John Wheatley College Post-16 Reform College Regionalisation College Response

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Introduction John Wheatley College welcomes the opportunity to comment on the proposals by the Scottish Government and Scottish Funding Council for the implementation of Putting Learners at the Centre. The College also welcomes the opportunity to contribute to shaping proposals which will determine the regions, structures within regions, and the funding methodology for the College Sector. In drafting this response the College has sought to make comment within each section of the consultation paper but has on occasion found the format of the questions unhelpful and therefore has provided a response which reflects its views. The College welcomes that the Post-16 Reform College Regionalisation document reflects a number of the comments which it has previously made as part of the consultation exercise linked to Putting Learners at the Centre. The emphasis placed on regions responding to local needs is endorsed by the College as it has long championed an approach which has focused on tailoring its provision to the requirements of its local labour market and the communities which it serves based on comprehensive consultation with key stakeholders including Glasgow City Council and local Community Planning Partnership Boards within effective partnership structures. The College broadly supports approaches which enable resources to be redirected to front-line provision in those communities which benefit most from participation in Further Education programmes. Furthermore, the College welcomes the opportunity to contribute to the development of a funding methodology which will provide efficient and effective Further Education provision for all Scotlands communities in support of the Governments key priorities. The College is content to expand on the contents of this response if required to do so. The College agrees to all or part of this response being placed in the public domain. Defining the Regions The College recognises the attraction of a regional administrative structure for post16 learning. It is the view of the College that if regionalisation is to be effective in promoting collaboration for all providers of post-16 learning and in affording opportunities to realise savings over a period of time that the regions should be based on existing local authority boundaries or coherent groups of local authority boundaries.
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The proposals for regions and the colleges within those regions are therefore in the main appropriate. However, the College would opine that it would be more appropriate for Perth College to be located in the Tayside Region than the Highlands and Islands Region. Furthermore, it is the view of the College that the Kilwinning Campus of James Watt College should be included in the Ayrshire Region. The College endorses the proposal for the Glasgow region in terms of the local authority areas as identified. The College does not support a model which includes one regional college for Glasgow and it contends such a body would not be sufficiently responsive to meet the diverse needs of the communities within the region while pursuing its role for the metropolitan Glasgow area (in particular the specific needs of the most deprived and more peripheral parts of the City). It welcomes and endorses the proposal for three separate fundable bodies of North, South and City of Glasgow College within the Glasgow Region. The College contends that this model is the most appropriate in order to meet the needs of communities within Glasgow while also supporting the needs of the Glasgow Metropolitan conurbation. The College opines that as the North East of Glasgow contains the greatest concentration of the 20% most deprived datazones within the City that these communities require an approach to Further Education provision which is focussed on inclusion linked to the needs of the labour market. Such an approach must be based on effective partnership working with key stakeholders including Glasgow City Council, other local Community Planning Partners, employers and local residents. This approach is necessary in order to ensure that residents acquire the essential and vocational skills required for employment or further study. John Wheatley College therefore contends that the communities in the North and East of the City would be best served in the new regional framework by a College for the communities predominantly served at present by North Glasgow College and John Wheatley College. It is of the opinion that such an institution would be sufficiently responsive to Government initiatives, local needs and Community Planning Priorities whilst being large enough to make an appropriate and comprehensive curriculum offer while operating efficiently. In the first instance, the College contends that a merger between North Glasgow College and John Wheatley College (and other interested institutions with a locus in the North of Glasgow should this be appropriate) would provide an opportunity to deliver the comprehensive curriculum envisaged by the Government in its proposed reforms for Post-16 learning. The College would therefore seek to explore with North Glasgow College how best such a merger could be achieved following the final defining of regions in January 2012. Such a single college serving North East Glasgow would in our view be best placed to work strategically within Glasgows community planning arrangements to the benefit of the residents of North East Glasgow. Equally, the College would also opine that a South Glasgow fundable body should have the opportunity to develop the curriculum which best serves its communities. The College is content with the proposals to take a national approach to: Newbattle Abbey College;
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Sabhal Mor Ostaig; and the land-based colleges.

It is the view of the College that travel to study is the most appropriate proxy for taking account of cross region student flow. The College contends that the Scottish Government should identify a limited number of key national specialisms and require the Funding Council to negotiate with the regions as to where such provision should be located in order to produce the maximum benefit from the resources required to support such specialist provision. Estimating Regional Need The College endorses the proposed indicators of regional need contained within the consultation document. In addition, it contends that there is a need for an indicator which reflects the extent of the poverty within a region in order that resources are available to support the Governments agenda for a Fairer, Healthier, Smarter and Wealthier Scotland. Therefore, it would propose an additional indicator to take account of the number of residents in a region who live in the 20% most deprived datazones. Furthermore, the College would seek clarification as to whether weightings would be placed on these indicators in order to arrive at an aggregate approximation of regional need. The importance of recognising the need to support those with no or low qualifications in a region is most welcome. It is the view of the College that only by enabling those in this cohort to access appropriate education and training, no matter where in post16 learning structures, will a Fairer, Healthier, Smarter and Wealthier Scotland be created. It is the view of the College that resources should be directed at those communities which have the largest number of long term unemployed and where historic structural unemployment requires to be addressed. It recognises the need to support communities where unemployment has recently risen but opines that it is important to consider underlying trends in order to ensure that the Scottish Governments ambitions for Post-16 Learning, economic development, and longer term economic sustainability are realised. In order to meet the role envisaged by the Scottish Government for colleges in the new Post-16 framework it is necessary to recognise that financial stability is a factor in ensuring that the needs of communities and employers are met. In addition, in order to ensure that learners acquire the skills required for either employment or further study, there has to be confidence that resources will be available across a realistic timeframe. The College recognises that the Scottish Funding Council will require to systematically rebalance resource allocations to regions however it would contend that these allocations should be made for a three year period with a transition phase to move to a revised resource allocation of a further year. This approach would have least impact on the learner experience. Re-allocation on an annual basis would not provide the stability required to provide high quality learning and teaching and deliver positive outcomes.

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Furthermore, the College seeks further discussion and clarification with regard to what would constitute the trigger points for the re-allocation of resources. There is a need to establish agreed parameters to assist regions to plan strategically provision within their area and to take cognisance of potential changes in ways which would minimise the impact on learners. Courses The College endorses the policy direction outlined in Putting Learners at the Centre to provide learners with skills for study, life and work. However, the College would wish to highlight that for learners with a previously poor educational experience, or those who have experienced considerable challenge in their life, the learning journey is non-linear and may require a variety of appropriately structured interventions. Recognition of this reality is not apparent in the proposals for the funding of courses. The acknowledgement of the key role played by Non Recognised Qualifications (NRQs) in providing those furthest from the labour market with the opportunity to reengage with learning is welcomed. The College would contend that in order to be eligible for funding, NRQ provision should be benchmarked within the Scottish Credit and Qualifications Framework (SCQF) if such provision is not accredited by an awarding body.

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The proposals to simplify funding arrangements are long overdue, though the College would wish to see further more detailed discussion on how the methodology is to be simplified supported by detailed modelling of the proposed changes. In addition, the College would welcome an opportunity to evaluate the outcome of the associated Equality Impact Assessments which were undertaken as part of the modelling. While welcoming the proposal that subject-based payments should reflect the costs of providing that subject in a large efficient college it is difficult to comment on the effectiveness of this approach as the size of a large college is not defined. Furthermore, it is the view of the College that the efficiency of delivering programmes should not be based solely on the number of WSUM delivered by FTE teaching staff. Rather it should reflect the cost of all the inputs deployed to support the learner. In this way a more realistic assessment of costs may be identified.

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The College is disappointed that here is no element within the base funding allocation which reflects the additional resources required to support learners from the 20% most deprived datazones. It is the view of the College that the challenges faced by these learners should be recognised within the core funding methodology not as an additional element which may incur both real and opportunity costs to evidence. It is the view of the College that the unintended consequence of this omission will make the achievement of the Governments priority of creating a Fairer Scotland more challenging. The College recognises that the challenge faced by rural areas requires to be addressed through appropriate resourcing, however, it would contend that those experiencing urban deprivation also should have access to resources which enable
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them to overcome barriers to learning which are of a similar if not greater scale to those faced by rural communities. 4.8 The allocation of an element within the core funding to support the costs of teaching learners with additional needs, is, in the view of the College inappropriate. The College opines that these funds should be linked directly to individual learners and special programmes in order that appropriate tailored support is provided to meet specific need. There is an established and auditable process for the recording of such support. This approach should be continued. In addition, there is the risk that if the proposed approach was adopted that colleges who make limited provision for learners with additional needs will receive funding at the expense of others where it may be more effectively deployed to support learners who require such support. Furthermore, removing the subject based weighting for current Dominant Programme Group 18 programme is of considerable disadvantage to those colleges who have sought to ensure that learners in this cohort have access to vocational and essential skills courses which will lead to employment opportunities. Removal of the subject element may have the unintended consequence of reducing learner opportunity for this cohort. In addition, it may lead to colleges being unable to make the necessary adjustments for learners as required by legislation. The College is also concerned that the failure to recognise that those regions, who experience greater demand for DPG-18 provision as a consequence of their operational environment, may be unnecessarily disadvantaged by this approach. In addition, the College would seek clarification as to whether an Equality Impact Assessment has been conducted with regard to the proposal to remove the DPG-18 subject weighting. If such an assessment has been undertaken the College would welcome the opportunity to consider its findings. As stated above the College contends that an element which recognises the challenges faced by learners experiencing urban deprivation should form part of the core funding methodology rather than adopting an individual deficit model approach. It is the view of the College that student support funding should be targeted toward those learners who live in the 20% most deprived SIMD datazones. In these circumstances it will be necessary to re-allocate student support funding to the proposed regions on this basis and not on previous historical allocations. The College would urge the Funding Council to distribute all the available student support funding at the commencement of the academic year and not to retain a portion for disbursement at a later date in order to enable colleges to offer places to the maximum number of learners. The College is content with the proposals for the disbursement of Capital funding. However, it would contend that regional arrangements should include expectation that the quality of the College estate and infrastructure is maintained over time, in order to prevent a gradual deterioration in the quality of the college sector estate. The College welcomes that the role of Non Recognised Qualifications (NRQ) has been acknowledged as a means of engaging with unconfident learners and meeting the requirements of learners with additional support needs where there are no appropriate SQA or other qualifications. However, the College would wish to see that this form of provision is benchmarked using the SCQF in order to be eligible for funding.
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The approach outlined in the paper which seeks to allocate resources for NRQ provision is broadly appropriate, but could perhaps include making specific reference to meeting the needs of learners with additional support needs. Retention The College notes with interest that the recently published HMIe overview on the College Sector commends the steps which have been taken to improve retention. The College welcomes the proposal to improve the quality of retention data by recording positive reasons for learners leaving programmes such as employment. However, it would also wish to see the acknowledgement of positive actions taken by colleges to adjust programmes to take account of changes in learners circumstances. It is the view of the College that if the 25% means of calculating eligibility for funding is inappropriate, then another arbitrary figure of 50% is equally inappropriate. In these circumstances the College would urge the Council to move to real-time funding linked to the delivery of learning and teaching and supported by attendance data. The removal of the entry costs elements of the funding methodology is, in the view of the College, likely to have the unintended consequence of having an adverse impact on retention. This funding has enabled a number of colleges to provide comprehensive pre-entry guidance as part of a retention strategy and to ensure compliance with Equalities legislation. This may not now be possible. The College has never sought to limit access to learning opportunities as part of its retention strategy, however, it is concerned that the approach contained in the consultation paper may result in a number of colleges only selecting the learners most likely to succeed rather than those who would benefit from participation in Post16 learning. Furthermore, the College would have wished to see more detailed comment on the role to be played by SDS in tracking and providing data on learners who leave college programmes irrespective of when they leave. In addition, it would wish to see the role of SDS in tracking extended to all age groups (in line with their role as an all age guidance provider as well as their position within data hub arrangements). It is not clear as to how the proposal to replace WSUM with FTE as a proxy for activity will simplify matters as the College opines both require complex definitions as to how the final figure is produced. However, the College is concerned that 16 credits is considered a sufficient period of learning for non-advanced full-time programmes. It is the view of the College that 18 credits should be required in all non-advanced full-time programmes with 15 credits being required for advanced (HN) programmes. It would be helpful if the Funding Council could inform colleges of the outcome of any discussions which it has held with employers with regard to the reduction in the number of credits contained within a full-time non-advanced programme.
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Regional Structures and Accountability The College believes that the proposed regional structures contained in the paper are appropriate. It also welcomes that colleges within the regions are encouraged to identify structures which are the most appropriate for their particular operational environment. Where mergers are being considered it is the view of the College that these should primarily focus on the benefits for the learner and the communities, employers and other key stakeholders which the colleges serve. In addition, mergers should provide realistic and achievable savings in the medium term (5 10 years) which will enable resources to be re-allocated to front line services for learners. Where appropriate colleges should use their reserves to facilitate mergers. It is the view of the College that loans to support regions facilitate merger would be inappropriate. The College opines that Outcome Agreements should ensure effective, efficient and comprehensive Further Education provision for the communities served by the region at best value to the public purse. Regional Outcome Agreements should be strategic and should reflect the needs of that region. These Agreements should contain agreed SMART targets based on readily obtainable Performance Indicator data, together with a series of longer term objectives linked to the key policies of the Scottish Government, the needs of the regional labour market and the priorities of the appropriate local authority and local Community Planning Partnership Board. Furthermore, the College would wish to see Outcome Agreements developed which reflect the public value contribution made by colleges to wider Government priorities such as a Fairer Scotland and other priorities established by Community Planning Partnership in areas such as the creation of safer communities. Governing bodies should be required by statute to consult with the appropriate local authority, local employer organisations, appropriate national skills bodies, Community Planning Partnerships and the communities which they serve in order to inform the strategic planning process and the development of Outcome Agreements which reflect the needs of these key stakeholders. The self-evaluation approach to demonstrate progress towards meeting the targets contained in the Outcome Agreement is welcomed by the College as this will enable fundable bodies to comply with the Equality Act duty to embed reporting within other key documents. Key stakeholders should also be engaged in the evaluation of the progress made against the targets within the Outcome Agreement. The College would seek assurance that the review of progress against meeting targets with SFC is not overly bureaucratic and will be based on evidence which is readily available to the organisations involved.

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Phasing of Reform The College acknowledges that the pace of reform is challenging but achievable. It welcomes the flexibility contained within the timetable to take cognisance of regional differences and the need to ensure the quality of the learning experience during this period of transition. The College welcomes the transitional arrangements outlined in the paper but would have wished more information through detailed modelling of the proposed changes, in order to enable it to make more meaningful comment. In addition, the College opines that the Scottish Funding Council should consider how it could best support Boards of Management during the process of merger and the transition to regional forms of governance. Finally, the College welcomes the proposal to provide colleges with an indicative letter of grant in December 2011 as this will assist in the planning process for session 2012/13.

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John Wheatley College