Consultation on Revocation of Further Education Teachers’
Qualifications (England) 2007 and Further Education Teachers’
Continuing Professional Development and Registration
Regulations (England) 2007: Response Form
The Department may, in accordance with the Code of Practice on Access to Government
Information, make available, on public request, individual responses.
The closing date for this consultation is 4 June 2012
Name: James Noble-Rogers
Organisation: Universities Council for the Education of Teachers (UCET)
Address: Institute of Education, 20 Bedford Way, London WC1H 0AL
Completed responses should be returned to:
Sue Ruck
Teaching Learning & Workforce Reform Team
Department for Business, Innovation and Skills
2 St Pauls Place
Sheffield
S1 2FJ
Email:sue.ruck@bis.gsi.gov.uk
Please tick a box from the list of options below that best describes you as a respondent. This
allows views to be presented by group type.
X
Business representative organisation/trade body
Central government
Charity or social enterprise
Individual
Large business (over 250 staff)
Legal representative
Local Government
Medium business (50 to 250 staff)
Micro business (up to 9 staff)
Small business (10 to 49 staff)
Trade union or staff association
Other (please describe)
Question 1
Do you agree that the Further Education Teachers’ Qualifications (England) Regulations 2007
should be revoked from 1 September 2012?
Yes
No
Not sure
Comments:
Teachers need to be trained in order to meet the vast range of needs of learners in the FE and
skills sector. Evidence often quoted by ministers suggests that the key determining factor in the
quality of education people receive is the quality of teaching. Subject knowledge on its own is
not sufficient. Teachers need a combination of practical training and relevant theory, as well as
experience, if they are to master the teaching skills they will need to meet the needs of
learners. Although preparatory training fulfils an important role, teachers will also need robust
training that is practice based and academically sound.
There would be a huge educational and personal risk in placing unqualified teachers in classes
of very challenging learners. The potential for staff turnover and learner underachievement
cannot be overstated.
It would be inequitable to allow 14-19 year olds in colleges to be taught by unqualified staff
while their peers in schools have the benefit of properly trained teachers. The educational
disadvantages experienced by many 14-19 year olds in college will continue, and increase, if
they are taught by unqualified staff. Although many colleges will continue to ensure that
teachers are properly trained, evidence from OFSTED and elsewhere suggests that many will
not (this is acknowledged in Lord Lingfield’s report when he describes employer engagement in
training as being ‘patchy’).
There has in recent years been a real commitment across the education sector to move
towards parity of esteem between teaching in schools and further education colleges. This was
reflected in a closer alignment between the qualifications and standards expected of teachers
in each sector. This will be undone if teaching qualifications in FE become optional.
Regulations controlling qualification requirements should be based on the needs of learners,
and not on the desire of some employers to have near total discretion on who should be
allowed to teach their learners or what experience and qualifications they need to have. The
quality of education people receive should be based on their needs. It is not true that colleges
will ‘stand or fall’ on the basis of their results, and the quality of teaching they provide. A pure
market does not operate in the FE sector and many learners have only a limited choice about
where to go. Colleges with good results would, in all likelihood, do even better with properly
trained teachers, while those colleges facing more challenging circumstances might be just
those who could be most tempted to save money by training teachers on the cheap (if at all).
Teaching qualifications provide teachers with both practical, analytical and research skills. For
many teachers in the sector their teaching qualification will be their first experience of education
at a higher level. This experience is essential if they are going to be expected to teach
vocational or other subjects at Foundation Degree Level or above. Teaching qualifications can
also provide platform on which to progress to yet higher forms of study. Qualifications act as
research based initiatives into the FE sector. They also provide teachers with essential skills and
knowledge in key areas such as: literacy (inc. phonics); numeracy, behaviour management; and
equality & diversity.
Evidence, not least from BIS, points to the success of the requirement that teachers be
properly qualified. We do agree that changes should be made to the teaching qualifications and
that improvements are needed in some areas. This can however be done without removing the
requirement itself, which would take professional status away from teachers in FE, lower their
status (and that of their learners) and damage the education of often very vulnerable people.
Question 2
Do you agree that the Further Education Teachers’ Continuing Professional Development and
Registration (England) Regulations 2007 should be revoked from 1 September 2012?
Yes
No
Not sure
Comments:
It is a requirement of most professions that its practioners keep themselves abreast of latest
developments and research findings within their chosen field. For FE teachers, as ‘dual
professionals’ this might cover their subject knowledge or pedagogic practice (or a
combination of the two). Some form of CPD requirement ought therefore to remain.
The nature of the CPD undertaken by a particular teacher should be the subject of discussion
between the individual themselves and their employer. Although a requirement for CPD should
remain, its content and form should not be a matter of prescription. CPD can include both
certificated and informal professional development and address subject knowledge, subject
pedagogy and teaching & learning. It might also involve opportunities for experiencing broad
aspects of FE provision through seconded placements within the college or associated
contractors. The undertaking of CPD should inform the appraisal process and be supported by
employers as a condition of funding.
QTLS status might in future be awarded as professional recognition on achievement of an
approved teaching qualification (as QTS is for school teachers). QTLS status could be
awarded on the successful completion of an approved programme of training by the
appropriate professional body on the recommendation of the training provider. The appropriate
body might then issue guidelines or requirements relating to induction, early professional
development and ongoing professional development. This would allow implementation of the
Wolf reforms.
Question 3
Do you think there will be any unintended consequences or implications by revoking these
regulations?
Yes
No
Comments:
The consequences would be:

Poorer learner outcomes

Lower status for teachers
Not sure

Abandonment of progress towards parity of esteem with schools and transferability across
sectors

Closure of established and good quality ITE programmes, and replacement by cheaper
‘quick-fix’ options

Lower quality delivery of HE in FE

Poorer skills set going into industry

Damage to quality of apprenticeships

Reduced scope for teachers themselves to progress their education

Higher staff turnover and increase in retention difficulties
Question 4
What do you consider to be the minimum level of qualification needed to teach in Further
Education?
Comments:
We think that all teachers in the sector should be expected to achieve a fully accredited
teaching qualification at Level 5 or above. This could however be delivered in the staged
approach set out below, with it being a condition of funding, and an OFSTED requirement,
that all unqualified teachers in the sector are working towards at least the 60 credit first stage
of the model outlined below.
Suggested regulatory and non-regulatory qualification framework for post compulsory
trainee teachers
One year part time compulsory Undergraduate and Post Graduate route
Integrated Learning and Skills
Professional Induction Award
60 credit award (a minimum of 20
credits to be at level 5NQF)
Providers to establish the structure
of the credits to meet employer and
provider need
Suggested Content: teaching and
learning strategies, curriculum design,
resources (electronic and all other),
assessment, managing learners,
reflective practice, personal and learner
evaluation, functional skill development,
incl. minimum core of literacy, numeracy
and ICT subject specific pedagogy
Progression and professional development
opportunities at this point to include
1. Undergraduate to full Certificate in
Education
2. Post graduate to full PGCE
3. Undergraduate and post graduate to
other subject specific certificated or noncertificated CPD and professional
development activity to be agreed with
employer and meet professional and
employer needs
4. Subject specialist advanced awards in
Literacy, Numeracy and ESOL
Achievement of above 60 credits provides a sufficient skill base to teach across the wider sector
and meet a range of individual learners needs. The induction award does not carry QTS status
and is insufficient for employment in the secondary sector as suggested by Alison Wolf (2011)
Non-compulsory continuation route for part time undergraduate and post graduate
trainees.
Content to focus on broader issues may include: Action Research, managing diversity, equality
in practice, contemporary issues and policy in post compulsory education, reflective practice and
professional development activity
Target Awards
Certificate in Education: 60
additional credits
NQF level 5
PGCE: 60 additional credits
20 credits at NQF 6 plus 40 credits
at NQF 7 (Master level)
Progression and professional development
opportunities at this point to include
1. Undergraduate to certificated FD & BA
qualifications
2. Post Graduate to PG Diploma, MA and
Professional Doctorate Awards
3. Undergraduate and post graduate to non
certificated professional development
activity
Both of the above awards achieved
through an additional year of
training.
Compulsory continuation route for part time Literacy, ESOL and Numeracy teachers, to
include subject specialist content and pedagogy
Target Awards
Certificate in Education or PGCE or
stand alone Diploma in teaching one
of:
Literacy
ESOL
Literacy and ESOL
Numeracy
60 additional credits at NQF 5 or NQF
6&7 in subject specialism
Achievement of all 120credits for both the compulsory and non compulsory part time awards
carries QTS status so is sufficient for employment in the secondary sector as suggested by
Alison Wolf (2011)
Rationale for the framework
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FE colleges, WBL providers and Training Organisations will be able to ‘qualify staff’ using
a range of providers (Awarding Bodies and HEI provision) to the same framework
The framework aligns to the HEA qualification framework where lecturers have to achieve
the 60 credits of a PG Certificate mapped to the HEA professional standards in order to
gain SD2 status with the HEA and be recognised as qualified lectures for the sector
The framework aligns with the qualification structures in Scotland where the 60 credit one
year initial award has demonstrated real success with all stakeholders. There is therefore
a consistency of structure and potential for recognition and transferability of Scottish and
English awards by employers.
This model retains the requirement for Literacy, ESOL and Numeracy teachers to have
subject specialist training, as recognised in the interim Lingfield report. It recognises that
these teachers need to develop their subject knowledge as well as teaching skills, and
that this takes more time. The two phases of this training may also be sequenced
differently, with specialist followed by generic, or fully integrated throughout.
Seamless progression across the framework from different providers will be possible
The PGCE module levels comply with HEI regulations for post graduate certification
Wolf’s recommendation that fully qualified teachers in FE can gain employment in the
secondary sector on equal footing to teachers holding QTS could be maintained by this
framework once the full 120 credits are achieved.
The full 120 credits align to the PGCE awards for the compulsory schools sector
A recommendation for the time frame for the achievement of the induction award could be
made.
There would be no recommendation or time frame for continuation to the full awards of
Certificate in Education and PGCE except those created by the provider
Achieved Undergraduate and post graduate credit would allow progression to a range of
undergraduate and post graduate awards offered through HEI’s and some Awarding
Bodies
A 60 credit compulsory award allows trainee teachers to apply to the student loan
company for means tested grants and loans to support their learning, this reduces the
cost to employers.
Awarding Bodies currently have a fragmented qualification framework that can still exist
within the larger credit framework suggested. Smaller chunks of the framework can still
be made available in WB Learning provision for continuous short training days to up skill
the workforce
HEI's have a range of credit structures of 10, 15, 20 and 30 credit modules but all can be
accommodated within the 60 credit structure
Question 5
What do you consider to be the most effective means of maintaining a professionalised
workforce?
Comments:
This would be facilitated by:

Ensuring minimum standards and levels of qualification (the coverage and content of
which would be owned by the profession rather than by government)

Access to communities of practice

Remission for mentoring

Adherence to a Code of practice agreed by the profession

Existence of a professional body (voluntary or otherwise)

Entitlement to (and obligation to access) relevant CPD relating to both teaching and
subject knowledge

Recognition that the ‘profession’ relates to teachers and not to the collective of employers

An appropriate balance between professional autonomy and accountability

Advanced practitioner support for teachers both new and qualified and development to
become an advanced practitioner
Question 6
Do you consider that any minimum expectations for training and qualifications should be
stipulated as a condition of public funding?
Yes
No
Not sure
Comments:
Ofsted should inspect this as part of the college and WBL provider inspection
Employers should clearly state the qualification requirements of staff within their College
contracts
Funding for teaching should only be allocated to colleges that employ qualified staff
Do you have any other comments that might aid the consultation process as a whole?
Please use this space for any general comments that you may have, comments on the layout
of this consultation would also be welcomed.
Thank you for your views on this consultation and for taking the time to let us have your views.
We do not intend to acknowledge receipt of individual responses unless you tick the box below.
Please acknowledge this reply
At BIS we carry out our research on many different topics and consultations. As your views are
valuable to us, would you be happy for us to contact you from time to time either for research
purposes or to send through consultation documents?
Yes
No
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