A decade-long spree of assessment reform has taken its toll on awarding organisations which are battling through levels of uncertainty while bearing the financial and human cost, according to NCFE chief executive David Gallagher, the new chair of the Federation of Awarding Bodies (FAB).
In his first interview since taking on the FAB role, Gallagher addresses the impact of skills’ shifting architecture on sector morale and market sustainability, and sets out how he wants to support the regulated community, particularly smaller and niche awarding bodies.
He also tells FE Week how he plans to utilise his own organisation’s experience of “brutal but necessary” regulation intervention. And he explains how FAB is making a tangible difference behind the scenes – asserting that apprenticeship assessment changes, for example, would have been “far worse” than what is now being proposed.
Weathering wave after wave of reform
Gallagher joined education charity and awarding giant NCFE in September 2018 as managing director of end-point assessment (EPA) before being quickly promoted to chief executive the following March.
Since that time the awarding sector has worked through the introduction of apprenticeship standards and EPA, T Levels, and topsy-turvy decisions on applied general qualifications to name a few policy changes.
The sector is now braced for even greater reform with the introduction of V Levels, the lifelong learning entitlement, higher technical qualifications, new level 2 pathways, the growth and skills levy and perhaps most controversially, the end of EPA.
“We’ve been in a state of major reform for a very long time,” Gallagher says.
“You recall this view that we were going to end up in a world with just T Levels and A Levels for 16 to 19-year-olds, and then obviously that was eroded over time. It doesn’t feel like that long since we introduced end-point assessments, and now that is being changed.”
Last month’s skills white paper, he adds, is “the most comprehensive basket of reform since I’ve been in the sector, around 22 years”.
Alongside V Levels and T Levels refinement, Gallagher reels off a list of regulatory and policy shifts reshaping the landscape simultaneously: apprenticeship units, functional skills adjustments, OfS regulating higher technical qualifications (HTQs), and the prospect of colleges getting their own awarding powers.
“It’s a huge programme of reform,” he says, “and what I’ve picked up on is a real mixed response from the sector”.
Many recognise that some elements – such as the bureaucracy and duplication in EPA – needed attention. But the speed and breadth of change comes at a heavy price.
AOs, he says, are being asked to “bear all of the uncertainty and the cost of another much bigger programme of reform,” without having seen the benefits of the last one.
Gallagher accepts that the motives behind much of the reform are “honourable”, as ministers or civil servants “have spotted problems and challenges and are looking to make improvements”.
But the disconnect between policy intent and practical delivery is widening.
“Underneath some of this, we’re talking about this being a simplification agenda,” he says. “I’m seeing a lot more complexity and confusion coming in.”
More than anything, organisations are struggling with the sheer lack of stability.
“Human beings don’t particularly like a lot of uncertainty a lot of the time. When everything’s uncertain, I think it’s really challenging in terms of the culture of the sector, the morale of the sector, even just the wellbeing of individuals.”
Policymaking ‘catch-up’
Labour’s new national skills body – Skills England – was billed as a chance to inject coherence into the system. But Gallagher warns it hasn’t yet had the stabilising effect many hoped for.
“We’ve gone from the Department for Education having the mandate working with the Institute for Apprenticeships and Technical Education, and then IfATE abolished, and Skills England being established, and then half of skills being shifted across to the Department for Work and Pensions, all with devolution in the mix,” he says. “It’s really challenging.”
Labour’s intention to broaden engagement with employers and beyond – to include trade unions, providers and professional bodies – is a step forward in principle, Gallagher says. But he argues that genuine consensus-building in the qualifications ecosystem is slow and complex work.
“It’s very rare that you could sit in a room with an AO, a college, an employer, a civil servant, a professional body, and quickly reconcile on what the problem is and what the solution is,” he says. “Getting that alignment is incredibly challenging.”
Instead, political appetite for quick wins is leading to policy being announced first and designed later.
“There’s a political desire to get the things moving more quickly, without spending a very long time trying to figure out the complexity, understand the root cause of the problems, and really think and work through the solutions,” he says.
“We tend to be announcing policy, and then the planning is always catching up. I’m the first one to advocate for an agile and responsive system, but the planning and the execution are arguably even more important.”
Compounding this is a worry he says regulators themselves have raised: a significant minority of AOs are now loss-making.
“That’s a real worry in terms of market stability and sustainability,” Gallagher says.
FAB-ulous influence
Gallagher is clear that the sector is stronger as a collective and sees FAB’s job as co-ordinating the position of all members, large and small, to create a more coherent and sustainable market.
He says current apprenticeship assessment reform is one example where the influence of the federation has come into play.
Ministers are currently pushing through changes that will see the end of EPA, moving to a system where only around 40 per cent of an apprenticeship standard’s knowledge and skills are mandatorily assessed independently. The rest will be “sampled”, mandatory qualifications in some standards will become the sole method of assessment, and behaviours will be “verified” by employers.
The proposals have been met with backlash from businesses in multiple safety-critical industries that fear apprentices will be allowed to pass without proving they are competent, as an FE Week investigation revealed last week.
Gallagher says FAB saw earlier drafts of the policy proposals that, in their view, would have gone dangerously far.
“It would have been an even more diminished role for any type of independent assessment, to the extreme that they may not have had a role.”
He adds that he is “still nervous” that elements of the current reform might not be right, but he “very strongly” believes that “if we [FAB] hadn’t worked actively in the background, it would have been worse for all stakeholders”.
Three-year term goals
Gallagher has been on FAB’s board for around five years. He is now stepping up from vice chair and replacing Lifetime Training CEO Charlotte Bosworth as chair of the federation.
He says Bosworth set a “brilliant example” of how to challenge “some really contentious, quite politicised, quite polarising things” and helped bring “stability” to FAB with CEO Rob Nitsch.
He now wants to follow Bosworth’s “calm” approach and has broad priorities for his three-year term.
The first is more professional recognition for people working in the sector – a nod to the federation’s work to deliver an “individual professional recognition” pathway. Gallagher says assessment design experts are “really difficult” to recruit and retain, but are more important than ever with reform “on steroids”, and he hopes this pathway will help.
He secondly wants to protect the specialist niche awarding bodies that “feel most threatened” by policy churn, recognising smaller AOs must have their “voice heard” and be “listened to, understood and supported”, just as much if not more than the larger awarding bodies in the sector.
Gallagher also sees an opportunity, with his commercial background experience, to help FAB members explore commercially resilient strategies, including international markets and new commissioning opportunities through the DWP.
Learning from ‘brutal’ intervention
Lastly, he wants FAB to be an “improvement partner,” helping the sector anticipate risk and not just react to it.
To this end, Gallagher reflects on recent years when NCFE was subject to significant Ofqual intervention in the wake of early T Level issues. He plans to use this difficult experience to help others across the sector.
“We were the only organisation that really was subject to any sort of intervention or public scrutiny,” he says. “That was really difficult to swallow.”
He stresses that this was not “a criticism of Ofqual,” but rather a consequence of NCFE being positioned “in the middle of the policymakers and the contract holders and the regulators and the colleges”.
Once intervention was finalised, however, he says the “brutal” process ultimately strengthened the organisation.
“It was the least preferable way to get you fit to run a marathon, because it was brutal, but it was necessary,” he reflects. The scrutiny acted like “scaffolding” which at times “felt a bit too heavy” but ultimately it helped to “repair all of the different areas in the business”.
In hindsight, NCFE is “so much better for it” and it has shaped Gallagher’s thinking about FAB’s future role.
“What I would love is FAB to increasingly play a role in helping organisations to understand what intervention could look like,” he says. Not just “getting off the naughty step,” but strengthening AOs before problems arise.
FAB currently has a record number of members – 161, which is just over 85 per cent of the government technical qualifications in the UK.
“Wouldn’t it be great if every Ofqual regulated awarding organisation wanted to be part of FAB’s membership because they saw value in it,” Gallagher concludes.
“If our voice can really step in, we can start trying to depoliticise this a little bit.”
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