An open letter from Graham Hasting-Evans regarding the recent consultation on Level 2 qualifications and below in England.

This week, I like many others will have put in our response to the Departmental Consultation issued through the Department of Education entitled “Review of post-16 Qualifications at Level 2 and Below in England”.

It is appreciated that the proposals are thin on detail, and many organisations have been calling for more detail and clarity. Whilst recognising that this is the case, I think that the true intent is very clear indeed – cut funding and saw the bottom off the skills ladder, which the Chair of the Education Select Committee, Hon Robert Halfon MP, talks so passionately about.

I agree we need reform, which includes rationalisation and simplification of the qualification landscape. We need to be able to readily update all the qualifications, apprenticeship standards and NOS where there are no standards, for digitisation and sustainability ‘green’ skills. In fact, we require a new and easy way of continually updating qualifications, as there are going to have to be changes made on an ongoing basis.

Whilst accepting the need for the change, it has to be the right change. I must challenge one of the core arguments for the proposals, that a total number of 8,000 qualifications is too large, as this is based on an incorrect premise.

This number comes from the total number of qualifications on the Ofqual register. However, it is understood that this is calculated by multiplying the number of AOs delivering the qualification. For example, FSQ English Level 1 is a single qualification delivered by 10 AOs. This is therefore displayed as 10 qualifications in the register; however, in reality it is 1 qualification. Accordingly, the 8,000 number overstates the real number of ‘different’ qualifications. When considering policy, we need to know accurately what our baseline is.

Also feeding into this debate on what to do on Level 2 and below qualifications, we have the first batch of Local Skills Improvement Plans (LSIPs) published. They tell us that employers find the skills system too complex, qualifications lag behind advancements in industry, formal courses and qualifications are too big and time-consuming, tutors aren’t up-to-date, and SMEs feel systematically excluded.

None of this really gets addressed in this consultation. In fact, quite the opposite. The approval process for qualifications will be long and tortuous if what has happened in the migration of EPAOs on apprenticeships is anything to go by. Smaller qualifications and even modules of qualifications are going to have their funding removed.

The policy proposals come over as ones which are primarily for young people in full-time education, getting their first job, or adults that need a significant amount of training to move sector and/or occupation. There appears to be a constant bias toward academic type classroom delivered large qualifications throughout the document. These are not applicable to adults and young people that are developing practical skills and competencies. The funding cuts will take away the bottom rungs of the ladder and will disadvantage those that need extra modularised learning support in school and college as well as ‘lowly’ qualified adults, stopping social mobility in its tracks.

The proposals do not address the major economic challenges the country faces and will not support the levelling up agenda to reskill a workforce of some 32 million adults with short duration qualifications or modules of a qualification at Level 2 and below.

The need for economic regeneration (building back better/levelling up) does not appear to have been considered. In fact, one is left with the impression that if the proposals set out in this consultation document are implemented, the Department of Levelling up, Housing & Communities will need its own separate skills programme and a separate set of qualifications and funding. This does not appear to be a good use of taxpayer money.

Our vocational and technical education and skills policies need to recognise that not everyone will progress to Level 3. In fact, some 30% of the current workforce are in occupations at Level 2 or below. Level 2 is a legitimate goal for many as well as a stepping-stone towards an ultimate Level 3.

We do need funded modularised qualifications that match the needs of jobs in the economy and can respond to changes in these jobs due to digitisation and other factors. These must allow people to build up knowledge through smaller modularised qualifications, demonstrating progression and increased knowledge. Smaller funded qualifications are critical if levelling up and social mobility are to be properly supported. This is a million miles away from the current proposals, which if implemented, will in my opinion damage the economy and social mobility.

My advice to the Secretary of State and Skills Minister is recognise the Department has not got these proposals aligned with levelling up, economic recovery and social mobility, and as a result bin them and think again.