Skill: National Bureau for Students with Disabilities
Response to Investing in Skills: Taking Forward the
Skills Strategy
Learning and Skills Council December 2004
Introduction
Skill is a national voluntary organisation with the aim of promoting
opportunities in post 16 learning for learners with learning difficulties and/or
disabilities. Skill is responding the this consultation with reference to learners
with learning difficulties and/or disabilities aged 16 – 99 and the contribution
adult learning makes to their lives.
Skill’s initial response is to be concerned about the title of the document as it
implies the only reason for adult education is to develop specific skills, rather
than a person centred approach which is so essential for many learners with
learning difficulties and disabilities. Skill is concerned that the tone of the
document implies a desire to fit non-accredited learning into a skills for life
strategy rather than starting from learners and their particular needs.
Section 1
Q1
Are these the right principles to apply?
Yes Skill broadly supports these principles. Under the principle of Fairness
we would like any guidance on this to take account of learners who have
acquired disabilities for whom non-accredited learning plays an important part
in recovery and taking new directions in learning. These learners may have
had to give up their original careers, for which they were qualified, and will be
economically disadvantaged. It would be unfair to expect them to pay fees
just on the basis that they were now pursuing learning at a lower level. We
recommend that the LSC includes the flexibility in guidance to providers to
take account of such individual circumstances.
Q2
Are there other principles you would like to propose
We feel there should be a principle centred on equal opportunities to reflect
the duties in the Learning and Skills Act 2000 and commitments in the LSC
Equality and Diversity strategy. This area of education plays a crucial role in
redressing inequalities of opportunity.
Section 2 Describing Adult Learning
Q3
Are the definitions of learning for personal and community development
and first steps clear and comprehensive?
Skill agrees broadly with the Learning Category Descriptors.
However, not all adults with disabilities will engage in learning through the
category of Skills for Independent living, there may be learners with
disabilities who would appropriately enter First Steps learning with the aim of
progression under paragraph 2.8. Some of these learners may have a
qualification equivalent to a full level 2 or above but because of an acquired
disability or deteriorating condition can no longer usefully use it and need to
progress into a different area. For example someone with an acquired brain
injury may have a professional qualification but may be no longer be able to
work in that profession. They may need encouragement to move into a new
field and then to go on to appropriate essential NVQs. If this move is related
to their disability, providers should have flexibility to enrol them on First Steps
courses. For example, an architect with acquired brain injury being
encouraged by IAG provider to look at health and social care as a new
pathway. He/she needs to progress to a level 2 NVQ before being eligible for
employment.
There is a danger that the programme descriptions will lead to stereotyping
and providers may think that everyone with a disability should be regarded
as needing Skills for independent living.
Q4
Are there additional activities that should be included?
Q5
Would these definitions assist in planning and funding discussions
Yes /No
Q6
What issues will arise when distinguishing between learning for
personal and community development and first steps learning on the basis of
provider intention in setting up the course?
Communication skills and independent living skills may be best delivered in a
varied curriculum and excellent progress will can be made through a
programme in which for example, sport or art, is the major element. There is a
danger that staff may be told the provider will get more money if its
designated a basic skills or independent living course. This raises the issue
of how to deal with courses that cross the two areas of learning.
Programmes for learners with all kinds of learning difficulties may not be easy
to place. Independent living skills needs will vary according to the student. In
Skill’s Aasha project, learners with learning difficulties from a South Asian
background told us that independence courses in colleges often focused on
areas of life which seemed irrelevant and intrusive to people from other
cultures.
For example, one young man who had been on a one-year life skills course
said ‘(it showed) you how to wash your clothes, how to cross the road,. I was
so ashamed I couldn’t tell my cousin what course I was doing because it was
a low course’.
Another example is a college which has stopped running independent and life
skills and instead adopted the Valuing People white paper principles. After
consulting with learners about what they most needed they received
responses including a short course on interviewing skills to contribute to the
Mencap newspaper, and self advocacy skills. Where would these come in
the proposed arrangements? It is important that learners are not forced into a
box but that this kind of creativity is provided for.
Q7
What is the best way of handling those programmes which are offered
by providers on the basis that they are primarily studied for recreational
reasons, but which do lead to external accreditation?
Q8 Is the transfer of out of scope activity to LID the best approach if not ,
what alternative approach might be adopted
Some provision funded via voluntary organisations etc has been incredibly
important and innovative. For example the Step and Roll programme which
was highly commended in the DfES STAR awards in October. These
programmes often include ESF funding as well. Short term funding is very
detrimental to the embedding of good creative learning programmes, and ESF
funding is likely to run out for most projects now. LID funding would need to
address issues of continuity and programmes should be monitored to see
where they can move into mainstream provision.
The Valuing People white paper highlighted the need for agencies to work
together and that options should be available that allow joint funding between
education and other agencies. In Skill’s experience is that joint funded
projects are the way forward and far more likely to be successful than trying to
get each agency to put money aside.
Skill’s Enhancing Quality of Life Project, on the needs of people with
profound and complex learning difficulties, included the recommendation that
provision be jointly funded between health, social services and education to
develop a holistic approach.
Funding Approach
Para 2.22
Yes but we have concerns about the implied means test , providers have to
decide who is able to pay, guidelines on which benefits should be included in
this means test will be essential, or disabled learners receiving benefits will
be disadvantaged. Benefits which fund the extra costs of having a disability
should not be taken into account.
Section 3 Funding First Steps Learning
Q9 Do you agree with the proposed approach to funding non accredited
First steps provision?
Skill welcomes the provision of Additional Learning Support to all first steps
learning as they operate in the FE funding approach, in para 4.11
Q10 What might be the difficulties in extending the FE approach to first
steps provision currently funded through the ACL funding stream?
There is a danger that providers will distort programmes to meet funding
criteria. This has happed already, when staff have been told they must label a
programme basic skills to get the best funding option.
Q11
Are there ways in which the approach could be simplified?
Q12 What factors should the LSC consider when developing a more
equitable allocation approach for first steps learning?
The LSC remit letter emphasises the development of personalised learning,
therefore the funding approach and additional learning support must reflect
this priority.
The LSC has duties under the Learning and Skills Section 13 and 14 and
arrangements need to be tested against these duties. Also under the
Disability Discrimination Act it would be difficult for providers to justify offering
different levels of support to disabled people, based on the level of the course.
Differentiation in funding is unlikely to be seen as reasonable on that basis.
Q13 Is the proposed funding regime for first steps learning appropriate?
Q14 What issues might arise through funding all first steps provision
through the FE approach?
Q15 What factors should the LSC use when allocating funding for first steps
provision?
As we have already stated the LSC needs to build in flexibility Some learners
may have support needs related to hidden disabilities, mental health
difficulties or medical conditions. These needs not always easily met through
additional learning support but will require other support, in particular flexibility
of delivery and the opportunity to extend the timescale of their learning
programme. They may experience periods when they are unable to attend, or
need to learn at home. It is important that the funding allows for this flexibility
and at times appropriate outreach work.
Section 4 Funding Learning for Personal and Community Development
Q16 What are the issues that would arise under the proposed funding
approach to learning for personal and community development
Q17
How might the approach be refined or simplified?
Q18 What option do you favour for additional learning support
arrangements?
None of the options is will fully meet the needs of learners with learning
difficulties and/or disabilities.
The LSCs preferred option, option three, does not reflect the findings of the
LSDA report, where an explicit statement of entitlement of ACL learners to
ALS was welcomed by respondents Currently there is an enormous variation
in ALS provision on non accredited courses. Many ACL providers are doing
excellent work. Others give this a low priority. This inequality must be rectified.
This can only be done with earmarked funding. The Introduction of Additional
Learning Support in FE has proved enormously beneficial for disabled
learners. The initial consultations conducted by LSDA show that staff
unanimously wanted it maintained.
Support needs for disabled learners are individual, not geographic, therefore
option 2 is inappropriate. It is not the same as looking at local needs to tackle
disadvantage.
All providers need to be able to fulfil their legal requirements under the DDA
and the LSC needs to meet those under section 13 and 14 of the Learning
and Skills Act 2000. Without identifying funding option three is unlikely to
deliver this.
Q19 What additional factors might the LSC consider in respect of weighting
the distribution of funds for ALS?
The proposed option three has no safeguards in it for learners with high
support needs. Under the proposal, providers might think it is acceptable to
turn away a deaf learner on the grounds that its too expensive to support their
communications needs.
The LSC champions cannot do all this unless they are given specific space in
their work programmes. Their roles as champions are not full time, this work
is in addition to their current workload for many. They will be hard pressed to
do the monitoring of ALS in FE. There has been no discussion of their role
being extended in this way. Further discussion of the LSCs commitment to
monitoring resources is therefore needed.
Skill: National Bureau for Students with Disabilities
December 2004