Workforce Development: shaping a system fit for all

A draft NIACE response to the LSC Draft Workforce Development Strategy
Published: June 2002

1. This draft response is posted on NIACE's website to inform members and others shaping their responses. It will be considered by NIACE's Executive on 20th June, and then submitted following any amendment agreed there.

2. NIACE welcomes the publication, by the Learning and Skills Council, of the consultation document LSC Draft Workforce Development Strategy to 2005 (May 2002). There is a growing consensus that both the volume and the effectiveness of workplace-led learning must be increased substantially if the UK economy is to become more highly skilled and more productive - and it is right that the LSC should be a leading public agency to bring about change.

3. There are many things to welcome in the document. It includes an impressively open-minded programme of pilot initiatives and a helpful overview of the territory. In particular, we welcome:

4. However NIACE has considerable reservations about the timidity of the strategy overall. For twenty years, there has been a touching faith in a voluntarist, 'trust the employer' approach to workforce development, which has, as the CBI and TUC both recognise, failed those with least skills, mobility and leverage in the labour market. Despite its strengths, NIACE believes that the draft LSC strategy will fail to do enough to overcome that legacy. Indeed, NIACE is convinced that measures to stimulate demand, and to improve the quality and responsiveness of supply of learning opportunities need to be complemented by a regulatory framework. This could, in our view, be introduced slowly, securing the maximum level of consent, just as the framework for Health and Safety regulation has been secured. We make suggestions about what might be included below.

5. NIACE is wary, too, of initiative-itis. Again, the lesson of the last twenty years is that a large number of short-term pilot initiatives have been undertaken but few long-term programmes. The key lesson they show is that short-term initiatives do not bring about long-term change, and as our industrial competitors show, stable, well-resourced and well-designed programmes do bear fruit.

6. Context
To some extent the LSC's tentativeness is understandable. Workforce development is a complex policy area and it is right that the LSC strategy should be harmonised not only with the new approach to developing workforce skills announced by H.M. Treasury and DfES in April 2002 but also with the follow-up, expected this summer, to last year's Cabinet Office Performance and Innovation Unit report In Demand - Adult Skills in the 21st Century (December 2001). The strategy will also need to be congruent with The Framework for Regional Employment and Skills Action (February 2002) led by Regional Development Agencies. Furthermore, both the Small Business Service and Sector Skills Councils are public agencies with their own significant interest in workforce development. While these are mentioned (for example in paragraph 95), exactly how coherence will be secured is not clear. Higher education, too, has a key role to play in strengthening workplace skills.

7. Coherence
Given the different emphases that each of these players bring to the topic, all stakeholders need to be clear whether their role is about delivery and operations or about formulating strategy. We would urge the Council to give the final version of its strategy a more authoritative tone and to set out the relationships with other agencies with greater clarity. This should be possible once the second PIU report is published and the results of the spending review have been announced.

A crucial test which Government should apply to the LSC's strategy is whether employers would get compatible advice if they contacted their sector skills council, their Regional Development Agency or the Small Business Service. If the answer is "No" then further development will probably be required.

Similarly, if individuals get different messages from learndirect, from their local IAG partnership or from their Union Learning Representative, then the LSC strategy is unlikely to be as effective as may be hoped.

8. NIACE is particularly concerned that the draft LSC strategy does not yet make a sufficiently distinctive contribution to policy development in the area in which it might claim to have greatest expertise - that is, around insights about how the processes of learning and teaching are best organised so as to most effectively engage with individuals and employers, thus meeting the Council's unique statutory duty to encourage participation in and provision of post-16 education and training.

9. This response covers the specific questions asked in the LSCs document (although not in order) and also includes broader comments and questions intended to help the Council to strengthen its strategy. In commenting, NIACE is concerned about the limited time available for consultation: The LSC document was issued in mid May 2002 and the closing date for responses to the consultation is 21 June 2002 - a period of less than seven weeks. In this respect the LSC departs substantially from the advice on public consultations set out by government in the Cabinet Office Code of Practice on Written Consultations. NIACE would urge the Council to follow this Code in dealing with responses and in any further consultation. Not doing so leads, inevitably, to a perception that particular positions are being "steamrollered" through.

10. Is the approach right?
In its consultation the LSCs second question is "Is our main approach of engaging adults in learning via employers the right one?" NIACE's response is that the approach described may be necessary but is insufficient. As it stands, the strategy:

11. Although the Council states "The best strategy will be an employer led one", (paragraph 16), NIACE believes that the best strategy should be employment led rather than employer led and should have a wider range of key partners than those mentioned in paragraph 3. It should include at its heart employers, employees, (both as individuals and collectively via trade unions) and government but also involve providers of opportunities and other public agencies. In this way the Council could set out how the competing agendas of different parties can be accommodated or reconciled in ways that would be more open, transparent and negotiable than those in the draft.

12. Paragraph 16 also states that "We cannot rely on so many additional adults finding an individual route back to colleges or distance learning" but the paper gives no evidence for this assertion. This is surprising given the success of the Council's 'Bite-Sized' initiative which suggests there is much untapped potential to develop individual routes further. In addition, the strategy does not properly reflect the fact that, for many people, effective learning is a social experience. NIACE would hope that the final strategy has more of a focus on individual learners and groups of learners in order to balance and contextualise the current emphasis on businesses. Unless workers are motivated to learn, training and development opportunities, however attuned they are to business need, are of limited effectiveness.

13. Implementing structural change
The LSC asks "If we can achieve the structural changes set out in this strategy, will we be in a position to raise the skills levels of the adult workforce and deliver sustainable economic success? What factors will prevent us implementing these structural changes?".

14. Although many of the changes proposed, such as improving the quality and use of LMI and recognition of the need to develop information, advice and guidance, are very welcome, NIACE is concerned that the structural changes proposed appear not to take adequate account of the interface between workforce development and active labour market policies promoting the move from welfare to work. While there may be little direct overlap between the workforce development strategy and the New Deal or the work of Jobcentre Plus, the interface between these policies needs to be clearly defined so that progression is not impeded.

15. Overall, NIACE is not convinced that the draft strategy has yet given enough attention to the implications of the apparent imbalance in the supply and demand of skilled labour (identified in Felstead and Ashton's study of UK skills) and in particular, the degree of regional variation that may exist here.

16. Engaging employers
For a strategy that wishes to be employer-led, the document contains surprisingly little in the way of concrete proposals for raising employer demand - a key thrust of the first PIU report. In response to the third specific question ("What steps can we take to effectively engage employers, particularly SMEs, that are so far disengaged?"). NIACE would suggest there is merit in considering:

17. What all these approaches will need to do is to accept that, for employers, workforce development is a derived demand that must be aligned with and responsive to business goals. A purely skill-driven approach will not work.

18. While recognising that the LSC must take its cue from broader government policy, NIACE believes that there is no body of evidence to suggest that a purely voluntarist approach to workforce development will ever bring about the scale of change that is needed. The time has now come to try a combination of employer incentives (perhaps through tax credits and corporate learning accounts to parallel the successor scheme to Individual Learning Accounts) and also through regulation to secure a learning entitlement (see below). The strategy will need, anyway, to be sufficiently flexible to accommodate whatever lessons emerge from the six pilots of paid time off for learning which were announced in the 2002 Budget.

19. Engaging individuals and groups
The Council's fourth question is "How best can we engage adults from groups often excluded from workforce development, for example those from some ethnic minority groups, those with physical or learning disabilities, older people etc?" Overall, we believe that the best way to raise the volume and widen the distribution of access to learning and development opportunities is to promote a common minimum entitlement, providing learning at the time, place and pace which is most appropriate to the individuals and groups - at or outside the work place. However, we do believe the strategy needs to include an explicit focus on the needs of key groups of workers and potential workers who benefit least from current provision, and are most vulnerable in the labour market.

20. NIACE notes with interest the proposed obligation to train, contained in clause 224 of the Draft Communications Bill 2002, currently before Parliament, for workers in the communications industry. Such an entitlement might combine the Skills Task Force recommendations of a publicly-funded entitlement to a first level 3 qualification with a targeted successor to ILAs and to an entitlement to paid educational leave which might be introduced gradually. (The impact of the current right to PEL enjoyed by 16-17 year olds appears not to have been assessed). Overall, an entitlement-based approach would send out strong signals and, by offering a low-risk way for reluctant and under-confident learners to re-engage in active career development, provide a powerful driver of demand.

21. The final version of the LSC strategy needs also to draw more strongly upon the evaluations that have been done of both the Union Learning Fund and also the Adult and Community Learning Fund, not least in the lessons they provide about developing and sustaining effective delivery partnerships which are not simply provider-led. The strategy might also consider how these could best be integrated with local learning partnerships and IAG partnerships.

22. Supporting providers
The LSC's sixth question asks "How can we best support providers in delivering the workforce development agenda?" The draft strategy does not make it clear to NIACE exactly who the key providers of workforce development will be - which makes this a difficult question to answer. In our view, too much workforce training provision has in the past shared unhelpful characteristics:

23. In our view, colleges have a key role to play in a successful strategy. Currently, however it is not clear how further education colleges' role should develop. Colleges are already under pressure to respond to the Government's emerging 14 - 19 agenda and there are concerns that this might be done at the expense of adults. Just how a comprehensive workforce development strategy sits alongside focused Centres of Vocational Excellence is not yet brought out. In general, the strategy needs to give greater recognition to the need to give the sector greater stability from which to plan than is the case in the draft document.

24. If private sector providers are to have an expanded role, the impact of this on the incorporated college sector needs further articulation, especially since, for all their responsiveness, they appear to be less good overall at securing quality, accessibility, and transparency. In addition, employers themselves (either through HRD departments or group training schemes) may be important providers.

25. Overall, NIACE urges the Council to make quality of the learning experience for learners absolutely central to whatever support mechanisms it establishes for whatever provider mix and to ensure that this includes adequate resources for trainer training.

26. We note incidentally that twice in the draft (paragraphs 15 and 68) there is a suggestion that all the LSC's funds can be used for workplace development. It hardly needs stating that colleges, schools, and community-based providers have other responsibilities too.

27. Interesting practice and innovation
The final question asked within the draft strategy document asks for examples of "best practice or innovation". NIACE urges the LSC to review lessons that can be learned from initiatives developed and closed down by past governments. Among the good practices the LSC will want to review are:

28. Conclusion
The focus of this response has been to highlight what NIACE sees as areas to be strengthened in the LSC strategy. Nevertheless, the draft illustrates the Council's potential to act as a co-ordinating focus for policy development in a key area. That co-ordination will work best where it commands the maximum level of consent. NIACE would urge the Council to extend the consultative phase to ensure that the widest range of partners share ownership of the strategy. The Institute will give priority to work to support the Council in developing a strategy which meets the needs and aspirations of all adults at work - whether employers or employees - those currently seeking work, and those who may want the option of working in the future.

29. Key documents
Cabinet Office Performance and Innovation Unit. In Demand - Adult Skills in the 21st Century (December 2001)
Regional Development Agency National Co-ordination Unit. The Framework for Regional Employment and Skills Action - A Regional Template (February 2002)
H.M. Treasury/Department for Education and Skills. Developing Workforce Skills: Piloting a New Approach (April 2002)
Learning and Skills Council. LSC Draft Workforce Development Strategy to 2005 (May 2002)
Great Britain. Department for Education and Employment. National Skills Task Force (1999) Tackling the adult skills gap: upskilling adults and the role of workplace learning: third report of the National Skills Task Force. London. DfEE

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