Frontier Economics is right: the T-level tender approach is not viable

Important new research carried out for the DfE demonstrates that a single awarding body for T-levels would have disastrous consequences – let’s hope the Department for Education listens, writes Gemma Gathercole

It’s a rare moment, working in policy, when a government-published research report quite literally takes the words out of your mouth, but that was my experience when reading today’s Frontier Economics report Assessing the Vocational Qualifications Market in England.

Its analysis, on behalf of the DfE, of market weaknesses neatly summarises my experience as a former senior manager of a large awarding organisation. Successive government policies have served to drive market behaviour, sometimes for the better but often for the worse, and some of those policies have contributed to the market weaknesses that Frontier Economics has described.

It would be easy to jump into defence mode to describe why some of the high-quality provision is ignored by this sort of analysis, but we live in an age where perceptions are important and, speaking honestly, there is too much of our education system that is too opaque. We should be careful about what we wish for, though: greater transparency about the general qualifications awarding processes has seen a dramatic rise in appeals and falls in public confidence of the system. 

There is hardly any incentive to innovate or provide high-quality support

I have to admit I hate the notion of qualifications that are ‘easier to pass’ – I always remember my Dad telling me that there are no easy or hard questions, there are just those you know the answers to and those you don’t. Well the same can be applied to competence assessment: you’re either competent or not yet competent, pass or not yet ready to pass. But there’s something awkward that we must confront; the pressures on providers to demonstrate achievement, value for money, progress etc are so great that they produce an incentive to chase things that are easier to pass, even when that’s a perception that isn’t true. Frontier Economics’ report recognises this impact in what it describes as “misaligned incentives, potentially leading to a race to the bottom in terms of rigour”.

In particular, the consultancy’s analysis of the potential pitfalls of a single awarding body or consortia franchise model is particularly welcome. In analysing the current market for vocational awarding bodies, the report recognises that while in some sectors there is a proliferation of awarding bodies, there is little competition over individual qualifications, with hardly any incentive to innovate or provide high-quality support.

While this might surprise some in the market who think they compete only on the quality of their support services,  the qualifications are so similar that that it becomes an indictment of complexity of the system. Where provider choice is driven by the impact of other incentives, the service or lack of service offered by an awarding body is often not really a factor in decision-making. In research I’ve seen but which might not have been publicly published, providers frequently refer to cost as important in their decision about awarding organisation choice. However, when asked a later question about whether a lower or more competitive price would make them switch, the answer is always no.

Now let’s imagine a situation where there is no choice, there is only one board/consortium offering a route, and they have a market monopoly. They’ve had to tender to develop the route, which has a cost, and an expensive one at that. They have no competition, so no incentive to innovate, provide support beyond the basics, or if they do it has a development cost and no competition on price. They have a fixed-term license, so their offer always has a potential expiry date. That’s a risky business model; a short license is unattractive and a long license potentially removes the prospect of provider change, again challenging the need for innovation. 

Where in any of this is the consideration of cost-effectiveness, what’s the right provision for UK PLC and learner choice? Or, most importantly, quality? When the coalition government embarked on GCSE reform, the plan was to have a competitive tender for ‘English Baccalaureate Certificates’ (EBCs). This was eventually abandoned, with Michael Gove telling parliament that the reform was “a bridge too far”. The reality is that work was being done behind the scenes and there was a barrage of evidence that proved the approach would be a bad idea.

Echoing the evidence generated about EBCs, the Frontier Economics report describes both short-term and long-term risks, which include market failure and the structural impact on competition in the future. The issues of market failure should not be taken lightly: you don’t need to google too hard to find single-provision market failure in SATs, or even last year’s SATs papers that got published online.  There were issues with GCSE and A-level papers this summer, and these still enjoy a competitive market. If that had happened to high-stakes technical qualifications, they would never recover.

I hope the DfE learns a great deal from this report

The duration of the license, if it goes ahead, will be subject to much debate. Too short and no-one would perceive the investment to be worthwhile, but too long and it would effectively prevent competition for a subsequent tender as the expertise would reside with only the contract holder. While Frontier Economics does present some examples of mitigating actions, much more work is required to ascertain whether these are viable or sufficient.

I’ve often returned to the advice given to me by a former director, back when I was still relatively inexperienced in the vocational qualifications world; she told me that if I stuck around in education long enough I’d see policy initiatives repeating themselves. And, a decade later, I can confirm she was right. This doesn’t have to be the case: we have evidence and we can learn. I hope the DfE learns a great deal from this report.

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