Main Response Form

FE Guild Consultation Project

A Main Consultation Response

from the Policy Consortium

to the FE Guild Development Project Team

22 February 2013

Introduction

The Policy Consortium provides these comments in the hope that they may help shape the development of a Guild organisationfor further education, according to the requirements set out in the Grant Letter 2012-13 to the AoC Chief Executive from the Deputy Director, Teaching & Learning Quality and Curriculum Division, Department of Business and Skills (BIS) on 9 November 2012.

The Policy Consortium is a group of experienced senior professionals, all with extensive track records in further education (FE) and skills. We work together as independent researchers and consultants to provide high-quality support for providers of education and training, sector organisations, government agencies and other clients with an interest in these areas. Full details of our membership and activities are available at

Main response form

Consultation to establish a guild for the learning and skills sector

We will accept responses in any format, however, sending us your views via this form will make them easier to analyse. We are looking forward to receiving your feedback.

The closing date for this consultation is 22 February 2013

Please tell us a bit about yourself:
Judith Cohen
Consortium Coordinator
The Policy Consortium

Are you responding on behalf of an organisation or as an individual?An organisation
If you are responding on behalf of an organisation please select from the drop down menu a category that best describes you:Consultants’ Group

Quick link to questions:

Main response form

Question 1, page 6 in Consultation Document

Question 2, page 7 in Consultation Document

Question 3, page 8 in Consultation Document

Question 4, page 10 in Consultation Document

Question 5 page 10 in Consultation Document

Question 6 page 10 in Consultation Document

Question 7 page 11 in Consultation Document

Question 8 page 11 in Consultation Document

Question 9 page 12 in Consultation Document

Question 10 page 13 in Consultation Document

Question 11 page 14 in Consultation Document

Question 12 page 15 in Consultation Document

Question 13 page 16 in Consultation Document

Question 14 page 17 in Consultation Document

Question 15 page 19 in Consultation Document

Question 16 page 20 in Consultation Document

Question 17 page 21 in Consultation Document

Question 18 page 22 in Consultation Document

Please complete the answers to the questions in the boxes laid out below and email completed forms to

Question 1, page 6 in Consultation Document

Do you agree with these top level aims?

Strongly Agree
/ Agree
x / Not Sure
/ Disagree
/ Strongly Disagree

Are there other key ones we should consider?

Although these aims are largely laudable in themselves, they are limited ones that we feel conform too rigidly to a limited grasp of the territory of further education, and its complexity, by civil servants. Support for organisational development, for instance, is likely to be vital to the achievement of the other aims here, but is not made explicit.
We believe that there is a need to move beyond ‘best practice‘(a concept that is debatable, and often not wellevidenced)by referring to practices informed by high-quality research evidence. We therefore believe that promoting high-quality associated research and development should be included within the top level aims. R&D in its widest sense could be said to underpin all the top level aims as stated currently, but in our view it would be a mistake not to make this explicit.
The last point regarding attractiveness of the workplace needs some clarification. The Guild could support developments and advise, but would not have direct power itself actually to make improvements. In this respect, it might be useful to make specific mention of support for effective Continuing Professional Development for staff in the sector.

Question 2, page 7 in Consultation Document

Do you think the concept of professionalism should form the basis for the achievement of the aims of the Guild?

Strongly Agree
x / Agree
/ Not Sure
/ Disagree
/ Strongly Disagree

Are any of the above statements about professionalism not applicable to the sector and is there anything crucial missing?

We believe that the new body must have full freedom to control its affairs without political interference.
The concept of professionalism should be founded on the idea that it embodies specialist knowledge and skills, developed and passed on over time. For this to happen, the new body must concern itself fully with coordination of related ITE, CPD and R&D. This should incorporate awareness of current research into pedagogic practice and advances in relevant vocational areas (as for instance set out in Claxton and Lucas: How to teach vocational education: a theory of vocational pedagogy).
We would further argue that the following elements might receive explicit mention within the definition of professionalism:

• Theability to work in a range of environments with students who havea diverse range of needs, abilities and requirements
• a strong understanding of, and commitmentto, equality and diversity
• appropriately professional levels of competence in basic skills.

Question 3, page 8 in Consultation Document

Given the top level aims for the Guild as set out earlier in this document, do the lists above encompass the core areas of activity that it should and should not work on?

Strongly Agree
/ Agree
x / Not Sure
/ Disagree
/ Strongly Disagree

Are there any that should be omitted or added?

In general, we support the approach. However, the limited resources likely to be available to the new body call for a collaborative approach. This issue appears in a number of the questions within this document.
We would, on the whole, also add ‘representing the sector’: both influencing/commenting upon / developing policy, and communicating the sector’s roles, activities and successes to the media and public. Clearly, harmonising views between the new body and its various constituencies will bring issues: a ‘single voice’ is difficult. But it is now increasingly vital in such spheres. It is worth noting that there was a strongly-held genuine difference of view on this suggestion, from one of our 18 members.
Though the possible areas of core / priority work as indicated in the consultation document are extensive as they stand, they nonetheless appear to back off to a degree from some key areas for which professional bodies normally take considerable responsibility – such as entry to/dismissal from the ranks of the profession, or mandating kinds and levels of professional development. Such matters clearly overlap with anynew body being tasked with definitions of professionalism, developing a code of conduct, and workforce qualifications and standards.
Despite other indications in your document, we in fact endorse Lord Lingfield’s recommendation that the new body might have a role in helping coordinate students’ qualifications in the sector, working with national awarding bodies and Ofqual.
We further suggest that an explicit role for supporting and advising staff (beyond just CPD activities) is included in the remit – and that this should certainly encompass those who support teaching staff directly and indirectly, since they have considerable impact on teaching and learning. (See also our later comments on the scope of Guild representation and membership.)
We additionally note and welcome the idea from BIS that the FE sector should take ownership of the FE Charter process within 2 or 3 years. This would seem to fall naturally under the auspices of the new body, and we assume that is the intention of BIS, too.
In the immediate future, there is a pressing need to take collective action to secure the retention of the more useful materials currently housed in the LSIS Excellence Gateway, in a form that is both accessible, and properly ‘searchable’. Though we do not believe that this resource is by any means perfect, it is nonetheless valuable to the sector and should not to be lost permanently when LSIS ceases to function.
Finally, we feel that the phrase ‘a raft of bureaucratic guidance for the L&S sector‘ as something in which the new body ought not to be involved is unhelpfully subjective – no matter how far such a view may be one which all within the sector might instinctively applaud at first thought. Defining ‘bureaucratic’ is almost always largely dependent on whether you create or receive the guidance. It could for instance be argued that the food industry has been increasingly relieved of the burdens of bureaucratic guidance in recent years, thus producing a ‘trust the sector’ approach to lower-cost provision that responds to the market, with consequences that are now very apparent. Other sectors and industries demonstrate this issue, too.

Question 4, page 10 in Consultation Document

Do you agree that these six considerations should be part of the Guild’s work?

Strongly Agree
/ Agree
x / Not Sure
/ Disagree
/ Strongly Disagree

Are there any significant areas missing?

We feel that effective governance ought to be a concern of the Guild. Equally, we believe that the Guild should certainly also have some sort of role in shaping policy of all kinds relevant to the sector, and in responding to proposed policies – not least in terms of realistic implementation strategies, timetables and other practical implications of change.
Having said the above, the effective discharge of all these roles is likely to present a daunting challenge for a small, lean organization that has only a core staff, as indicated as the intention elsewhere in the consultation document.
In addition to investing in research, comparable resources need to be invested in the transformation of existing research evidence for use in informing practice. It involves the gathering together, assessment and distillation of research evidence followed by the production of user-friendly aids to practice and decision-making. This vital and relatively inexpensive function is often overlooked in the haste to produce new research, yet its impact on practice can be powerful and immediate. The Toolkit of evidence-based practices, developed by Durham University for the Sutton Trust and Education Endowment Fund, is an example that has been taken up widely by leaders in the school sector.
The Cabinet Office and specific ministries are also encouraging evidence-based approaches and it is important that sector bodies take a lead on this, rather than deferring to universities with their associated norms for the production and application of knowledge. Bodies such as LSIS, IfL, NIACE, AoC and UKCES have played leading roles in this to date and it is important that the Guild builds on their work. In particular, there needs to be:

• collaboration between practice-based and university-based researchers
• an emphasis on effective use of existing knowledge as well as production of new
• support for the key role of third party intermediaries, acting between the practitioner and researcher

Models for all of this are available (see for example the Coalition for Evidence-Based Education) and resources for it are being made available in the schools sector (for example, through the Education Endowment Foundation, EEF). A key role for the Guild could be to ensure this work is adapted for the learning and skills sector. As the issues are similar in the school and early-years sectors as well as other public services, such as social care, health, criminal justice, there are opportunities to collaborate with and learn from others.

Question 5 page 10 in Consultation Document

Should the Guild work with the sector on the development of a covenant as outlined in the Lingfield report?

Strongly Agree
/ Agree
x / Not Sure
/ Disagree
/ Strongly Disagree

In principle, we support the development of a Covenant as outlined in the Lingfield report although we find the term itself unduly portentous. Other reputable professional bodies deal with such matters through their codes of practice. With Lord Lingfield, though, we accept that this is the place for ‘the expression of a code of professional conduct and those many other matters of mutual interest across the sector which transcend anything that readily can be agreed between the individual employer and its staff‘.
However, we have some concerns that on the strength of past experience, an FE Covenant may prove ineffectual. The Guild will therefore need to work with the sector to bolster its potential to be taken seriously on all sides – and to mitigate the potential risks involved.

Question 6 page 10 in Consultation Document

Should the Guild have a key role in implementing recommendations from sector reviews and implementing relevant new initiatives?

Strongly Agree
x / Agree
/ Not Sure
/ Disagree
/ Strongly Disagree

We see a clear role for the Guild in helping to implement policy. However, the Guild should not be merely a delivery arm of government, and should therefore play a key role in undertaking such reviews and determining recommendations.They will also clearly need to consider how the role of the Guild in this respect relates to that of other sector bodies such as AoC, AELP, 157 Group, NIACE, etc.

Question 7 page 11 in Consultation Document

Should the Guild own and govern the framework to ensure that the highest standards and the excellent training practice of skills competitions can be spread across and embedded in mainstream vocational training for the sector workforce?

Strongly Agree
/ Agree
/ Not Sure
x / Disagree
/ Strongly Disagree

Though it may be desirable that the Guild takes a lead here, we do not regard it as a priority. Furthermore, we feel that ‘own’ may not be the right word to use. We are unsure how owning the framework but having no responsibility for organising and running the infrastructure would help, and there could be overlap or turf wars between the Guild and whichever other organisation was responsible. And though there may be issues about who would own and govern the framework, ideally the sector and its staff must ‘own’it. Furthermore, it would be unwise to encourage here, or elsewhere, a sense of the Guild being synonymous with the entire sector.
We also consider that ‘help maintain’ or ‘support’ would be more appropriate here than ‘ensure’.

Question 8 page 11 in Consultation Document

Are these a good set of impacts against which the future success of the Guild could be judged?

Strongly Agree
/ Agree
x / Not Sure
/ Disagree
/ Strongly Disagree

Are there other important ones that need to be included?

In our opinion, the Government’s proposal that a ‘guild’ organisation for FE should be established represents an important opportunity for bolstering the sector’s professionalism and self-respect, and enhancing its public image. An acid test will be the degree to which the new body achieves positive recognition within the sector, and from politicians, media and the general public.
A key issue will be how much the new body is sector-owned in practice, or is able to be used by government as another means of control while abrogating its own responsibilities.
Real impact is, however, also likely to be heavily dependent on the Guild’s funding,.
While generally supporting the impacts listed, we feel that as they stand they have insufficient focus on the effects of staff working in the sector, and upon those staff. We suggest that a measurement of CPD should also be included, and the effectiveness of the Guild in supporting that. There is also an ambiguity in the term ‘breadth of sector ownership‘, as to whether this is intended to extend beyond employers within the sector.
There is certainly again a strong argument that the Guild’s impact should be on the shaping of policy and its implementation implications, and not merely as a convenient conduit for delivery. This is implicit to some degree in some of the existing bullet-points, but it is by no means guaranteed.

Question 9 page 12 in Consultation Document

Do you think the Guild should aim to encompass all staff or just teaching, learning, assessment and direct support?

It should aim to encompass all staff.
If the accepted concept is that all staff, in whatever role and at whatever level, play a part in supporting the effective and efficient achievement of learner outcomes and are thus integral to learner-centred quality and provision, then it is a given that they must be involved in such a body as this, in some manner.
Having said this, the definition of professionalism given at the outset of the document may well conflict with the notions of an all-encompassing body. The range of staff employed within the sector is very broad and not all occupations thus represented fall under the banner of professional. Nonetheless, the IiP initiative covered the training and development of all staff and was able, without introducing discrimination, to differentiate between categories of occupations.

If the Guild is to encompass all staff, do you agree with the key points above?

Strongly Agree
x / Agree
/ Not Sure
/ Disagree
/ Strongly Disagree

Are there other points you wish to make on this issue?