LGA response: DfE consultation - Implementing a New Further Education Funding and Accountability System

The DfE launched a second stage consultation on implementing a new further education funding and accountability system for adult skills. It is relevant to the adult skills system as a whole, councils’ adult and community learning functions and devolved functions. Our response was submitted on 12 October 2022. We previously submitted a response to the first consultation (September 2021).

Q1: Do you agree with our proposal to create a national model for funding that devolved areas can use as a basis for shaping and funding local skills provision?

While the question focuses on devolved areas, it is worth highlighting that all areas across England have unique labour markets including a mix of jobs, unique priority sectors, qualification levels, unemployment, and vacancies so a one size fits all approach is inappropriate. This means adult skills reforms must provide local government – councils and devolved authorities – as well as providers, with maximum flexibility to adapt provision to local need so they are part of a wider joined up employment and skills offer.

Local government’s added value in getting the skills and jobs offer right locally

This consultation and others (LSIPs) make only passing reference to the wide-ranging functions that sits within local government and their ability to successfully land and tailor skills policy on the ground into a more coherent local offer for residents, communities, businesses and other employers. Local government – councils and MCAs/GLA – in devolved and non-devolved areas are also democratic leaders and trusted convenors of partners, and should be a core DfE partner for the following reasons: 

• Planning, commissioning, and delivering adult skills: through devolved Adult Education Budget (AEB), MCAs/GLA have worked with partners to successfully shape and deliver new adult skills approaches to improve outcomes and cultivate an area-wide approach to skills. Council-run adult community learning (ACL) funded through AEB in devolved and non-devolved areas supports 500,000 adults every year, many with low qualifications to develop skills for work and life across 10,000 community venues.
• Councils’ education and training duties for young people: includes finding education and training places for young people up to the age of 17; re-engaging young people not in education, employment, and training (NEETs); and supporting young people with special educational needs and disability (SEND).
• Providing wrapround services for young people and adults with barriers through public health and its link into health services, Family Information Services, childcare and housing support, debt advice, which allows residents to then engage in learning.
• Their ‘lead authority’ role for growth and skills investment including Levelling Up, Community Renewal, Towns, Shared Prosperity and Multiply Funds which will generate new employment growth including net zero and retrofit jobs, support capital investment in FE, unlock major regeneration projects, and improve people’s skills and job prospects. 
• As strategic planners, large employers, commissioners or deliverers of services, it interlinks employment and skills strategies with wider spatial strategies to deliver local and national priorities e.g. health and social care, transport, net zero, inward investment, digital, often using social value to increase local training and job opportunities.
• Reach the entire local employer base: via Growth Hubs, economic development and inward investment functions, they work with existing and incoming employers of all sizes / sectors (micro to multinationals, public, private, charitable and representative bodies). 
• Take a holistic view on employment, training, skills, and economic growth. Many have discretionary or devolved employment and skills schemes or services e.g., local hubs and portals to address gaps / join up the system. Existing local employment and skills boards (ESBs) convene partners, promote collaboration, and provide intelligence to agencies including Careers Hubs, Jobcentre Plus and delivery partners.

Devolution areas

Existing and prospective devolved authorities and their constituent councils are best placed to respond to the specifics of how the model would impact existing / planned commissioning and delivery. Alongside their responses, the Local Government Association offers the following observations below.

Current MCAs / GLA manage 60 percent of the Adult Education Budget (AEB). The Levelling Up White Paper facilitated two new deals with more being negotiated. This could result in 80 percent devolved, leaving 20 percent managed nationally by ESFA for non-devolved areas. A commitment to invite all areas to sign a deal by 2030 will see adult skills fully devolved, so we do not think a national adult skills funding model should apply to devolved areas.

The consultation focuses on a (perceived) inconsistency of how devolved AEB operates without referencing the positive impact MCAs/GLA have had, or how DfE/ESFA could apply learning from them for the 20 percent it will manage for non-devolution areas. MCAs/GLA have applied test and learn to develop innovative delivery, improved local relationships with employers, providers, residents and constituent councils, reshaped the adult skills landscape and flexed national rules to support more residents and employers: 

• West Midlands CA stewarded a 33 per cent increase in provision aligned to regional priority sectors (such as construction, manufacturing, digital and business and professional services), introduced new ways to support people in low-paid, low-skilled work e.g., providing ‘Access to HE’ for ambulance contact centre staff to progress to paramedics, Level 4 care management for BAME workers, and construction management for women.
• Liverpool City Region CA funded the WEA with a Test and Learn pilot to help residents gain a bespoke Level 2 Maternity Nurse qualification with the aim of progressing towards the industry required standard of Level 3.
• Cambridgeshire & Peterborough CA used increase participation by nearly 10 percent (2020/21), targeted low-skilled residents in deprived areas (Fenland and Peterborough), introduced a £1,200 bursary for Care Leavers aged 19-22, and fully funded English for Speakers of Other Languages (ESOL).

We believe that DfE has a critical role in develop adult skills through the following ways:

• Develop an adult skills / lifelong learning strategy which joins up national policy and funding. Ageing populations, high vacancy rates, new technologies (digital, green, automation) changing our jobs market, supporting refugees, addressing pressures in health and social care, and increasingly moving services online are just some of the reasons why continual improvement in adult skills is essential to helping people be part of a skilled and productive workforce and lead independent and fulfilled lives, but much of this sits with other parts of Whitehall. DfE should provide strategic leadership on adult skills, join up policy and funding in its own Department, and other Government departments to develop a coherent policy.

• Invest in Level 2 and below. Creating a high skills economy has driven FE reforms and investment (Level 3 skills and above), but more investment is needed in Level 2 and below to support the least qualified be part of skills talent pipeline. Funding must be devolved so local government can target support at those that most require it.

• Co-design with devolved commissioners a light touch, permissive adult skills / lifelong learning framework allowing for maximum local flexibility. Linked to paragraph 50 of the consultation, it could cover over-arching principles, broad objectives and outcome measures, minimum standards, and a ‘what good looks like’ tool for procuring and managing provision.  

• Adopt a ‘local-first’ approach to new or repurposed skills activity. Devolution and a ‘local first’ approach should be the default position for new programmes and initiatives, with the aim of taking more decisions locally and freeing up departments to tackle national issues. For instance, the way DfE worked with councils and devolved authorities to plan and deliver the Multiply adult numeracy programme is a step in the right direction. We now need to see maximum flexibility for them to deliver.

• Prepare for full devolution now by empowering non-devolved councils with a ‘Community Skills Lead’ to plans the adult skills offer for Level 2 and below. Paragraph 30 suggests until a devolution deal is reached in all areas, the ESFA will continue to directly fund providers in non-devolution areas. We do not agree. In non-devolved areas, no single authority has a strategic role to plan adult education at Level 2 and below, yet councils already plan and deliver ACL and Multiply and are democratically elected. A ‘Community Skills Lead’ role would allow for 1) a coordinated local offer in non-devolved areas now, 2) smooth devolution transition for councils, DfE/ESFA, and 3) support Employer Representative Bodies (ERB) to develop adult skills pathways within Local Skills Improvement Plans (LSIPs).

• Play its part in improving the employment and skills offer for all areas. Our analysis reveals £20 billion is spent on a complicated mix of 49 national employment and skills-related schemes or services across England, managed by multiple Whitehall departments and agencies, delivered over different boundaries by various providers. While well-intended, they are disconnected, short-term with no single organisation coordinating the system overall nationally or locally, so it is hard to join up provision for learners, unemployed people, career changers and employers.

The LGA’s Work Local is a blueprint for moving towards an integrated and devolved employment and skills service for all places and could act as a delivery mechanism to help ERBs deliver LSIP priorities. It will give democratically elected local leaders the power and funding to work with partners to join up careers advice, employment, skills, apprenticeships, and business support provision for their areas, with local and national accountability for outcomes. The underpinning principles are:

• a ‘one stop’ place-based service
• with clear and responsive local leadership
• that is driven by local opportunities and needs
• within a common national framework for devolving strategy, financing and delivery of employment and skills
• underpinned by Devolved Employment and Skills Agreements to cover outcomes and funding envelope
• delivering better outcomes at lower cost.

A cost benefit analysis reveals it could increase by 15 per cent the number of people improving their skills or finding work by using investment more effectively – adult skills, contracted employment support and UKSPF, apprenticeships and 16-19 funding. We also believe careers advice and JCP employment support should be part of this, however there is limited public information about their budgets.

To make this happen and improve the system for all areas, local and national government need a new partnership – a Work Local Board – that would:

• get the basics right everywhere so all places can join up the offer more effectively. Our prospectus for change sets out what changes are needed
• empower local leaders and agree a framework for employment and skills devolution
• implement Work Local and roll out more place partnerships sooner than 2030. 

Q2: What are your views on the core elements of a national model set out in the consultation document? Are there other elements which should be included?

Response to creating a streamlined and simplified Skills Fund.  

See our response to question 3 regarding merging Community Learning. Notwithstanding this, DfE’s commitment to simplify and streamline a small but important part of the system – adult skills – and increasing flexibility for learners and employers by creating a single Skills Fund is a step in the right direction. It must though come with a commitment to a single place-based approach and incorporate a mixed and balanced funding offer for community skills, basic and functional skills, alongside technical and higher-level skills to make inroads into addressing productivity, levelling up, and social mobility.

Work Local recommends that Government accelerates a move towards three-year placed based approaches. Alongside adults skills funding (including bootcamps), wider funds such as contracted employment support, UKSPF, careers advice and JCP employment support should be considered with more influence over apprenticeships and 16-19 funding.

There should also be a place based, three-year, programmatic approach to DfE capital funding to help FE providers meet current and future local need. This would enable local government to work with providers and employers to set up new facilities, purchase kit and hi-tech equipment for delivery of specialised curriculum to meet new employer demand. Eligibility for FE Capital funding should be extended to include ACL providers. 

Response to moving from historic allocations to a “needs-based” funding formula.

While we support the principle of moving towards a needs-based funding formula, certain areas will gain and others will not. As a minimum, a range of criteria need considering including spatial conditions (rurality, coastal and urban), levels of skills and deprivation, population growth etc. A new formula must be subject to a full impact assessment and consultation including what transitional protection will be made available to mitigate against funding changes.   

Response to adopting a lagged funding model.

The lagged model already applies to 16-18 provision where there is a clear idea of cohort size and a consistent population for the duration of an academic year but even with that, it inhibits roll-on-roll-off provision and can result in financial burdens in-year when experiencing growth. This makes it difficult to apply to adult education where known quantities – numbers, enrolments, course duration, etc – are not always clear. It could reduce flexibility to meet local employer need and hinder any LSIP curriculum changes. If this applies to council-run ACL provision, additional financial pressures due to the lagged model would be hard to withstand.

Devolution areas should be free to determine their own funding allocations process in line with local commissioning arrangements, local need and skills strategies and therefore be exempt from ‘lagged’ funding in their mayoralty. 

Q3: What would the impact be, both positive and negative, of adopting the proposed objectives for non-qualification provision?

The proposals are problematic for the following reasons:

1. The objective of the wider benefits of adult and community learning to support health and wellbeing, integration and community development are removed.  
2. Achieving an employment and further learning for all learners is not realistic.

We welcome the objective to support people with learning difficulties and/or disabilities.

MCAs/GLA should be exempt from this proposed change to ‘Non-Qualification’ provision.

Local government is using funds to support adults into further learning and work

Adults with the lowest qualifications are least likely to access adult training despite being the group that would benefit most. That’s why adult learning services’ first steps engagement is so crucial in reaching people and communities experiencing disadvantages, whose support needs often demand coordinated intervention of different council and external services. Councils and devolved authorities regularly use ACL funding with their own devolved and / or discretionary employment and skills services to make resources go further. Ultimately, they aim to address entrenched issues so people and places can reach their potential.

• Bristol City Council’s employment, skills, and learning service (ESL) coordinates apprenticeships, ACL, post-16, and employment support. One project ‘Move In, Move On, Move Up’ helped homeless people progress towards work by building their skills, resilience, confidence and independence. Funded by DWP and the council, it brought specialist partners to create a new delivery model including housing, health, drug and alcohol support and debt advice. Between December 2020 and October 2021, it supported 100 rough sleepers, including 28 who started employment and 35 who completed an English language course. Working with the council’s homelessness support team, ESL is looking to incorporate this into permanent delivery.

• Kirklees Council’s Adult and Community Learning worked with West Yorkshire Combined Authority to strengthen pathways to higher level skills given 13 per cent of residents have no qualifications. Around 40 per cent of ACL learners had existing qualifications at level 2 or below, rising to 57 per cent on first step programmes, such as food hygiene. The ACL offer is diversifying access points into learning, blending on-line and in-person training, to provide a strong foundation for progression with short first-steps provision deployed experimentally to assess new forms of delivery to meet the needs of learner groups, allowing services to be refined and more impactful.

• East Sussex County Council’s Moving on Up! programme supports people in refuges, temporary and supported accommodation, as well as Ukrainian and other refugee groups, travelling communities and those leaving care, offering employment skills, training and brokerage to people whom councils have statutory responsibility for and direct access to, with a view to moving into independent accommodation. It engages a partnership of district and boroughs, community sector, DWP and colleges to deliver it. The council uses its AEB, Multiply and UKSPF, and the college AEB to fund specific training elements, while public health, council, and Homes for Ukraine funds support the wider social and wellbeing elements as well as addressing obstacles to learning, like travel, mental health, confidence building, clothing for work and childcare. Around 80 individuals a month are referred onto the programme.

• Westminster Adult Education Service (WAES). Adult learning is not instant or straightforward, so services are skilled at creating the conditions to enable gradual progress. In 2019-20, WAES supported 148 adults to sit and achieve GCSEs in English and maths. Of these, 96.2 per cent (126) achieved a pass mark and 61 per cent achieved a high grade - the national average pass mark was 92.5 per cent. Nadia, a mother of three from Morocco, is one of these GCSE learners. She started as an ESOL student and became interested in teaching assistant roles to support her own children's schoolwork. She started by volunteering and while initially lacking confidence, with her teacher’s support, achieved maths and English grades, went on to qualify as a teaching assistant, and now works in a local primary school.

• Redbridge Institute of Adult Education’s ‘Working in mind’ is an employability initiative targeting priority Jobcentre Plus clients – unemployed adults with mental ill health and older people with poor literacy skills. Working with partners such as Redbridge Concern for Mental Health and other local mental health charities, the initiative combines traditional employability support, dyslexia screening, wellbeing coaches and access to social prescription provision, such as mindfulness training. Around 50 per cent of participants progress into work, while others to further learning.

• Essex County Council’s pilot was developed in the context of Harlow needing up to 14,000 battery electric vehicles (EVs) by 2030. It supports the transition to EVs by creating a new Electric Vehicle Centre at Harlow College, opening in September 2022. It will fund 50 free places over a 24-month period for Automotive Technicians to develop the skills to maintain and repair EVs, futureproofing local employers. Community learning is a tool to raise local awareness about EVs and help owners understand their vehicles. With more funding, they can extend this to include training courses to upskill electricians to install or maintain council-owned charging points.

• Central London Forward’s £51 million devolved ‘Work and Health’ programme, ‘Central London Works’, aims to support 21,000 residents with health conditions and disabilities and the long-term unemployed into work. Not only do CLF and Ingeus, the provider, work closely to assess referral numbers, job starts, and the quality of jobs and support, they work with the boroughs to integrate borough-led and JCP provision including through ‘super centres’ in Hackney, Lambeth and Islington, which also helps to support employers’ recruitment needs.

• Greater Manchester Combined Authority’s (GMCA) ‘Working Well’ suite of devolved and test-and-learn employment and health related programmes, take a whole-population approach to health, skills and employment. The programmes have supported more than 60,000 people, helping more than 15,500 into work - a success rate of 26 per cent. Provision also supports inactive groups. GMCA recognised from the start that to turn Greater Manchester into a ‘northern powerhouse’, it had to tackle the very high level of economic inactivity, and particularly health-related economic inactivity. It was also a key element of the health and social care devolution deal.

More examples are captured in our Learning for Life and Work Local reports.

Today, addressing record levels of vacancies is our biggest labour market challenge, and we know that rising levels of economic inactivity and long-term illness (both affecting the over 50s) are key drivers for this. DWP has urged lead authorities – councils and MCAs/GLA – to use the Shared Prosperity Fund (SPF) people and skills strand to engage economic inactive people, which can only be used, in most cases in 2024/25 only, with no funding certainty thereafter, and replaces a much larger European Social Fund (ESF) which ends next year.  

Economically inactive people may have been out of work for some time and lack confidence to engage in formal learning. Community learning is a vital first step engagement that can boost adults’ confidence, address mental health and for many provide a path back into formal learning and work for those furthest from the jobs market. Reducing the objectives of community learning will limit the options councils have to support this group.

We recommend re-inserting the wider benefits of adult learning.

ACL providers (councils and institutes of adult learning) help 500,000 adults a year develop skills for work and life across 10,000 community venues including libraries, community centres and village halls. These courses assist those furthest from the labour market, are used as a social prescribing tool, and can help end generational disadvantage. ACL has been referred to by the House of Commons Education Select Committee as the cornerstone of adult learning, and Ofsted rated 93 per cent good or outstanding, because they know how to identify, promote, and incentivise residents with low qualifications least likely to seek it out.

Many councils find that demand for ACL surpasses ESFA funding, so they adopt a ‘Pound Plus’ model of income generation which adds to their existing budget through, for example, course fees, financial sponsorship, low or no-cost learning spaces, donations of equipment, and other funding sources and grants.

In our response to the first consultation, we warned against merging Community Learning with the wider Skills Fund without providing adequate protections (e.g. ringfencing). This is because while both support productivity, the Skills Fund is aimed at higher, technical skills while Community Learning helps people experiencing disadvantage. We also suggested provision could be set as a reasonable percentage of total spend and devolved to locally democratic delivery partnerships which understand the cohorts that need to be supported, can determine the most appropriate delivery metrics and set provision to meet local need.

This consultation goes ahead with the merge, proposes no protections, and removes the objective of the wider benefits to health and wellbeing, integration and community development. Councils (through HOLEX, the representative body for ACL services) tell us that the removal of the objective will put at risk the following provision and cohorts:

• family learning
• those referred via social prescribing through GPs for instance (including people experiencing mental health issues)
• joint courses to integrate communities
• older learners or other groups not seeking employment (parents and carers)
• adults rehabilitating from drugs and / or alcohol dependency
• household budgeting courses
• improving family health through learning about healthy eating
• ESOL to help adults integrate and support their family to also
• supporting women who are in domestic abuse situations to rebuild their lives.

The loss of this provision risks:

• councils’ ability to help adults cope with life’s challenges, lead independent lives and reduce reliance on other public services such as health, housing, and probation and the ability of the community and voluntary sector to support struggling adults. Many courses are delivered in partnership with other local and national services and charities. By removing a layer of skills support from people dealing with life’s challenges including managing household budgets and mental health (which has risen sharply due to the cost-of-living crisis, and before that the Covid 19 pandemic), we are concerned where people that need support will turn to.

• further reducing the number of adults moving into further learning or work and harming growth ambitions. Adults do not take a linear journey to learning like most young people. Most turn up to an adult community learning setting because they want a fresh start, need to find a sense of community or improve their wellbeing. They do not usually sign up for their first course because they think it might lead to a specific job or on a pathway to a qualification. First steps learning like those listed above are vital to get them through the door and are more likely to take a next step with the support of dedicated local tutors.

Other issues

• Net zero / cost of living support. We believe that adult and community learning can play an even greater role in supporting residents, communities and employers. With more funding, the Government could increase community engagement and outreach by using ACL to deliver carbon literacy to raise residents’ awareness about energy efficiency and net zero measures, as our Essex example shows above. It could also provide energy saving advice which is critical to supporting households during cost-of-living pressures alongside complementary place-based support delivered by the Energy Savings Trust.

• Councils have told us that the term ‘non-qualification’ is unhelpful. We recommend ‘community skills’ as an alternative.

The unintended consequences of this proposal are significant, but we are confident this was not DfE’s intention. It should publish an impact assessment of the proposed changes on adult learners (and where they will turn to for alternative support), the levelling up agenda, other government services, voluntary and community organisations and public sector jobs.

Q4: How should we monitor providers delivering against these objectives?  

Monitoring of non-qualification provision objectives is difficult as this could range from community learning through to programmes like Skills Bootcamps, which have very different objectives. As a mechanism, the Individualised Learner Record (ILR) could work, but would need to be adjusted, as destination/outcome monitoring is inconsistent and often time consuming, and providers are not paid to capture more details information.

Q5-10: Funding for Qualifications  

Please see our response to Q18.

Q11: How should credit-based courses which are currently funded at a higher rate be treated in the new Skills Fund? 

N/A

Q12: Do you agree with our approach to setting rates for maximum amounts for Advanced Learner Loans?

N/A

Q13: Do you agree with our proposal that providers should be able to earn a given percentage of their Skills Fund allocation on innovative provision?

Q14: Do you agree that this facility [funding innovation] should only be available to providers who meet the criteria set out? We would also be interested in any case studies of how you have successfully developed and implemented new and innovative provision.

Small and niche providers (which usually have lower contract levels) should not be excluded by criteria such as percentage/value thresholds, as they are often well placed to innovate and flex their offer.

In non-devolved areas, much more could be done to incentivise collaboration of a joined up local provider base, drawing upon the strength of each provider and creating pathways for adults to increase their skills from entry level through to higher level skills.  

In devolved areas, MCAs /GLA have already put in place their own local approach to ‘innovation’ to encourage local responsiveness and provider/employer partnerships and this should continue. For example, Cambridgeshire and Peterborough CA invited providers to develop proposals to pilot innovative delivery models, capacity building initiatives and new curriculum development.

Q15: Do you agree with our proposal to allocate a fixed sum to grant funded providers for learner and learning support based on their historical level of this funding or should we continue with the existing arrangements? 

Learner and Learning Support funds should not be ring-fenced. Grant providers should be free to plan and allocate funds as part of the Skills Fund allocation. This will provide maximum flexibility for them to respond to learner needs and ensure they are meeting their duties under the Equalities Act 2010 and responding to learner hardship.

Q16: To what extent do you think this reform will result in a reduction in data and administrative burdens?   

To some extent it will, however a move towards merging more adult education funding into the Skills Fund and simplifying the offer would undoubtedly also have the benefit of reducing administrative burdens further. More should be done to reduce and simplify data collection as it is a barrier to learners particularly those engaged in shorter learning as it can take a significant time for enrolment, administrative follow-up etc.  

Q17: Do you agree with the approach to multi-year funding?

Yes. Multi-year funding settlements would allow providers to plan with more certainty, consider areas of growth and demand more sensibly, take risks in adapting to changing employment and community needs and avoid a process of time-consuming bidding process. Providers should be incentivised to work together locally to identify the multi-year investment priorities that will benefit local economies and communities. Local and combined authorities are in a unique position to facilitate this.

Multi-year allocations must consider inflationary increases, as static year to year allocations would in effect mean reduced budget over time for similar learner numbers. The DfE need to urgently review the inflationary pressures on skills budgets and provide an in-year inflationary increase for 2022/23 and further years, to ensure participation in adult learning and skills does not decrease.

Q18: What level of granularity do you think would be helpful when setting national skills priorities?

• Current and future skills priorities will differ from one area to the next. For instance, what is a ‘green economy’/’green skills’ or priority manufacturing industry to one area will be different to another. There must be an ability for local areas to flex these locally. As evidenced in the national list of economically viable Level 3 approved qualifications (now called free courses for jobs), some MCAs found that sections of their foundation economy would not benefit from these, so used their devolved AEB to widen access to supplementary qualifications, supporting more people to upskill. Flexibility is crucial for all areas – devolved and non-devolved.
• As has been highlighted in the recent guidance for local skills improvement plans (LSIPs) they will only focus on certain skills required. Since local government – councils and MCAs/GLA – are lead authorities for local growth and skills investment including the Levelling Up, Community Renewal, Towns, Shared Prosperity and Multiply Funds which will generate new employment growth including net zero and retrofit jobs, unlock major regeneration projects through major schemes / contracts, strategic local planners (inward investment, environment, transport) and are large employers, commissioners or deliverers of services, their intelligence must be used as DfE develops this work.

Q19: Do you agree that the Performance Dashboard provides the right mix measure to capture what ‘excellent’ FE delivery looks like, including for non-qualification provision? We would particularly welcome comments on the Learner Employability measure and the English and maths measure?

No, the Dashboard does not provide the right mix of measures as it is too fixed on linear routes into employment and does not allow the wider benefits of learning / value added through community learning as a means of initial engagement to be recognised. 

Q20: Looking at the Dashboard measures, are there any unintended consequences or behaviours that you think the Dashboard will have?

Yes, as currently written, the dashboard encourages a direction towards narrow and direct employment related courses which will reduce and restrict the adult education offer, narrows its impact and excludes learners. The reality is it can take more than one intervention / course to reach this goal for some who have not been engaged for some time. This makes it harder to measure progression / employment in one academic year (which is also relevant to Multiply) which disincentivises providers to work with those who may need longer. The following measures should be considered:

• health and well-being,
• progression in work (possibly using increase in pay and / or hours),
• improving essential skills (communication, ability to work in teams, community connections, numeracy, literacy and digital),
• indicators of personal achievement or meeting life goals – e.g. gaining the confidence to plan next steps (which may include moving towards employment or further study).

Incremental progression of this type is not only related to independent living for those with defined learning difficulties or disabilities. All of these may help learners progress towards employment or further learning but are not easy to capture.

Q21: How can we best streamline information requests from DfE and MCAs to keep burdens on colleges to a minimum?  

Data sharing should be improved between DfE and MCAs/GLA, so information can be collected once and used multiple times and shared with relevant funding agencies. This should be co-designed between devolved authorities and DfE.

Q22: Do you agree with our proposed approach to Single Improvement Plans?

Yes. We welcome the MCAs/GLA being included as key stakeholders in the FE Commissioner’s diagnostic and improvement support.  Local Authority ACL providers should also benefit from FEC Diagnostic support. We welcome further engagement with LGA and HOLEX members to develop this.

Q23: Do you agree with our approach to reviewing the assurance process for the ESFA and providers?

N/A

Q24: Do you agree with our proposals for which providers should be in scope for our accountability reforms?

No. This proposed reform is narrow and focused predominantly on FE Colleges. This is a missed opportunity. The scope should be broadened to cover all grant funded assured providers to also include institutes for adult learning and local authority adult learning services. 

Q25: Do you have any comments about the potential impact, both positive and negative, of our proposals on individuals on the basis of their protected characteristics?

Q26: Where any negative impacts have been identified, how might these be mitigated?

It is clear from our response to question 3 that narrowing the objectives to employment and further learning outcomes only and provision for adults with recognised disabilities and learning disabilities excludes many other groups who currently benefit from Community Learning provision. This is likely to include learners who are experiencing disadvantage, or who come from a protected group or characteristic. The DfE must carry out a full impact assessment on the implications of learners.