DfES 14-19 White Paper - Skill: National Bureau for Students with

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Skill: National Bureau for Students with Disabilities
14-19 Education and Skills
Response to the White Paper
Introduction
Skill: National Bureau for Students with Disabilities promotes opportunities to
empower young people and adults with any kind of disability to realise their potential
in further, continuing and higher education, training and employment throughout the
United Kingdom. Skill works by providing information and advice to individuals,
promoting good practice and influencing policy in partnership with disabled people,
service providers and policy makers.
Skill agrees that 14-19 is a key age, for learning, achievement and raising
aspirations. We also agree that in order to achieve this, there is a need to strengthen
11-14 education. However, Skill is disappointed that the DfES has not implemented
the recommendations of the Tomlinson report on 14-19 reform more fully. We think
that there needs to be an rethink of the current system, to allow young people,
including those with disabilities and learning difficulties, to achieve their potential, to
promote vocational learning and have a consistent academic/vocational approach,
and to ensure that assessment is accessible and rigorous.
Skill was also disappointed about the lack of firm commitment to equality and
diversity and in particular disability in the delivery of the curriculum, and the lack of
inclusive language in the text and case studies. It has been recognised for some time
that inclusive learning can only happen if disabled learners are seen as an integral
part of the education system, rather than a constituency whose needs are considered
later as an add-on.
Disability Equality Duty
In addition to discussions on the White Paper, the DfES must also bear in mind the
implications of the Disability Discrimination Act 2005, which introduces a Disability
Equality Duty for public bodies, including government departments and education
institutions. The legislation includes both a general and a specific duty.
All public bodies will be covered by a general duty to eliminate disability
discrimination, to promote equality of opportunity for disabled people, to eliminate
harassment, to take account of disabled people’s disabilities even if this means
treating disabled people more favourably, to promote positive attitudes towards
disabled people and to encourage participation by disabled people in public life. This
means, for example, that public bodies will need to take into account the needs of
disabled people when making decisions or developing policy.
The specific duty applies to named bodies, which includes government
departments, the Learning and Skills Council, further education institutions and
schools, and will require them to draw up and implement a Disability Equality
Scheme on a three-yearly basis.
Chapter 5: A strong core 14-19
While Skill agrees that functional ability in core subjects such as English and maths is
very important, the DfES must ensure that core subjects are made accessible to all
young people. This is even more essential if functional English and maths is to be a
key requirement for all young people. Without proper accessibility, disabled young
people will be put at a serious disadvantage in their future learning and in the
employment market.
Skill has concerns about the functional English and maths element because of the
nature of existing Key Skills qualifications and equivalents. Often the assessments for
these qualifications are not accessible for groups of disabled people. For example,
the current Key Skills qualification in Communication is not appropriate for visually
impaired people. For blind people who are unable to physically ‘read’ the qualification
is impossible, as appropriate adjustments, eg allowing a reader or the use of screen
reading software, are currently not permitted. Skill believes that the purpose of a
communications qualification should not be to physically ‘read’ but to demonstrate
ability in processing and understanding information. People with visual impairments
should be able to achieve a qualification in communication, as they clearly have the
necessary functional skills. In addition, when qualifications become core
requirements, it is even more essential that they are accessible to all learners. Skill
recommends that in developing qualifications, the DfES must ensure that the
qualifications are accessible, appropriate standards are set and effective
adjustments made for disabled students.
Staff at Skill were key contributors in the writing of Access for All, a document which
spells out in detail what is needed for the Skills for Life curriculum to be made
accessible to the full range of learners with disabilities and learning difficulties.
Access for All has been supported by a national staff training programme and has
been very positively received by staff working in the Skills for Life area. Skill
recommends that a similar approach should be embedded into any new
curricula changes brought about in the light of the 14-19 White Paper and that
the inclusion of learners with disabilities and learning difficulties should be
addressed right from the start.
Skill also welcomes the discussion of IAG in the White Paper. However, Skill is
disappointed that there is no recognition of the needs of disabled young people,
particularly in paragraph 5.26. Disabled young people have additional needs in
relation to IAG which must be acknowledged. IAG advisers must be able to identify
not only educational options, but also the impact that options have on social services
and health provision, transport, and accessibility.
Skill believes strongly that IAG must be independent and impartial. It is not always
appropriate for IAG to be delivered by schools. School staff, though willing, may not
have the knowledge of disability support available in further and higher education to
give accurate information, and young people’s choices and aspirations might be
hindered by this. Schools with sixth forms could not be seen to be giving impartial
and independent advice.
Chapter 6: routes to success for all
With regard to the entry level diploma, Skill was represented on the entry level and
equal opportunity sub group, and we are greatly concerned that the
recommendations put forward by this group do not seem to be reflected in the White
Paper. There is a real opportunity to put work with learners at entry level on a par
with all learners and bring them in to the 14-19 curriculum framework. Skill
recommends that the DfES make a further statement on the vision for the future for
this area of education. The emphasis of the document is on achievement of level 2
and above, and although Skill is aware of the importance of this in the Skills Strategy,
we were surprised by the lack of focus on recognition of distance travelled in
mainstream 14-19. As mentioned above, we are disappointed that the work of the
entry level and equal opportunity sub-group seems to have been lost.
Skill agrees that it is important to develop vocational qualifications so that they are
considered on a par with the existing GCSEs and A Levels. However, we are unsure
of whether the Government’s approach of developing vocational diplomas alongside
existing qualifications is an appropriate way forward. Skill is concerned that the
proposals will contribute to a two-tier education system, whereby A Levels and
GCSEs are seen as the ‘gold standard’ and vocational alternatives are seen as
second best. This runs against the principles set out in the Tomlinson proposals.
When developing vocational options, it is essential that provision for people
with disabilities and learning difficulties is built in from the start. Indeed, this will
be a requirement of the department’s Disability Equality Duty. Skill remains very
concerned about the recent changes to the Entry to Employment programme for 1619 year olds, which made it much less accessible to young people with learning
difficulties and disabilities. The programme was initially very welcome as it focused
on individual need and not on a strict timetable to achieve qualifications. However
since the programme has been refocused by the LSC, there is much more emphasis
on achievement of progression to Level 2 or employment within 22 weeks, which is
not appropriate for many disabled learners, particularly those with learning difficulties
and mental health issues. Skill has heard from learners who had places on E2E
withdrawn as a result of the change in focus.
Furthermore, Skill believes that the DfES must ensure there is transparency and
clarity for students regarding the vocational options. If they are to be truly ‘vocational’,
they should lead to employment and a relevant Sector Skills Council approved
qualification.
In addition, Skill is concerned about the respective value of vocational and academic
qualifications. Although the White Paper clearly emphasises the importance of all
qualifications having the same value as routes into higher education and
employment, this is not currently the case. Skill believes that there will have to be a
lot of work, especially with higher education institutions, if vocational qualifications
are to be seen as a viable alternative to GCSEs and A Levels. The DfES must not
underestimate the importance of working with higher education institutions to raise
awareness of the new vocational diplomas.
Chapter 8: Strengthening GCSEs and A Levels
Skill understands the reasons for developing a model of post-qualification admission,
as discussed in paragraph 8.20. However, Skill has concerns that the change in
admissions procedures would substantially disadvantage disabled students due to
the resulting change in assessment for support needs, and has written to Sir Alan
Wilson outlining these concerns. It is not acceptable to change the arrangements for
assessing the support needs of students with learning difficulties and disabilities if
this carries a risk that some students may not have support in place at the start of
term. This would leave disabled students at a substantial disadvantage compared to
their non-disabled peers. Any change in the arrangements for assessing disabled
students’ support needs must be robust and must guarantee the establishment of
effective support by the very beginning of term.
Chapter 9: Engaging all young people
Skill welcomed the commitment in the White Paper to providing better opportunities
for young people. However, we remain concerned about the lack of thorough
discussion throughout the document of the needs of learners with learning difficulties
and/or disabilities, and some of the language used in the document.
Indeed the recent Prime Minister’s Strategy Unit report Improving the Life Chances of
Disabled People states in recommendation 6.8 that ‘DfES and LSC, from 2006
onwards, should ensure in response to the Tomlinson group’s recommendations for
14 to 19 educational reform that any new arrangements address the needs of
disabled young people’. Skill is disappointed that the White Paper does not
adequately reflect needs of young disabled people.
Skill does not believe that it is sufficient for a major Government White Paper to
discuss the needs of a group of learners by outlining other current initiatives, but this
is what the 14-19 White Paper appears to do, through mentioning the SEN strategy
and the LSC review. However these existing initiatives do not address the curriculum
needs of young disabled people, which the 14-19 White Paper should set out to do.
The DfES in the White Paper is not demonstrating its understanding of the issues
around the well documented needs of disabled students in the 14-19 phase.
Curriculum changes will affect disabled students, and this should be carefully
considered.
The examples in the document portray a lack of knowledge of the complexity of
disabled students’ needs. Examples used by the Department need to be positive,
appropriate and fully coherent. There is a lack of positive examples of the
achievement of young people with disabilities and learning difficulties, for example on
page 68 where the example states that five pupils who attended special schools were
not entered for the full qualification, but achieved parts of some units. A fuller
explanation of this is needed, and examples of how disabled students have been
supported in order to achieve qualifications. Young people with learning difficulties
and disabilities should be enabled, through appropriate curricula and support, to
achieve – not given half-hearted opportunities. Again, on page 71 the example
mentions that a learner has a period of illness but no mention of the support this
needed, only discussion of the learner causing the school some problems. Such
language is at odds with the concept of putting the learner’s needs at the centre,
which is the key concept of inclusive learning and person-centred planning. In this
particular example, no mention is made of Connexions, although that service should
have been instrumental in providing advice and guidance, rather than first turning to
the voluntary sector.
Chapter 10: Rigorous assessment in which all can have confidence
Skill agrees that the assessment process must be rigorous and trusted. It must also
be fully accessible. From 2006, general examinations will be covered by the Disability
Discrimination Act, and the respective awarding bodies will be required to ensure
equal access for disabled students and to make reasonable adjustments where
required. Too often disabled students are denied the opportunity to achieve
qualifications because the assessment process is not accessible. Accessibility must
be brought into the development phase of new qualifications and assessment
methods, and reasonable adjustments considered from the outset, for all types of
assessment. Skill recommends that the DfES ensure the development phase of
new assessments and qualifications includes accessibility.
Chapter 11: A system configured around young people
Skill agrees that if the 14-19 phase is to be successful, it must be built around, and
understood by young people. Skill recommends that the DfES produce appropriate
and accessible information for young people so that they understand the changes
and the options open to them.
With regard to the prospectus (as discussed in paragraph 11.31 onwards) Skill
believes that this is a good idea, but that further thought needs to be given to the
content of the prospectus. For example, disabled young people will need extra
information about the disability support, accessibility, transport, equipment etc. Skill
recommends that additional information for disabled students be incorporated
into the prospectus, or accompanying information be made available.
Skill currently produces an annual guide for disabled students, called Into Higher
Education, with comprehensive information, contact details for disability officers and
case studies of disabled students studying in higher education. The need for specific
information for disabled students was additionally outlined in the HEFCE/LSC
commissioned research into transition from further to higher education for disabled
students, which recommended an expansion of Skill’s ‘Into HE’ guide. This
publication could be replicated for the 14-19 sector if appropriate resources were
available.
Skill policy team
April 2005
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