The government’s review of level 2 and below qualifications was “opaque and largely meaningless”, the Association of Employment and Learning Providers (AELP) has said.
The provider body has added to warnings from exams regulator Ofqual, which said this week that the Department for Education’s reform plans risk adding further confusion to the landscape.
Representative bodies and awarding organisations have flagged a number of concerns in their responses to the DfE’s review of qualifications at level 2 and below in England, which closed for submissions last week.
Among them was Ofqual, the government’s exams regulator, which said that the DfE’s implementation timetable could “overwhelm” educators.
Qualifications consultation was ‘materially flawed’
The DfE claims the current landscape of level 2 and below qualifications is “confusing”, with around 8,000 technical and academic qualifications available at these levels, many of which cover the same or similar subjects.
NOCN boss Graham Hasting-Evans took aim at this claim, saying in an open letter published on the NOCN website that the 8,000 figure “overstates the real number of ‘different’ qualifications”.
Hasting-Evans explained that the figure double-counts qualifications that are provided by multiple awarding organisations. For example, he said: “Functional skills English level 1 is a single qualification delivered by ten awarding organisations. This is therefore displayed [on the Ofqual register] as ten qualifications. However, in reality, it is one qualification.”
“When considering policy, we need to know exactly what our baseline is” he added.
Ministers plan to axe thousands of qualifications through this review as they clean up a “confusing” landscape so that learners “benefit from high-quality provision that helps them realise their talents and achieve their career ambitions”.
But the DfE has not been forthcoming with detail on exactly which qualifications face the chop.
Sector leaders previously called the proposals “devastating” and a “full-frontal assault on the very idea of lifelong learning” which “flies in the face of the ambition to level up the country”.
A lack of evidence and detail in particular has attracted harsh criticism from the AELP and the Federation of Awarding Bodies. According to its submission, AELP’s requests to the DfE for a list of qualifications at risk of losing funding was “unfairly rejected”.
“On this basis,” the association said it “believes this consultation to be materially flawed in both its approach and its design”.
Speaking for awarding organisations, FAB was equally direct, challenging the government on its narrative that the current landscape of qualifications has too many low-value or low-quality qualifications “without any substantive evidence being presented”.
“If there are concerns about quality, then these need to be addressed by the regulator. As part of the regulated community, awarding organisations follow strict conditions to offer their qualifications. If these standards are not being maintained, then government should look at the role of regulators and other enforcement mechanisms.”
Proposals ‘appealing to policymakers’ but not best for students
Under the plans, the surviving qualifications would be placed in one of 17 new “groups” – eight at level 2; five at level 1; and four at entry levels.
Ofqual has warned: “At present, there is a risk that the large number of proposed groupings are not sufficiently clear or straightforward for students and others to differentiate between.”
The watchdog said its “expert opinion” is that it would be helpful to “segment, and define, the provision based on aspects such as qualification purpose – in effect, combining those of the 17 proposed groupings that have common features”.
Not only will this aid navigability for students, but will also provide “clarity with respect to purpose”, which is “critical” to supporting good assessment design by awarding organisations.
“This will help ensure that students are tested on the right things, in the right way, to support them in taking their next step, whether this is into work, an apprenticeship, or further academic or technical study,” Ofqual said.
The Sixth Form Colleges Association criticised proposals to divide qualifications into groups as “a simplistic approach that primarily appeals to policymakers”.
“Sweeping away level 2 qualifications that play a valuable role (for a group of young people that are more likely to come from disadvantaged backgrounds and have special educational needs and disabilities than level 3 learners) is not a price worth paying for a system that looks tidier in charts and diagrams,” the SFCA said.
In its submission, the Association of Colleges said that the DfE’s proposal to group qualifications for progression separately to qualifications for employment would also cause confusion and could reduce class sizes, making certain courses unviable.
“Having different qualifications with different purposes in the same subject area, such as construction, hair and beauty, catering and motor vehicle, for example, may lead to confusion and limit opportunity. Smaller colleges or departments with smaller numbers may not be able to run both a progression qualification and an employability qualification,” the AoC said.
Appeal for SEND learners
The DfE’s reforms will have a disproportionate impact on learners with disabilities and special educational needs, acknowledged by the DfE in their own impact assessment.
A proposed 280 guided-learning-hour maximum for entry level 3 pre-technical qualifications is too low, according to the AoC: “Students who have learning disabilities benefit from progression not from one level to another but from a smaller to a larger qualification at the same level. For these students, generalising skills and applying skills to a broader range of contexts is a crucial purpose of vocational education.
“This means that progressing from a certificate with less than 280 GLH to a diploma with more than 280 GLH is meaningful progress that helps equip them for the working world.”
The Federation of Awarding Bodies has “serious concerns about the impact of these proposals on SEND learners” it said in its submission, and advised officials to “proceed with caution”.
Similarly, AELP cautioned the government against moving too quickly to remove funding from qualifications with low enrolments: “It is important to recognise that learners with SEND tend to be registered with more niche and lower-level qualifications appropriate to their sometimes complex needs. In the government’s proposals to defund qualifications with low or no enrolments, due care and attention are required to ensure provision isn’t removed that would have a direct impact on the life chances of learners with SEND.”
The DfE’s response to the consultation, which excludes GCSEs, functional skills and essential digital skills qualifications, is expected to be published later this year.