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1.1 Introduction1.1 The TUC welcomes the opportunity to submit comments to the consultation on Machinery of Government changes as set out in the document, Raising Expectations: enabling the system to deliver. This joint consultation by the Department for Children, Schools and Families (DCSF) and the Department for Innovation, Universities and Skills (DIUS) will have far reaching consequences over the coming years and it is crucial that the new arrangements will have broad support among all stakeholders. 1.2 The proposed institutional changes will radically change the delivery and funding of learning and skills development for young people and adults over the coming years. As such, it is important that there is a broad consensus on the overall new framework and also that the transition to the new arrangements do not adversely affect the learning and skills development opportunities of young people and adults in the immediate future as well as over the longer-term. 1.3 Before highlighting the main themes in the TUC submission (see below), it is important to note that the Machinery of Government reforms reflect a genuine recognition by Government of the ever-increasing importance of education and skills to achieving greater social equity and improvements in productivity and economic success. The establishment of two new Government departments - DCSF* and DIUS* - highlighted this approach as well as bringing a greater coordination to policy relating to children's services and this is to be welcomed. 1.4 It should also be noted that many TUC-affiliated unions will be making separate submissions to the consultation with a more detailed input on specific issues where they have a particular expertise. In particular, there will be detailed submissions from trade unions representing the workforce in the education sector, local government, and national government departments/agencies whose members will be directly involved in the organisations and institutions coping with this new phase of institutional reform. 2.1 Summary of main points2.1 The main points made in the TUC submission are as follows:
3.1 Policy context3.1 As highlighted in the White Paper, there are two key policy agendas driving the proposed institutional and funding reforms:
3.2 Two related policy agendas that are also driving the reforms are the Government's Sub-National Review (SNR) and ongoing developments to bring about a greater coordination of services for children. The proposals in the SNR include streamlining the regional tier of decision-making, including giving Regional Development Agencies the lead responsibility for regional planning and strengthening the local authority role in economic development. The TUC is also currently in the process of responding to the current consultation on the SNR, Prosperous Places: taking forward the review of sub-national economic development and regeneration. 3.3 It is anticipated that a central concern that will be raised in the TUC response to the SNR will be, that given the abolition of regional assemblies, there will need to be a focus on building a strong voice for stakeholders, especially trade unions, in the new arrangements that emerge. This issue of stakeholder engagement and union voice is also one of the central themes of the TUC response to the Raising Expectations consultation in relation to both young people and adults. 3.4 The policy context for the proposed reforms in Raising Expectations are also linked to changes to national policy-making and the establishment last year of two new Government departments, DCSF and DIUS. The TUC welcomed this on a number of grounds, including that it brought together a more coordinated national policy approach on a range of children's issues. The establishment of DCSF reflected at a national level a number of welcome developments at local authority level in recent years, in particular greater coordination and integration achieved by Children's Trusts arrangements and also greater integration of educational objectives with the wider well-being of children via policy approaches such as the Every Child Matters initiative. In addition, the transfer of the Connexions services to local authorities will mean that advice and guidance services for young people will be properly aligned with education and training provisions. 3.5 This is one of the reasons why the TUC is supportive in principle of the proposal for transferring funding to local authorities for 14-19 education and training as in principle it builds on developments to date aimed at developing a more holistic and universal approach for all services for children and young people at the local level. It will also hopefully help to bridge the chasm between the academic and vocational routes by making local authorities responsible for all education and training of young people with the support of new arrangements at the sub-regional, regional and national levels. However, a key concern is that these new arrangements are not so complex as to hinder the ability of local authorities to rapidly develop their new role in this area. 3.6 The TUC also previously welcomed the fact that the establishment of DCSF and DIUS has led to two Government departments with direct responsibilities for education and skills, highlighting the increasingly importance of these policies for driving forward the Government's social and economic priorities. However, there are some concerns about the coordination of policy at a national level by DCSF and DIUS in a number of areas and especially in relation to the overlap regarding provision for young people and their transition to adult provision. 3.7 With FE* colleges and Apprenticeships* playing a key role in provision for both young people and adults, it is crucial that DCSF and DIUS work closely together on these policy areas and that a seamless transition is achieved between youth and adult provision, and most importantly, that this is reflected in the new funding and delivery arrangements that will be introduced over the coming years. This will require the Young People's Learning Agency and the Skills Funding Agency to work closely together in tandem with a close partnership between DCSF and DIUS. 3.8 It is also important that the proposed institutional reforms take into account the impact on equality and diversity and a clear aim should be to improve access to learning and skills for all those groups who face discrimination. While the White Paper acknowledges the role that the new arrangements will have with regard to supporting disabled people and offenders, it is less expansive on the impact of these institutional reforms on other groups and this should be clearly addressed in the Government's response to the consultation. 4.1 Young people4.1 As highlighted above, in principle the TUC supports the model for transferring funding to local authorities for 14-19 education and training and giving them a strategic role in this area. This submission has already highlighted some potential barriers relating to policy and operational matters resulting from dividing education and training for young people between two government departments and two separate funding and delivery arrangements. In this section of the submission, we highlight a number of priority areas which need to be addressed in order to ensure that the proposed system will operate effectively and ensure that all young people will be empowered to fulfil their potential. 4.2 Before highlighting some key concerns, there are a number of aspects of the proposed models that are welcomed by the TUC. First, it is welcome that the Government is clear that there will be planned provision within the context of meeting learner demand unlike the comparable system for funding and delivering adult skills. It is also welcome that 'comparable funding will be provided for comparable provision' and the TUC hopes that this commitment will result in an end to the funding gap between schools and colleges for 16-19 provision. A related issue is the need for the Government to tackle the continuing pay gap between teaching staff in schools and colleges - this inequity will become more evident as the 14-19 agenda develops and more young people attend a variety of educational institutions in the locality. 4.3 It is also welcome that there is a commitment to 'a national funding formula which will continue on a very similar basis to the current formula' as this will provide a degree of stability in the new system and support quality provision. It is also important that there will be a national agency to support local authorities in this role. The Young People's Learning Agency (YPLA) will play a crucial role, especially in the early years, and it would be advisable for the Government to err on the side of caution in its longer-term aim to completely devolve responsibilities to the sub-regional clusters of local authorities. Whatever final model is adopted, the TUC believes that the YPLA should have a robust role in ensuring that high-quality provision for all young people is being delivered under the new arrangements. 4.4 The commitment to give local authorities responsibility for learners with learning difficulties and/or learning disabilities up to the age of 25 is a sensible proposal. This will serve to safeguard these particular learners during the transitional period between youth and adult provision which often does not does not meet their needs at present and which will be even more challenging once the post-19 system moves to a more demand-led approach. The Government should use this opportunity to examine the challenges facing these young people at this transitional stage and consider additional measures to improve the quality of education and training that they can access under the new arrangements. 4.5 The TUC agrees with many of the general principles underpinning the new local, sub-regional and regional arrangements set out in the White Paper. For example, it is right that the new arrangements should enable young people to access suitable provision to meet their individual needs within reasonable travelling distance. However, the TUC is concerned that the proposed models for funding and delivery set out in the White Paper have the potential to evolve into a degree of complexity that could undermine the central aim of widening and improving the education and training offer for young people. 4.6 For example, the White Paper sets out three different models on page 32 (one without sub-regional groupings and two with different sub-regional arrangements) and in paragraph 3.39 offers three different models for how sub-regional models could take forward the commissioning and contracting processes. The TUC is aware that a range of stakeholders have already raised concerns about the complexity of the sub-regional arrangements and would urge the Government to ensure that further consultation is taken on this particular issue before finalising any model. 4.7 There are a number of proposals relating to the role of sixth form colleges and Academies in the new system that raise some concerns. The decision to give a legal designation to sixth form colleges and tying them more closely to 'home' local authorities may bring a number of benefits to the new system. However, the TUC is concerned that there may be a detrimental impact if some colleges decide to use this as a pretext to radically reduce their adult provision. In the case of Academies, there are ongoing concerns about their limited collaboration with local schools in many areas currently and the TUC believes that their full involvement in 14-19 Partnerships under the new arrangements would be greatly facilitated by bringing them under local authority control. 4.8 In the context of our support for the transfer of funding, the TUC is also aware that local authorities will be taking on a range of new responsibilities that they currently do not have the capacity to meet. We welcome many of the proposals in chapter 6 on implementation designed to ensure that this key challenge is addressed, including putting in place a shadow structure and supporting staff to be in a position to deliver a high quality service when the new arrangements come into place. 4.9 Finally, the TUC is concerned that the new arrangements are designed to fully enable other stakeholders, especially trade unions, to play a key role at the local, sub-regional and regional levels. All the new LSC Regional Councils will have a trade union board member in the same way as local LSCs did and under these arrangements trade unions have had a means of articulating their input to the ongoing development of the education and training system. With the abolition of the LSC in 2010, it is not clear what arrangements there will be for trade union input under the sub-regional and regional arrangements and we therefore recommend that the Government should focus on building a strong voice for stakeholders, especially trade unions, in the final funding and delivery model that is agreed. 5.1 Adults5.1 The proposed institutional reforms relating to adults are clearly based on the recommendations of the Leitch Review of Skills and the implementation programme set out in World Class Skills (DIUS, 2007). In this context the TUC's view of the proposed institutional reforms are closely based on its previous policy responses to these two key reports. [1] In summary the TUC welcomed the scale of ambition on skills in both reports and the range of proposals designed to achieve this end. However, it expressed concerns that the new demand-side approach would only be effective if it genuinely enabled both employer and employee demand (articulated and supported by trade unions) to drive the system rather than focusing on a largely employer-led approach. In this context, our comments focus on the need to ensure that the new demand-led system operates effectively for employers and individuals alike by meeting their learning and skill needs on an equitable basis. 5.2 The Government's implementation plan for taking forward the recommendations of the Leitch Review was clearly set out in World Class Skills published last summer. The TUC welcomed a nuanced change in tone in this document, with the skill needs of individuals and employees being more centre stage than in many previous skills policy statements. In particular, the TUC welcomed the vision of a new demand-led skills system set out in the implementation plan - 'What all our reforms have in common is that they are trying to put the customer - in this case, adult learners and employers - first. We call this our 'demand-led' approach' (World Class Skills, paragraph 10). This is a much more balanced view of a demand led skills system compared to previous policy statements and it quite rightly gives due recognition to individual demand as well as employer demand. It is crucial that this is translated into reality by ensuring that employees and trade unions have a significant voice in the new institutional skills framework for adults set out in the White Paper 5.3 The implementation of the Leitch Review of Skills has endorsed the view that Sector Skills Councils (SSCs) should play a major role in driving forward the new demand-led skills system. The TUC has supported the development of the SSCs* in recent years and unionlearn* is playing a central role in coordinating the union input, in particular around the development of Sector Skills Agreements. T he sectoral approach in particular has the potential to deliver some of the key elements of a new demand-led approach, but this would need to be accompanied by a much more robust form of social partnership than simply obliging Sector Skills Councils to have at least one union Board member. 5.4 The regional dimension to the new demand-led approach and related policy reforms (e.g. the Sub-National Review) is another important dimension. T he TUC believes that the Government's skills strategy needs to be closely inter-linked to the regional economic strategies undertaken by the Regional Development Agencies (RDAs). To date there have been concerns that delivering the Government's skill strategy at the regional and sub-regional levels has been a very challenging exercise due to necessity of coordinating national, sectoral and regional skills priorities and integrating these within the regional economic strategy. As the role of Sector Skills Councils has grown in importance, it has also proved difficult to align sectoral and regional skills priorities. Whilst the TUC recognises that any further development of the new Employment and Skills Boards should build on existing arrangements and simplify coordination and strategic decision-making (e.g. as in the case of the London Skills and Employment Boards) it will also be important to ensure some key principles are applied to the ESB model, in particular by ensuring that equal weight is given to employer and employee demand. 5.5 As well as lacking a wholly coherent narrative on how exactly the new demand-led system will equally meet the skills needs of employers and the workforce, the White Paper fails to recognise the vital role of unions at the workplace level in supporting employees to raise their skill levels. The union role on skills has of course been transformed in recent years as a result of the establishment and growth of union learning representatives (ULRs) - there are now in excess of 18,000 and they are continuing to prove to be highly effective intermediaries in engaging and supporting employees to take up learning and training opportunities in the workplace. The establishment of unionlearn in 2006 has helped to build the union role further by supporting the development of a more coherent framework for union-led activity on learning and skills, in particular via the role of ULRs and innovative collective arrangements in the workplace, such as Learning Agreements. 5.6 The TUC believes that the White Paper should have been more specific about how trade unions should be given a leading role in articulating and supporting employee demand both through institutional arrangements and at the workplace level, and that this should be addressed in the Government's response to the consultation. For example, at a basic level there is a need to consider how the current role of trade unions (and employers) in helping to direct the work of the LSC will be carried forward into the new arrangements. The Government needs to consider how trade unions and employers will engage with the new Skills Funding Agency, and more specifically, what role they will have in its governance in order to ensure that it is genuinely supporting a demand-led system. 5.7 In spite of the above reservations about the proposed demand-led system for adults, there are a number of aspects of the proposed model that the TUC does strongly support. The role set out for the new Skills Funding Agency (SFA) will be vital and it will be imperative that it works closely with Jobcentre Plus* in order to support an employment and skills system that genuinely supports many more economically inactive citizens to achieve sustainable employment. It is also welcome that the SFA will house the National Apprenticeship Service (NAS), the adult advancement and careers service and the National Employment Service* (NES). This will mean that the agency will support a great deal of continuity as regards the important role of the NES and it will also provide support for the ongoing development of the other two services on a national basis. 5.8 The TUC had been concerned that Lord Leitch's recommendation to move to a fully demand-led skills system by 2010 would destabilise the FE sector. It was therefore welcome that the Government clarified in World Class Skills that this 'would create unacceptable risks to the performance and stability of colleges and providers, which in turn would damage the quality of education and training offered to learners.' However, it is important that the Government continues to closely monitor the impact of the expansion of the demand-led skills system on the ability of colleges to deliver a broad range of learning and training that supports both economic and social priorities nationally and also in all our local communities. The Skills Funding Agency, supported by trade unions, employers and other stakeholders, will need to ensure that any potential detrimental aspects of a demand-led system are tackled and rectified. For this reason, it will be important that the existing national LSC arrangements for giving stakeholders an influential role are transposed to the SFA. 6.1 Staffing issues6.1 The scale of the proposed reforms, especially the ultimate abolition of the LSC, will have a huge impact on the workforce in a range of institutions and also the propensity of the new system to build on successes to date The TUC welcomes the fact that the consultation document clearly acknowledges that the Learning and Skills Council (LSC) has played an important role in supporting the Government's skills strategy in recent years. In the TUC submission a clear priority is that the expertise built up by LSC staff is utilised in any future arrangements, without recourse to compulsory redundancies, and that the trade unions are closely involved in agreeing transition to the new arrangements. 6.2 With this in mind the TUC is supporting PCS in the central role it is playing in protecting the interests of its members whilst also emphasising that they remain committed to delivering the best opportunities for learning and skills development for all young people and adults. In particular the TUC supports the principles that PCS are advocating during the period of transition over the coming years, which are as follows:
7.1 Maintaining a focus on current skills challenges7.1 Finally, the TUC is particularly concerned that the energy and time required to plan and implement the agreed reforms do not divert the Government and its agencies from tackling the current range of skills challenges that face young people, adults and employers. There is a real danger that that the focus on organisational reform of this scale over the coming years will lead to current education and skills priorities being neglected. The Government needs to ensure, in partnership with employers, trade unions and other stakeholders, that the risks associated with this scale of institutional reform are monitored closely in order to guard against this eventuality. [1] TUC responses are available on the TUC website at: www.tuc.org.uk Briefing document (4,300 words) issued 21 May 2008  Right to Request Time to Train consultation - TUC Submission More than half the UK workforce would use a right to ask for training at work It's Time to Talk Training |
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