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:
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 bodyCentral 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 Not sure
Comments:
The consequences would be:
· Poorer learner outcomes
· Lower status for teachers
· 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 Award60 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 non-certificated 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 AwardsCertificate 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)
Both of the above awards achieved through an additional year of training. / 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
Compulsory continuation route for part time Literacy, ESOL and Numeracy teachers, to include subject specialist content and pedagogy
Target AwardsCertificate 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
§ 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