumstances would be encouraged but all local Learning and Skills Councils should be expected to meet a minimum requirement. We recommend this is specified in the strategy.
Proposal: include core performance indicators and forms of evidence in the model framework.

1.3 We welcome the commitment to incorporate actions related to voluntary and community sector engagement in annual planning and reporting processes. Benchmarking is fundamental to such monitoring and progress review and consequently NIACE believes it is not sufficient to “encourage” every local office to conduct a benchmarking exercise. This should be an expectation of all local Learning and Skills Councils that have not already done so. Local Learning and Skills Councils will need resources and support to do this, particularly if mapping exercises similar to that undertaken by London East (highlighted in the strategy) are to be viewed as useful models. The potential for regionally co-ordinated benchmarking and monitoring might be worth exploring
Proposal: make clear an expectation that all Learning and Skills Councils should conduct (or have conducted) benchmarking, with appropriate resources and support.

1.4 Aligned to this, NIACE believes that the development of the framework should have an indicative timescale as part of an Action Plan. We propose the inclusion of this Plan in the final version of the strategy and that it should cover, as far as possible, key steps towards implementation, monitoring and review. The model for this might be Learning and Skills Council’s widening participation strategy, ‘Successful Participation for All’, which is a comparable undertaking to the voluntary and community sector strategy.
Proposal: the final version of the strategy to offer an Action Plan or implementation timetable, including an indicative timescale for framework development.

1.5 The Learning and Skills Council’s commitment to share and build upon current good practice is the most sensible way forward, particularly given the limited capacity of all concerned and the growing body of excellent work now available. However, we are doubtful that the proposed compendium is the most effective solution in view of the rapidly changing environment. As alternatives, we suggest a more consistent and sustained engagement with sectoral infrastructure bodies such as national umbrella organisations, regional networks and sub-regional consortia (linked to sufficient resources, see Section 4, paragraphs 3 and 4), steps to enable the “named person in each local office” to distil and circulate information, workshops and keep in touch meetings, and periodic electronic and paper-based newsletters and bulletins. These have greater capacity-building potential, are capable of sifting and circulating up-to-date information, and are more developmental and dynamic. They would be advantageous to the Learning and Skills Council in terms of better intelligence and more effective communication, and support voluntary and community organisations by improving their contact with the Learning and Skills Council and their access to useful information that has been tailored for the sector. Such approaches incur on-going as well as set-up costs and these would need to be recognised. This includes addressing the practicalities of voluntary and community sector involvement such as ‘backfill’ cover and costs, as exemplified by the Black Country case study.
Proposal: substitute the proposed compendium with better engagement with voluntary and community sector infrastructure bodies, sufficient support for the “named” local Learning and Skills Council people, workshops KIT meetings, bulletins etc.

Section 2: the voluntary and community sector as a provider of learning opportunities

2.1 This section is at the heart of NIACE’s interest in Learning and Skills Council /voluntary and community sector engagement and we welcome both the analysis of the issues in the strategy and its specific proposals. However, we would like to offer the following additions and amendments.

2.2 NIACE believes that the strategy could acknowledge the importance of enabling voluntary and community organisations to engage more systematically with the delivery of Skills for Life. Our experience with the Adult and Community Learning Fund, the Department for Education and Skills’ Voluntary Sector Fund and the Learning and Skills Council Basic Skills in Local Communities programme has shown that the sector has enormous but largely untapped potential to develop both embedded and explicit support for adults with literacy, language and numeracy needs.
Proposal: include strengthening the contribution of Voluntary and community organisations to ‘Skills for Life’.

2.3 We would argue that the strategy should reflect the importance of e-learning to the sector’s role in widening participation and the provision of high quality non-accredited and qualification-based learning. We suggest it should recommend extending the Learning and Skills Council’s National Learning Network to voluntary and community sector providers. The Network, which is a substantial driving force behind the use of information and communication technology, is currently limited to further education colleges, local authority adult education services and specialist colleges. Voluntary and community organisations would clearly benefit from access to the staff development opportunities, learning content and infrastructure support the National Learning Network provides. This would also be an effective step towards linking voluntary and community organisations with other deliverers of e-learning and ensuring quality provision.
Proposal: consider extending the National Learning Network to voluntary and community sector providers.

2.4 We welcome the proposal to promote capacity-building funding to the voluntary and community sector. NIACE’s experiences with initiatives such as the Adult and Community Learning Fund, and our evaluation of the Learning and Skills Council Neighbourhood Learning in Deprived Communities Fund, convince us that this is crucial to enabling voluntary and community organisations, and particularly smaller groups, to meet their own high aspirations in relation to adult learning as well as the requirements of the Learning and Skills Council and the external inspectorate. However, we would like clarification of what is meant in practice by the term “promote”, and a recognition of the legitimacy of incorporating funding for associated staff development in project costings. We would also argue that short-term, one-off injections of capacity-building funding are insufficient to address the issues and that the strategy should include a commitment to sustained resourcing for this purpose. As the report on the cross-cutting Treasury review argued:

“Government programmes often presume that the voluntary and community sector has the capacity to participate or that this capacity can be built quickly. The presumption is often unjustified and can lead to unrealistic expectations.”

Proposal: clarify the meaning of “promote” with regard to capacity building, recognise associated staff development costs within project budgets, and incorporate a commitment to sustained resourcing for capacity development.

2.5 NIACE urges the Learning and Skills Council to make a specific commitment to addressing the potentially more pressing capacity-building needs of black and minority ethnic voluntary and community organisations. These have a disproportionately large funding shortfall to contend with, have a greater reliance on grants from statutory bodies that fund delivery but not core costs, and (research suggests) they are less involved with umbrella bodies, such as CVS, that could offer advice and support.
Proposal: make an explicit commitment to addressing the capacity development needs of black and minority ethnic Voluntary and community organisations.

2.6 Aligned to this, the strategy should recognise the relationship between underdeveloped voluntary and community sector capacity and the nature of the funding sources available to the sector. These are disproportionately short-term, discretionary and focused on delivery. This is an expensive (in terms of organisational costs) funding base and one that works against organisational investment and long-term planning. As a case in point, the strategy could note the consequences of limited regular and predictable access to capital and revenue funds on voluntary and community capacity to introduce and maintain ICT services. This affects the extent of equipment repair, upgrading and replacement, and also levels of technical and user expertise.
Proposal: recognise the relationship between limited voluntary and community sector capacity and high levels of short-term, discretionary funding.

2.7 NIACE would argue that this section of the strategy should identify a cluster of funding issues affecting voluntary and community sector providers. This includes consideration of opening access to mainstream further education funding and funding for work-based learning, full cost recovery, the need for premium funding for small and niche service providers dealing with specific disadvantage and exclusion, inconsistent sub-contracting arrangements, and access for new voluntary and community sector providers. We would like to see an explicit commitment to sustainability for high quality, needs-led voluntary and community sector provision. The strategy is an opportunity to affirm the Learning and Skills Council’s commitment to voluntary and community sector access to all Learning and Skills Council streams and not solely adult and community learning and discretionary funds, recognising that the emphasis in such funding on innovation can distort as well as enrich provision.
Proposal: incorporate a cluster of common and persistent funding issues and make a commitment to sustainable funding for high quality voluntary and community sector provision.

2.8 NIACE recommends that the Learning and Skills Council review its practices with the voluntary and community sector against the 10 steps to Getting Better Delivery put forward by the Guidance for Effective Working with Frontline Providers, and the recent Treasury Guidance to funders.
Proposal: review practices against the DfES ’10 Steps’ and the Treasury Guidelines.

2.9 The strategy should distinguish between lack of capacity and preferred alternative approaches. This would signal an organisational commitment to understanding and working with the distinguishing characteristics and differences of the sector.

2.10 NIACE supports the intention to work with the sector to improve funding applications and financial planning skills. We recommend that there should be an explicit commitment within this proposal to collaborate with appropriate parts of the voluntary and community sector to make funding advice and application processes more accessible to black and minority ethnic organisations and potential applicants with disabilities. This would help to address a legacy of disadvantage and relative under-resourcing.
Proposal: include a commitment to develop more accessible funding advice and application processes in order to attract black and minority ethnic voluntary and community organisations and potential applicants with disabilities.

2.11 We welcome the intention to commission capacity development activities for Learning and Skills Council staff from voluntary and community organisations or secondees. NIACE believes that sufficient, appropriate Learning and Skills Council staff training and development is central to the strategy’s successful implementation, particularly, but not exclusively, to support local staff with the lead role for the sector. NIACE is pleased the strategy identifies this as a priority. We urge the Learning and Skills Council to include an indicative timescale for the development of such activities in a strategy Action Plan.
Proposal: include an indicative timescale for Learning and Skills Council staff development activities in a strategy Action Plan.

2.12 The strategy highlights correctly the importance of work between local Learning and Skills Councils and sub-regional consortia. These arrangements are increasingly prevalent and significant within Learning and Skills Council /voluntary and community sector relations and this trend will almost certainly continue. Therefore, we view the proposal to explore common standards and fit for purpose support as timely and helpful. We would also like to see an explicit recognition of the independence of these bodies as part of voluntary and community sector infrastructure, and of the importance of local Learning and Skills Councils remaining open to supporting learning delivered by voluntary and community organisations that either cannot or choose not to join these arrangements.
Proposal: recognise the independence of consortia and the importance of the Learning and Skills Council continuing to work with voluntary and community organisations not involved in these arrangements.

2.13 NIACE welcomes the Learning and Skills Council’s intention to explore ways of rationalising contracting arrangements in order to minimise bureaucracy. However, we would argue that national, multi-site, multi-contract voluntary and community organisations require a single contracting point within the Learning and Skills Council at national level either as part of the National Contracting Service or an equivalent arrangement. Lead Learning and Skills Councils cannot address fully the problems of scale and complexity encountered by national organisations, nor capture sufficiently their distinctive contribution. We note that paragraph 20 of the Learning and Skills Council’s Remit Letter states that “ the Council will establish mechanisms to ensure that large national organisations and employers are able to liaise with the Council at a single national point.”
Proposal: establish a single contracting point for national and multi-site Voluntary and community organisations at national Learning and Skills Council level.

2.14 We strongly endorse the proposal to explore the development of a quality support programme for voluntary and community sector learning and skills providers and note that sector providers have requested this since the inception of the Learning and Skills Council. We urge the Learning and Skills Council to incorporate an indicative timescale for this work in an Action Plan for the strategy.
Proposal: include an indicative timescale for developing a voluntary and community sector quality support programme as part of a strategy Action Plan.

2.15 The consequences of scale have a direct bearing on the ways in which particularly smaller voluntary and community organisations can engage with adult learning. In addition to its proposals to build voluntary and community sector infrastructure, the strategy is an opportunity to highlight the Learning and Skills Council’s potential role as an ‘honest broker’ to foster links and collaboration between sectors. With the requisite safeguards against inequitable and poor practice, this could encourage greater cross-fertilisation of ideas and experience, ease access to Learning and Skills Council funding for quality provision and help bridge capacity issues for some voluntary and community organisations. The role could grow from existing good practice, for example, within the further education and local authority sectors.
Proposal: promote a role for the Learning and Skills Council as ‘honest broker’ between the voluntary and community sector and other sector providers.

Section 3: the voluntary and community sector as an employer

3.1 NIACE endorses the strategy’s recognition of the important role of voluntary and community organisations as employers and its acknowledgement of the learning and skills needs of these small and medium sized enterprises. We believe this will stretch perceptions of the voluntary and community sector contribution to Learning and Skills Council priorities and help to counter any tendency to see this exclusively in terms of ‘first steps’ and more informal non-accredited provision - important though these areas are. Close collaboration with the voluntary sector national training organisation and the intention to align the Learning and Skills Council’s strategy with the proposals in the voluntary and community sector Skills Strategy are sensible ways for the Learning and Skills Council to build its approaches.

3.2 The terminology of the strategy, which refers to the sector’s “workforce” and “staff”, might imply an exclusive focus on paid employees, despite an acknowledgement of the significant and unique contribution of voluntary workers. Volunteers will be involved in managing and delivering learning opportunities and the Learning and Skills Council has a clear interest in developing their skills. It would be helpful, therefore, if the strategy mentioned the importance of meeting the training and development needs of volunteers and of building these into any workforce development strategies at national, regional and local levels. We would argue that the strategy should also encourage local Learning and Skills Councils to recognise some volunteer training as eligible for workforce development funding. There are precedents for this that could offer useful models. A focus on volunteer learning and training as part of workforce development would be mutually beneficial. It would build the capacity of individual volunteers and voluntary and community organisations and enable the Learning and Skills Council and government to count the achievements of these learners towards delivery targets. Given the demographic profile of volunteers, it would also support the Learning and Skills Council’s strategic objectives in relation to widening participation and promoting equality and diversity.
Proposal: recognise the importance of volunteer training and development and incorporate as far as possible this as far as possible into workforce development planning and access to resources.

3.3 Volunteering adds to social capital, builds self-esteem and enhances confidence. It also helps people to find paid work and to progress to further learning and training. This highlights the importance of skilled and appropriate information, advice and guidance, and the significance of progression across the voluntary and community sector and between voluntary and community organisations and providers in other sectors. We suggest that these skills should be mentioned within the strategy alongside the particular training requirements of teachers, tutors and trainers in the sector.
Proposal: include guidance skills amongst the identified training needs of voluntary and community sector practitioners.

3.4 NIACE would like to see an acknowledgement of the importance and quality of qualification-based programmes in the sector (including Modern Apprenticeships), and the unique potential of voluntary and community sector providers to offer accessible high quality progression routes for more sceptical and hesitant learners from ‘first steps’ provision to advanced vocational programmes.
Proposal: include a recognition of the value of voluntary and community sector qualification-based and vocational programmes.

3.5 NIACE agrees with the strategy’s assertion that voluntary and community organisations, as learning organisations, will be more effective in their work with Learning and Skills Council priority groups. However, as an aspiration this would feel more realistic if there was an acknowledgement of the barriers to achievement. These include limited staff development budgets and the problems of ‘backfilling’ for workers undertaking training (both of these are potentially more significant for the many smaller voluntary and community organisations), transport (particularly for rural voluntary and community organisations), insufficient knowledge of qualifications and progression routes, lack of appropriate ‘bespoke’ materials, and a mixture of unpaid staff and relatively high numbers of dispersed and part-time employees. Many of these are held in common with other small and medium-sized enterprises, with the notable exception of volunteers, and the Learning and Skills Council might have a role in brokering or supporting cross-sectoral work in this area.
Proposal: identify the barriers to workforce development in the sector.

Section 4: the voluntary and community sector as a source of expertise and intelligence

4.1 NIACE shares the view that sector perspectives should be included in the implementation and evaluation of Strategic Area Reviews. However, as Learning and Skills Council Circular 03/06 makes clear, although voluntary and community organisations are listed for representation on local stakeholder groups, they are not amongst those mentioned as essential to the core stakeholder group except, potentially, as part of the broad ‘provider’ category. Inclusion of the sector in the core group would have both symbolic and practical consequences. It would signal the Learning and Skills Council’s intention to give parity of esteem to its voluntary and community sector partners alongside Local Education Authorities, colleges, employers, and Job Centre Plus. It would also help to address inconsistencies in local Learning and Skills Council engagement of voluntary and community organisations in the Strategic Area Review process. NIACE recommends that the strategy proposes this reform to the Strategic Area Review arrangements.
Proposal: advocate the inclusion of voluntary and community organisations in the Strategic Areas Review core stakeholder groups.

4.2 We are pleased the strategy values voluntary and community sector expertise and experience in the work of the Learning and Skills Council, particularly around widening participation. We would argue that this extends (and could extend further) to other areas, for example, the development and application of the Equality and Diversity Impact Measures, the design and processing of funding applications to support Learning and Skills Council staff in aligning these with equal opportunities best practice, planning to meet corporate aims and targets, and community consultation approaches. In the light of this, we recommend that the strategy advocates the principle of paying for voluntary and community sector consultancy rather than suggesting that this “should perhaps be considered”.
Proposal: make a commitment to paying voluntary and community organisations for their expert advice and guidance.

4.3 The strategy’s emphasis on the cost benefits of working with voluntary and community sector infrastructure organisations is clearly correct and we strongly endorse the acknowledgement that this may entail capacity-building investment by the Learning and Skills Council. It is important that developments in this areas are taken forward with reference to the findings of the Infrastructure Review undertaken by the Active Community Unit and to the outcomes of expenditure through the National Exemplar Fund and other monies from within the projected £93 million government investment in voluntary and community sector infrastructure. We recommend that the strategy argues for complementary approaches.
Proposal: ensure that Learning and Skills Council infrastructure investment complements and aligns with outcomes and actions arising from the Active Community Unit Infrastructure Review.

4.4 Earlier comments have highlighted the need for the strategy to take particular account of the circumstances of black and minority ethnic voluntary and community organisations. This applies also to the development of infrastructure bodies. These are subject to the same constraining factors such as persistent, disproportionate under resourcing, a greater reliance upon delivery funding, direct and indirect discrimination, relatively poor access to ICT, and low levels of engagement with umbrella bodies. National, regional and sub-regional second tier organisations are emerging within the black and minority ethnic voluntary and community sector but these are precarious financially and development is extremely patchy. We recommend the strategy refers to these bodies specifically and carries a commitment to partnership working with appropriate voluntary and community organisations in order to define the most appropriate Learning and Skills Council contribution.
Proposal: make a commitment to address the specific needs of black and minority ethnic infrastructure bodies.

4.5 NIACE strongly endorses the intention to include in national and local planning activities specific approaches to involving smaller voluntary and community organisations that work with the most marginalised and disadvantaged learners. This is necessary to helping the Learning and Skills Council towards a proper understanding of the needs and aspirations of communities it finds most hard to reach and which are consistently excluded from institutional arrangements. However, achievement of this proposal will depend on organisational commitment. This includes recognising the need to allocate resources to the work (see paragraph 4 above, and paragraph 2 below) and to adjust current processes to accommodate the requirements and capacity of these organisations. This will affect lead in and response times for consultations, and entail a stronger focus on participative, community development approaches. Action in these areas and a willingness on the part of Learning and Skills Council to ‘do it differently’ will demonstrate the Council’s commitment to valuing the characteristics of the sector and, on a very practical level, make it more likely it will achieve the desired results (see also paragraph 6 below).
Proposal: develop and use more flexible, responsive and imaginative community consultation and planning approaches.

Section 5: the voluntary and community sector as a channel of networking and communication

5.1 Please note the suggested amendments to the structure of this section (see Overall Comments, paragraph 9).

5.2 NIACE feels the analysis of the issues might identify more clearly factors affecting communication. These include rurality and long travel distances to attend meetings and consultation events; the opportunity costs of participating; a cultural focus on ‘doing’ and delivering; the impact of fund raising (time taken by bid writing and servicing the requirements of multiple funders); and particular barriers to communication for groups from within black and minority ethnic communities and those working with disabled adults.
Proposal: identify clearly the barriers to effective communication with and within the voluntary and community sector.

5.3 NIACE endorses the intention to identify a named person in each local office to act as the primary contact with the voluntary and community sector across all areas of engagement. This has been requested by voluntary and community organisations for some considerable time. NIACE believes the strategy should argue for these posts to be located at a sufficiently senior level within the organisation to carry authority and to be sited centrally to avoid an exclusive identification of the role with particular areas of work such as adult and community learning or neighbourhood renewal (see Overall Comments, paragraphs 5 and 6). We urge the Learning and Skills Council to provide an indicative time scale for identifying staff and for delivering suitable induction, training and resources, to be published in an Action Plan as part of the final strategy. The monitoring and review processes for the strategy should track the evolution of this role and assess its impact upon Learning and Skills Council /voluntary and community sector work.
Proposal: ensure that the “named” local Learning and Skills Council contact person is sufficiently senior to have authority and to carry a comprehensive understanding of Learning and Skills Council’s different functions and processes.

5.4 See Overall Comments, paragraph 10.

5.5 We welcome the proposal to promote compact principles, codes of practice and support arrangements and to encourage local Learning and Skills Councils to agree local ‘compacts’. Time invested in these arrangements will make subsequent Learning and Skills Council /voluntary and community sector dealings more effective and will build on the excellent work already undertaken in this area by voluntary and community organisations and local Learning and Skills Council staff. This reinforces the need to address internal Learning and Skills Council communication around the sector in order to make best use of existing good practice, and the need for a commitment to implementation from Board level down.
Proposal: address internal communication around the voluntary and community sector and make a ‘whole organisation’ commitment to implementation.

5.6 We agree with the intention to work with voluntary and community sector representatives to review local and national communication channels. We recommend that the base line for this should include the ‘Code of Good Practice’ on consultation and policy appraisal (part of the Compact). This offers clear undertakings by both government and the voluntary and community sector, advises on effective practice and different approaches, and provides guidance on designing consultation materials and processes.
Proposal: use the existing ‘Compact’ on consultation and policy appraisal as a baseline for the review of national communication channels.

For more information please contact Cheryl Turner, Development Officer, NIACE, cheryl.turner@niace.org.uk

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