The consultation paper is not easily understandable and this lack of
accessibility creates obstacles in obtaining clear views. At no point are
the terms, ‘outcome-based measure’, ‘outcome-based target’, ‘performance
indicator’ explained to the reader and all are evident in the three
proposals in relation to young people. For learners to be at the heart of
the system means having regard to the language that makes policy
accessible.
On balance, once these difficulties are be clarified, NIACE welcomes
the retention of targets as ‘measures’ – but urges Government to be
cautious about how they are used. While targets have the positive effect
of focusing attention and resources there is a real risk that they can
distort the policies for which they are proxies. Both the Government and
LSC must monitor and reflect upon how programmes and provision evolve and
how this confirms or challenges the analysis behind the target setting. As
long as ‘measures’ do not attract less attention, or resources though,
they offer a mechanism for adapting and fine-tuning targets better to meet
the aspirations of learners.
ii) PSA targets in relation to young adults
The Department will need to take care that taking positive action to
understand drop-out at 17 is done before a decision is taken on
outcome-based measures. Some PSA targets have resulted in unintended
consequences such as the narrowing of curriculum offers and the reduction
of provision aimed at widening participation. Taking positive action will
involve increasing and effective guidance and the valuing of learning
outcomes other than qualifications. The report of the 14-19 Reform Group
may well offer guidance on this. NIACE believes that because 19 is the age
used to identify participation and level 2 attainment, it makes sense to
keep 19 as the measurement point for a single attainment target. However,
we would want to see an attainment target set which values those
activities of young adults which contribute to social development and
cohesion, as well as whether or not they hold level 3 qualifications,
‘vocational’ or ‘academic’.
iii) Adult literacy, language and numeracy is about more than
‘employability and progression’
NIACE notes that from the learners’ perspective, adults with the
greatest level of literacy, language or numeracy need may be those at
entry level. We also know that the participation levels and actual
achievements have been increasing at a greater rate than qualification
levels in basic skills. This indicates that adults wish to learn with or
without taking qualifications, which may or may not be relevant to them.
We need to recognise all those who are learning and what has been missing
thus far is a publicly recognisable participation measure to balance the
target based on taking qualifications successfully. We believe that all
learning has the potential to assist economic and social development.
Practitioners report a narrowing of the programme offer when only
qualificatory outcomes are valued by funders or providers. NIACE believes
it would be better to have a publicly recognised measure of participation
in learning basic skills, at whatever level, rather than the PSA target of
achievement at level 2. If these two things can be combined effectively we
might then concentrate effort on ensuring that as many adults as possible
had successful achievements.
iv) PSA target on skills at level 2 may reduce participation
The focus on level 2 for all qualifications will put pressure on the
Learning and Skills Council- funded provision to give priority to courses
operating between level 1 and level 2 rather than at entry level. It is
still unclear what is meant by ‘first level 2 qualification’. There appear
to be some who believe that a single GCSE at Grade C is enough. This needs
clarification. The single adult target at level 2 may also effectively
marginalise the basic skills focus, risking reduced support for this
provision. The level 2 target is important but does nothing for the many
adults whose learning is uncertificated, or at entry level, or at level 3.
Again, all learning has the potential to improve personal or economic
development. When a national target is created so funding drives down a
narrower route, thus taking resources away from those who may not be
wanting to take a level 2 qualification but for whom participation in
learning is a means to better health, stronger social capital or social
inclusion. NIACE would prefer to see a broad target, with supporting
measures, provided the measures value adult participation in learning and
achievement, as well as passing of qualifications. All are important.
v) FE and training providers need safeguards
NIACE welcomes moving Success for All targets to delivery plans but
suggests that safeguards are needed in order to protect provision aimed at
‘new’ learners, those adults returning to learn for the first time since
leaving full-time education and those for whom attending college is an
enormous first step. Some consideration might also be given to defining
provision rather than providers. For example, college provision can be
made by local education authorities and ‘other’ or ‘adult and community
learning’ provision is often made by colleges.
vi) Balance between local and regional discretion and national
priorities: some concerns
Although NIACE supports the move to enable providers to take ownership of
targets for their local area or region, or to incorporate them into their
national remit, we have some reservations about this section. NIACE would
wish to see:
- genuine negotiation between the local LSC and providers, which
allows full recognition of the mission and purpose of each provider, and
to ensure that targets are realistic and appropriate;
- adequate funding is made available to support the achievement of
targets;
- a proper balance of provision aimed on the one hand at contributing
to targets, and on the other with provision designed to widen
participation in learning or increase the social, health and well-being
outcomes of communities and learners.
NIACE would not wish to see targets simply handed over to providers if
it meant insufficient negotiation and no shared responsibility for the
achievement of targets; if the curriculum offer or balance of provision
was twisted out of shape; if providers were blamed for lack of achievement
of PSA targets, instead of Government departments who have overall
responsibility for them.