QCA consultation on a draft qualifications strategy for the Foundation Learning Tier

A response from the National Institute of Adult Continuing Education

Published: August 2006

Introduction

1. The National Institute of Adult Continuing Education (NIACE) is an independent non-governmental organisation and charity. Its purpose is to secure more, different and better opportunities for adult learners, especially those who benefited least from their initial education. Its work embraces a wide range of stakeholder organisations and agencies including the DfES and other departments of state, the Local Government Association and the Learning and Skills Council.

2. NIACE gave a broad welcome to initial proposals for the Foundation Learning Tier (FLT) in its response to the earlier QCA consultation on the draft principles. There are considerable potential advantages in the idea – not least because it should clarify the relationship between Skills for Life qualifications and other progression to level 2 and GCSE equivalent study, bringing much-needed coherence and facilitating progression. It will also enable Sector Skills Councils to identify preparatory courses needed to progress to level 2 and beyond in industry specific-qualifications. NIACE is concerned however that the direction of development may, perversely, result in the FLT restricting rather than fulfilling its potential to benefit adult learners.

3. The primary purpose of the FLT is not age-blind. Ministers want to construct a means to support progression routes that work for adults but there is a real danger emerging that it could end up squeezing and narrowing adult participation in learning.

4. Our main concern, set out in the detailed comments that follow, is that the FLT appears increasingly to be driven from a 14-19 perspective, with adult learning considered almost as a desultory afterthought. With nearly 8 million adults with no qualifications and over 7 million with qualifications below Level 2, the potential adult client group for the FLT is considerable. Although most of these adults are economically active, it is reasonable to assume that, without a significant re-alignment of Train to Gain priorities, relatively few of them will access the FLT from the workplace. In addition, Government is keen to engage adults outside the labour market in order to raise the overall employment rate. If the further education system is to offer access to employability to people currently a long way from the labour market, it will need to be responsive to how they want to engage with learning, to build confidence and esteem. Top down planning, where the funder can predict and map student progression, needs to be complemented with space for learning journeys and progression routes chosen by learners themselves. A range of strategies will therefore be significant in engaging, retaining and helping adult learners achieve their FLT and progress to Level 2 and beyond. The success of the FLT will therefore depend on a broad and generous curriculum framework offering multiple points of entry and valuing a range of aspects of adult learning.

5. The second major concern is that the strategy appears unclear about whether the FLT is simply a set of pre-Level 2 progression pathways, or whether it is, in itself, a Foundation Level and, if the latter, where that Level ends, and what status is conferred to achievement of an Individual Learning Programme within the Tier. This is not an incidental question, on it hangs how the Foundation Level is to be promoted to individual learners, and also how the public and employers are to view its status.
Detailed comments

6. NIACE agrees broadly with the findings reported in the section ‘Development, purpose and scope of the qualifications strategy’ related to the lack of coherent provision across Entry Levels and Level 1. However, we consider it important that any assessment of the coherence of pre-Level 2 provision should review both the content of the provision and also how it is provided. Adult learning is often characterised by zigzag routes around barriers to learning, and NIACE considers it important that these barriers are also considered in any review of the coherence of provision. Apart from the personal barriers to learning encountered by learners, there are often systemic barriers which impact on coherence. Research over the years identifies such factors as geographical variations in the volume of provision; inadequate co-ordination of provision; unhelpful divisions between sectors; insufficient next-step and bridging courses; inflexible qualifications; inflexible delivery; cost; inadequate advice guidance; lack of progression routes; poor preparation for progression; and poor learner support. These issues have particular significance for adult learners within the FLT who may often be obliged to navigate their way round multiple providers to achieve their learning objectives.

7. Much community based adult learning (CBAL) offered by local authorities, colleges and voluntary organisations offers a broad curriculum which corresponds significantly to the component parts of the FLT: vocational courses, basic skills, ESOL, return to learn, subject based learning, pre-entry and entry level programmes, family learning, employee training. This blend of learning has traditionally been used to engage priority groups of people in learning and to encourage their progression. The experience of engaging hard-to-reach groups is that increased confidence, self-esteem and achievement is critical to retention and progression. Much CBAL is posited on an understanding that part-time adult learning can be a snakes-and-ladders process, and that achievements are often vitiated by the twists and turns of adults’ lives.

8. NIACE believes that the experience of CBAL needs to be better integrated into the construction of adult learning within the FLT to enable engagement, retention and achievement. The permissible timescale for engagement with the FLT will need to reflect this to avoid learners dropping out and then finding it difficult to re-engage. NIACE considers it important to see the FLT as a learning journey rather than a race to the finishing line, and welcomes the draft’s inference that sideways progression can sometimes be as significant as vertical progression.

9. NIACE therefore is in broad agreement with the key purposes of the FLT as outlined on pp 4-5. However, an additional point would relate to the new Framework, and might read:

and a further point related to recognition of prior learning (which is especially important to adults) might read:

10. NIACE considers that the section on ‘The scope of the qualifications strategy’ (page 5) requires further clarification. If the FLT qualifications strategy does not encompass the whole Entry and Level 1 of the proposed credit and qualifications framework, it is vital to set out the guiding principles for inclusion or exclusion. This is particularly significant for adult learning where there are myriad routes back into learning and where there are ‘spiky’ patterns of achievement, which need to be recognised in the construction of an FLT individual learning programme. The inclusion/exclusion question also has special significance for adult provision made through the open college networks which give adults the opportunity to accrue credits in much the same way as proposed by the new Framework. NIACE’s view is that a restrictive curriculum will be unhelpful, and that the interests of FLT adult learners will be best served by the widest recognition of achievement in whatever form it comes. The FLT will be all the stronger if it reflects the realities of adult learning.

11. Similarly, the draft states on page 6 that grades D-G of GCSE are outside the scope of the FLT. No reason is given. Many adults coming back into learning and with qualifications at this level will justifiably question why their achievements cannot be recognised within their FLT ILP. NIACE suggests that this be re-visited.

12. NIACE considers that the section on the ‘Framework development’ (page 6) understates the significance of the new Framework to the FLT. We have already expressed concern over the slow pace of development for the introduction of the Framework, and are further concerned that there appears to be no evident linkage between the trials of the FLT and those of the Framework. These two major initiatives are intertwined, and it is virtually impossible to see the FLT succeeding in terms of adult learning and progression without the full engagement of the Framework. We would propose that this relationship is given greater weighting in the strategy.

13. Whilst NIACE remains supportive of the government’s skills strategy, we think that the section on ‘Sector qualifications reform’ (page 6) needs to be placed within the spirit of the purposes of the FLT qualifications strategy as outlined on pages 4-5 of the draft, and that the vocational element in the FLT is seen as complementary to the transferable skills brought by increased confidence and the pursuit of systematic learning and training.

14. Within the section on ‘Personal and social development units and qualifications’ (PSD), NIACE considers that the inclusion of the PSD strand as obligatory for all adults is inappropriate. Clearly, some adults, especially those with learning difficulties and/or disabilities, will wish to take up elements of PSD within their ILP, and it is important that PSD provision is available to them. However, for many adults, all the transferable skills required for employability (team working, problem solving, IT, communications etc) would be contained adequately within the basic and key skills strand of the FLT.

15. NIACE is broadly supportive of the purposes for developing vocational units and qualifications as outlined on pages 10-11. However, these purposes seem to be viewed from the perspective of those entering the labour market for the first time and do not adequately embrace the needs and aspirations of the millions of potential FLT adults who are in employment or are returning to employment.

16. This issue is also relevant to the proposed ‘Titling for vocational qualifications within the FLT’ as proposed on p.15. The titles of ‘Preparation for working life’, ‘Preparation for work in (sector area)’, and ‘Preparation for work in (job area)’ seem more related to young people who have not entered the job market. These job titles may be appropriate for adults who are economically inactive, but are unsuitable people in work who are potential FLT learners. NIACE recommends a major re-think of the proposed titling – and the recognition that young labour market entrants and adult returners may need different routes to achievement and qualification.

17. Whilst NIACE generally supports the design principles for vocational qualifications in the FLT on pages 15-16, it is concerned that adoption of all these principles into programmes at pre-entry and entry levels may prove impossible, and would therefore exclude people with learning difficulties and/or disabilities (LLDD). Rather than say that every whole qualification must meet all principles, NIACE believes that a better formulation might be ‘Qualifications should be constructed as appropriate to include relevant principles …’

18. NIACE is particularly concerned that the section on ‘Subject-based qualifications’ pages 16-17 is unhelpful to adult learners. In particular, there is an unevidenced assertion that learners doing first-time areas of learning such as Spanish or a particular ICT package ‘tend to be adults who are not operating at this level in other aspects of their learning and are outside the scope of the FLT’. It is true that this description is valid for many adult learners undertaking a Personal and Community Development Learning (PCDL) course. However, it is not valid for many others who have chosen this route as a stepping-stone back into learning.

19. NIACE has two recommendations here. Firstly, that PCDL courses leading to achievements relevant to the purposes and principles of the FLT be considered as possible for inclusion in a learner’s ILP. And secondly, that prior achievement in such courses be validated as contributing to that ILP. Whilst this may present technical difficulties there is an important educational principle that learning is about the whole person, and not something which has greater or lesser validity according to the place it occupies in the a hierarchy of funding streams. If the boundaries of the FLT are set too narrowly, there will be a strong case for additional funding for PCDL to avoid the erosion of less predictable progression routes

20. In the same section, although the statement ‘GCSEs will remain the primary offer for Level 1 learners in terms of their subject-based learning’ may be true for younger learners it is not necessarily so for adults. We suggest that this section is in need of review.

21. Finally in this section, NIACE supports the ‘Design features/principle for subject-based qualifications’ on page17, but suggests that the first bullet-point be re-written to include the word tutor and so to read ‘… allowing some room for context to be chosen by the learner and their teacher or tutor’.

22. Whilst NIACE’s prime focus is not with learners below the age of 19 (page 18), it would support the concept of broad-based, personalised Entry Level qualifications and their accompanying design principles.

23. Consideration will need to be given to the many potential learners who have partial achievements that could count towards their FLT. The draft qualifications strategy proposes that the FLT will be constructed across three curriculum strands (vocational/subject, basic/key skills, personal and social) and that exemption from one of these individual learning programme will be made only exceptionally. However, NIACE considers this is inappropriate to adults, where exemption may be the rule rather than the exception.

24. NIACE regards the section ‘Recognising achievements below Entry Level 1’ as especially important, and welcomes the inclusion of primary qualifications for learners working at the bottom end of Entry Level. However, consideration should be given to whether these primary qualifications will necessarily be across rather than within the different FLT strands. It is important that the inclusivity built into the FLT is not inhibited by over-prescription.

Other considerations

25. NIACE fears that a narrow FLT curriculum offer will lead to further restrictions on the curriculum offer available to all adults, both pre-Level 2 and more generally. As indicated above, the FLT needs to include more of the myriad avenues through which adults come to learning. These are not always tidy. NIACE could only agree with the proposal in the FE white paper (March 2006) (paragraph 3.43 ‘Over time, the LSC will concentrate public funds on programmes that align with these pathways’) if the tier is genuinely inclusive – otherwise the effect would be to exclude exactly those adults most in need of flexible routes to return to learning and employment. It is understandable that government might wish to have distinctive funding streams to differentiate between work focussed primarily on progression and work focussed on personal and community development – but the challenge for the FDL is to establish parameters that open more doors to learners than they close.

26. NIACE considers it vital that the construction of the FLT acknowledges, explicitly, that the form and content of adult learning is different to school-based learning. The current draft FLT qualification strategy does not make such a distinction and, although many of its over-arching principles are universally applicable, such ‘age-blindness’ leads it to give the impression that it has been drafted for 14-19 year-olds rather than the 19+ group. Given that the potential client group for the FLT includes some 14 million adults, NIACE proposes that the draft be revised to demonstrate more clearly that it can embrace adult learners’ needs and aspirations. NIACE would be willing to assist in this revision wherever useful.

27. NIACE also believes it important to note that FLT provision should not become the principal or only provision for students with learning difficulties/disabilities or, for that matter, for anyone who will not progress to Level 2. There is a real danger that funding an eventual FLT entitlement could lead to restricted or non-existent funding for those who complete an ILP and for whom a second or third ILP is required but which falls outside the remit of ‘a first FLT entitlement’.

28. The construction of the individual learning programme should be flexible, tailored to need, and open to amendment and change. The review process should enable learners and providers to adapt and change the individual learning programme, so that learning is flexible, responsive and tailored to the learner. Consideration will need to be given to the validation of the process, in particular to prevent outcome-related funding leading to learners being encouraged to remain in learning programmes not adequately tailored to their needs.

29. The experience of learner engagement in CBAL is that success breeds success. The challenge for the FLT will be to recognise learners’ early achievements in ways that are valid and have wider currency. Here the FLT may wish to re-visit the approaches developed for the LSC by the Learning and Skills Development Agency and NIACE. These resulted in a method sufficiently robust to recognise and record progress and achievement in non-accredited learning, in the absence of formal assessment. The approach developed recognises that accreditation is not the only valid outcome of learning, but that it is possible to capture a heightened self-confidence and esteem, and a desire to succeed. It will not be helpful if just one kind of linear progression is imposed on the FLT. We suggest that, in essence, the FLT curriculum offer should be about personal capacity building, giving learners both skills and a sense of achievement and the confidence to progress. To this end, it could usefully concentrate on transferable personal and employability skills that boost self-confidence, self-esteem and enhanced desire to learn. There will be a critical importance of basic skills (literacy, numeracy, ESOL) and key skills (communications, team working, communications, IT, teamwork, adaptability, willingness to engage in learning and training, ability to review performance, motivation, problem solving, leadership and customer care).

30. CBAL providers have a long history of mixing and matching provision to meet the needs of individual learners. A bespoke blend of learning opportunities is an important element of engagement, retention and achievement. However, there is a risk that ring-fencing elements of the curriculum and defining them as the sole components from which the FLT can be drawn may close down options for learners in drawing up their individual learning plan. Even with a new credit and qualification framework where qualifications are built up from units and credit accumulation and transfer, there will be considerable difficulty in weighing the relative value of elements of personal and social development or of PCDL subject related learning. The experience of CBAL is that curriculum diversity can significantly help to retain and progress new learners. The moderation and approval of the relative validity of these individual learning programmes will be very important.

31. Some adult learners may have prior awards of some kind which are obsolete or which now fall outside recognised qualifications. There will need to be discretionary measures to ensure these are adequately recognised.

32. Recognition of prior learning has the potential to play an important part in validating the experience and skills that adults bring with them and act as a powerful kick-start for adults returning to learn. Initial assessment will cover previous achievements. In the case of adults, this will need to consider informal and non-formal learning as well as formal learning. There is a strong case for adults’ skills and experience to be recognised through a user-friendly system of recognition of prior learning (RPL) with formal credit given towards achievement within the FLT.

33. Effective and consistent information, advice and guidance (IAG) will be critical to learners’ engagement, achievement and progression. It is suggested that all actual and potential first-time learners are given an outline of the FLT, and an offer of an advice session. Good initial assessment will be essential to the construction of the individual learning programme. The assessment should be done with rather than to learners, and with an emphasis on self-assessment. For some new learners, choices about learning preferences may be difficult, and it will be important for learners to be able to re-visit this and other elements of the assessment. If the assessment attracts a unit of funding, consideration should be given to addressing adequately the needs of every learner, especially those who may find the process difficult and demanding considerable time.

34. Progress reviews will form an essential part of the FLT, giving learners the opportunity to modify or extend their ILP. Much good practice in CBAL derives from a commitment to learner centred provision, in which the learner has a direct say in the pace and the content of the course, and is able to reflect periodically on their learning and to change or amend their learning goals and objectives accordingly. The recording of achievement engages the learner in a process of reflection and self-evaluation. This works differently for different learners, and it is important that providers allow proper review time, especially in the cases of part-time adult learners and of adults with learning difficulties and/or disabilities. The experience of RARPA in CBAL can make an important contribution to the progress review element of the FLT.

35. Although the strategy goes some way towards defining the Foundation Learning Tier and of the progression pathway, it is less clear as to what constitutes the Foundation Level and how an Individual Learning Programme fits within it. NIACE considers that the qualification strategy should address the following questions:

What is the Foundation Level?

What is the Foundation Learning Tier?

What is a progression pathway?

What is an Individual Learning Programme?

More thought needs to be given to the status of achievement within the Tier in order to make it attractive to adult learners and to be accepted as part of the wider qualifications and credit framework.

36. NIACE advises against measuring the success of the FLT solely in crude data returns showing linear progression through to a full Level 2. There are a number of factors which should also be considered in evaluating the relative success or failure of FLT provision, for example:

37. The FLT has the potential to mark a sea change in the opportunities available to adults who are marginalised from learning, but NIACE recommends that the QCA review the qualifications strategy in the light of adult learners to make it responsive to their wants and needs. Some issues will not be easy to resolve, and some may require new thinking. Overall, we consider that:

38. Finally, NIACE advises against an over-hasty introduction of the full FLT. It considers that much thinking is still to be done to make it adult friendly, but the potential prize is worth the wait.

39. NIACE is able to provide further details about anything contained in this response. In the first instance please contact Mick Murray (mick.murray@niace.org.uk).

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