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