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LSC Circular on Post 16 Funding Arrangements for 2002/03
A NIACE Response
Published: October 2001
Introduction
NIACE is the National Institute for Adult Continuing Education. Our core aim is the increase in good quality learning opportunities for adults but our particular focus is the involvement of more and different learners in education and training and in particular those who have benefited least from the educational system.
The Learning and Skills Council and the Government have consulted widely and thoroughly on the arrangements for funding and this Circular shows that the consultations have been attended to and have influenced final thinking. The Circular is most welcome as is the recognition of the difference between sectors in their readiness to move to a common funding approach. These differences fully justify the intention to move gradually to the more integrated approach to funding hoped for in 2004/05.
There are clearly going to be problems for providers as they implement the new formula and modelling with the software promised will be vital for them in predicting the level of change they will experience. There is also much preparatory work to do in moving the last of the four sectors to join the methodology, adult and community learning, by 2003/04 and some of that work will affect other providers too. It is good to see that the effects on Institutions formerly known as External Institutions are understood and that the necessity for action to deal with these providers is seen as worthy of special arrangements.
The principal expressed throughout the Circular that unintended turbulence for providers caused by the new arrangements will be prevented by safety netting is important for learners too. Changes in funding arrangements almost inevitably lead to alterations in the pattern of provision and adequate safety netting will help to ensure that perverse effects are minimised as Colleges and other sector Institutions adjust to the future.
NIACE Particularly Welcomes
The basing of learner fee expectations on the unweighted national base rate:
This should mean that learners will not find courses appropriate to their
needs being offered at higher prices than less attractive or useful options and
should make the issue of the learner fees for such courses of less concern to
providers.
The avowed intention to give particular attention to the issue of learner
contributions in the funding of Adult and Community Learning within the common
funding arrangements:
NIACE is committed to seeing more and different learners accessing learning.
In the context of limited funding it is clearly in this interest to ensure that
where adult learners are able to make a significant contribution to the costs of
their learning they should do so. Not enough is yet known about the significance
of fee income in adult and community learning for the application of the 25%
formula in FE at this stage. We welcome the intention to investigate this are
thoroughly before decisions are made.
In relation to public support for adult learning NIACE believes that a system is needed that supports both disadvantaged individuals and disadvantaged areas but also enables the supply of a generous range of opportunities to those able to pay. This seems to us the best strategy to ensure that there is a wide range of provision which is a necessary part of any strategy to widen participation.
The permissive regime that enables providers to set their own fees mitigated
by a warning about unproductive local competition:
NIACE strongly believes that providers need the flexibility to target
provision to attract new learners and offers of free or low cost provision are
critical to such strategies. We are opposed however to "price wars"
between providers that often result in non-viable provision and little or no
gain for learners.
The understanding that attention will need to be given to the funding of
outreach and development work delivered by adult and community learning
providers:
NIACE is conscious that , while much adult and community learning is
susceptible to funding through a formula some particular aspects of provision
targeted at hard to reach groups is not based on the concept of a course which
is fundamental to the funding formula. The development of work in basic skills
in the community is also dependent on outreach strategies that may not easily be
fundable through a formula based approach.
The intention to ask the National Rates Advisory Group to investigate
rurality and other area issues as a part of its longer term programme:
NIACE is conscious that the needs of sparsely populated areas are considered
by providers to be particularly challenging and to have higher costs that
delivery in more densely populated areas.
The adjustment of the cost weighting for basic skills to take account of the
disappearance of the entry element for this provision which took account of the
need for specific learner assessment in such provision.
NIACE fully supports this adjustment although its effects on providers are
yet to be seen. We believe that further work needs to be done on basic skills
funding to enable work in basic skills in integrated programmes with basic
skills elements to be recognised in funding terms. We believe such provision is
essential if the Government’s Basic Skills Strategy is to be effective and
that providers will need incentives to develop it.
The intention to set up external user groups to ensure that developments are
informed by providers’ experience:
NIACE believes that the involvement of providers and their consultation in
the planning of the funding arrangements is critical to the development of
ownership and acceptance of future funding arrangements. We would hope that the
interests of learners, and particularly adult learners, which may not always be
the same as those of providers will be represented in such consultations.
The recognition that there will be problems and turbulence for particular
groups of providers and the commitment to deal with the issues arising while
assuring stability while such work takes place.
The section in the introduction to the Circular specifically addresses the
likelihood of turbulence impacting on former External Institutions. We would
hope that the strengths in widening participation and the needs of learners in
such institutions for quality provision will be given due weight by the Council.
The recent review of External Institutions resulted in parity of funding for
similar provision with other parts of the Further Education Sector and we would
be unhappy if a reduction in funding was an unintended outcome of the
introduction of the new system.
NIACE has some Specific Concerns
The combined effects of the demise of the entry element, changes to the
funding of short courses, the universal application of the 25% learner fee
expectation and increase in the percentage of the achievement element may
discourage providers from activities known to widen participation:
The Circular identifies External Institutions as being particularly affected
by these changes and also indicates that providers with limited range and volume
of provision may suffer turbulence. Our concern is that the very courses likely
to be affected by this cocktail of changes are those most likely to be targeted
at widening participation where short first level courses have proven success at
involving new learners. If the effects of the new mechanism are that providers
will lose by increasing the proportion of this work (and the effects predicted
for former External Institutions would seem to indicate that this is the case)
then there will be a financial disincentive for all providers in increasing the
volume of opportunities of this kind. This seems to counter the government and
LSC’s policy to widen participation.
The Circular seems to indicate that this is a set of circumstances that only affects certain institutions we would argue that it will effect particular and effective forms of provision. Other FE providers including the large Voluntary Sector providers in the sector will also be affected by this issue as they offer a high proportion of short part time activity much of which is non-accredited and with the demise of Non-Schedule 2 will be interested in the debate about levels of public funding and issues relating to achievement.
NIACE has already made the case for a unit dealing with the large Voluntary Organisations similar to the National Employer Unit within the LSC. We consider the specific issues that need to be examined in relation to funding for these providers are an illustration of this need.
NIACE welcomes the intention to carry out further work on achievement in relation to the Adult and Community Learning Sector but has a number of concerns in this area. | Achievement in non qualifications based learning is not only an issue for the adult and community learning sector but for all providers who will be providing non qualifications based learning including FE providers and it is important that the same rules apply to all providers on this issue regardless of sector. |
| Funding is only one of the ways in which achievement may be monitored and not perhaps the most effective. The Quality Assurance activities of the LSC are more likely to be able to influence the development of good practice in this area than financial auditing. |
The definition of achievement is relatively straightforward in learning programmes leading to qualifications but much more complicated in learning that is unaccredited. The qualification becomes the proxy for learning that has occurred. Opportunities that do not lead to qualifications are offered by a wide range of providers and there is a great deal of interest in the field in how learning gain in such programmes can be identified in a way that is robust enough to allow for the recognition of such achievement. Work is currently being carried out by both NIACE and LASDA in this area examining learner achievement from the perspective of both the teacher and institution and the learner.
This issue is not confined to the Adult and Community Learning Sector. In Further Education many courses are offered that do not lead to a recognised qualification and the use of such provision in attracting non-traditional learners has been re-enforced by the Non-Schedule 2 pilots that have been running in Further Education.
We welcome the intention to recognise achievement in learning that does not lead to a qualification and fully support the Council in its stance on this issue. To treat non-accredited learning differently is to re-invent Schedule 2.
However, we would press for a system that used all aspects of the LSC’s activity in this complex task. Funding is not the only lever in the system to effect change and improving quality assurance arrangements and rigorous inspection have arguably had more effect in raising achievement in FE than the funding system.
In the evaluation of the Non-Schedule 2 pilots the requirements of audit were shown to result in bureaucratic systems that were not friendly to new learners and restricted providers in delivering what was actually needed. Any system for recognising achievement should not rely on financial auditors making judgements on the quality of provision or on the measurement of learning gain since they are clearly not qualified for this role. It should also be straightforward enough to encourage providers to undertake the processes necessary for recognition or there is a risk that it may cost more to prove achievement than will be obtained from the funding received from this element.
We would favour a system that used a simple measure to release the achievement element; completion has been offered as one measure that might be used. Completion could be further defined by percentage of programme attended if this was felt appropriate.
However, such a simple and "risky" definition would need to be backed up by rigorous quality assurance and review of providers’ activity. The LSC has very comprehensive provider review systems that would admirably serve this end and the Adult Learning Inspectorate has also expressed great interest in this area. The LSC’s planning systems should ensure that the appropriate balance is retained between qualifications bearing and non accredited programmes.
NIACE would be pleased to work with the LSC in its development of proxies for achievement where provision does not lead to a qualification.
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