The Government is now consulting on a National Skills Strategy and Delivery Plan with the aim being to publish a White Paper in June. According to the Government 'the Strategy will set a wide-ranging agenda for raising skill levels amongst young people and adults, working closely with employers to ensure their skill needs are met'. The commitment to publish a Skills Strategy was announced as part of the Comprehensive Spending Review (CSR) in July 2002. In addition, one of the outcomes of CSR 2002 was a commitment that the Government should undertake a Review of the Funding of Adult Learning.

The consultation process includes three documents published at the end of March, two by the Department for Education and Skills (DfES) and one by the Learning and Skills Council (LSC). They are as follows:
Delivering a National Skills Strategy and Delivery Plan: Progress Report (DfES)
Delivering a National Skills Strategy and Delivery Plan: Underlying Evidence (DfES)
Funding Adult Learning: Technical Document (LSC)
The DfES 'Progress Report' is the key consultation document. It summarises progress to date on developing the Skills Strategy and sets out the Government’s emerging thinking on the main elements. However, the 'Underlying Evidence' report is also significant because as well as drawing together the evidence supporting the need for a new approach, it discusses in some detail the various mechanisms the Government could use to drive forward the Skills Strategy (e.g. including the possible role of statutory entitlement to paid time off). The LSC document is also a consultation document in its own right but is largely aimed at key LSC stakeholders (e.g. education and training providers) and focuses on the issues raised by the Review of the Funding of Adult Learning. However, it does flesh out the Government’s latest thinking on the 'priority groups' that may be in line for an 'entitlement' to public funding in order to reach a certain skill level. The Guild is presenting a single submission to the Skills Strategy consultation process and will address issues raised in all three documents.
OVERVIEW OF GUILDS RESPONSE The Guild positively welcomes the commitment to publish a National Skills Strategy and Delivery Plan and to achieve a much more coordinated approach to the delivery of skills provision, especially through the work-based route. In addition, it is especially welcome that the proposed Skills Strategy builds on previous recommendations by the National Skills Task Force and the CBI/TUC Productivity Initiative to focus on upskilling adults without a level 2 qualification and young people without a level 3 qualification. The Guild also specifically welcomes the commitment that the Government should lead by example with respect to its own workforce. Positive action of this kind in the public sector will highlight to other employers what can be achieved when there is a real commitment to workforce development by both employers and unions. However, whilst welcoming the broad tenor of the Skills Strategy, there are some key issues that the Guild believe are likely to limit the potential of the strategy in achieving a skills revolution. The key issues that we have highlighted in the submission are as follows:
The role of trade unions/associations is seriously understated in the consultation documents. Unions and Associations need to be recognised as key stakeholders in the skills policy framework. There should be a robust partnership approach adopted at national, local/regional and sectoral levels of the skills policy framework as well as in the workplace;
There are limitations in the proposals for targeting public funds on priority groups. There must be a commitment to paid time off for training to create new 'skill entitlements' for adults without level 2 and young people without level 3;
With regard to sectoral arrangements, the Government must reaffirm and strengthen its commitment to introduce statutory levies where it can be demonstrated that sectors are not meeting targets or training obligations. It should also extend the model of ‘licences to practice’;
There is a clear failure to acknowledge collective rights to training. Negotiating rights for employees over training should be strengthened under collective bargaining arrangements, and training and workforce development included when the Information and Consultation Directive is transposed into law;
Equalities issues are not mentioned in the consultation documents yet must be a central tenet of the Skills Strategy;
The principle of NVQ levels 2/3 being platforms for achieving higher level qualifications is welcome. However, there should be clear pathways from lower to higher level skills and synergy between the Skills Strategy and the DTI’s Innovation Review in this regard; and
Individual Learning Accounts should be re-introduced. However, it is imperative that the new scheme is not too narrow and that the role of unions in providing support to learners is recognised and built into the new ILA model.
NEW 'SKILLS PARTNERSHIPS'
The Need for a new Partnership Approach The consultation documents give a partial and misleading view of the trade union role in relation to learning and skills in the workplace with reference to trade union activity confined to a few references to Union Learning Representatives (ULRs). While the increasingly important intermediary role played by ULRs in encouraging employees to engage in learning is partly acknowledged, the consultation documents fail to capture the 'bigger picture' of union and trade association involvement in training and development issues.
The role that trade unions play in boosting the provision and take-up of learning opportunities through a range of other activities, especially collective bargaining, is completely overlooked. In addition, there is little debate on the need for specific measures to develop a partnership between Government, employers, trade associations and unions at all levels in order to implement and drive forward the National Skills Strategy. The consultation documents quite rightly highlight the serious 'skills deficit' in the UK and the detrimental impact this has on both the social fabric and economic performance. On the latter point, we know from recent academic research that around a fifth of the productivity gap with Germany is explained by the difference in skill levels (Britain’s Relative Productivity Performance, NIESR, March 2002). This research also shows that only 20 per cent of the German workforce have low skills compared to 57 per cent of the UK workforce and that 65 per cent of German workers have intermediate qualifications compared to only 28 per cent of UK employees.
This clearly lends support to the Government’s strategy to improve the quality, and expand take-up, of the 'vocational offer' so that we are more in line with the situation in countries like Germany. However, it is imperative that the UK Government recognises that the 'skills gap' with European countries like Germany cannot be tackled without taking account of the social partnership model that exists in such countries. This model has forged an alliance between Government, employers and unions in Germany at both the national, regional, and sectoral levels as well as at workplace level. Combined with statutory underpinning, it has resulted in a shared commitment to provide high-quality workplace training and development.
The need for the UK to emulate a similar approach is strongly hinted at in the recent Budget speech by the Chancellor of the Exchequer. He said 'moving beyond the old voluntarism of the past in this national effort for skills, everyone - government, employers, employees, trades unions - has a responsibility and a part to play'. However, to achieve such a cultural shift of this kind requires a genuinely new beginning on skills policy. Tinkering with a new form of voluntarism and a loose coalition of Government, employers and unions will ultimately fail in achieving a skills revolution.
It is critical that the Government recognises trade unions and trade groups lke the Guild as key stakeholders in the learning and skills framework. The Guild believes that there are a number of measures the Government could undertake to promote a range of new partnership approaches to underpin the promotion and delivery of skills provision. These partnership approaches would provide coherence to the system and facilitate a strategic approach to skills policy at all levels. These are outlined in more detail below.
A National Partnership on Skills Providing a clear message from Government, employers and unions on means to push forward the learning and skills agenda is an essential step in facilitating a skills revolution. Leadership from the key stakeholders at the national level will provide the foundation for a strategic approach to skills policy. Building on the recent TUC/CBI Productivity Initiative, the Government should develop a national tripartite consensus that underpins the skills policy, similar to the approach in much of continental Europe. Regional and Sectoral Skills Partnerships There is a large focus in the consultation exercise on the needs of different sectors and on the local and regional dimension to any proposed Skills Strategy. In addition, it is stressed that there is a key role for regional and sectoral skills plans (e.g. FRESAs) in determining the pattern of education and training and the regional agencies involved in this (LLSCs, RDAs, SSCs etc.). The Guild welcomes this approach and it is crucial that the crossover between new regional and sectoral approaches outlined in the consultation are dealt with properly The Guild would like to highlight the importance of 'regionalised' learning funds. These funds are working flexibly towards meeting the needs of the individual regions.
The adult skills' pilots, operating between the RDAs and local LSCs, are a further illustration of the Government trying to wrestle with the fragmented nature of the existing skills infrastructure across England. In different regions, different policy approaches are required if diverse and complex problems are to be solved. Different targets are not necessarily the solution, but different (devolved) policies, tailored to the needs and context of different areas, might be.
To ensure successful implementation, new strengthened skills partnerships at the local/regional and sectoral level are required. The social partners should be actively engaged in governance at these levels to provide the opportunity for skills policy to be developed in a consensual way that takes account of the strengths of trade unions and trade associations as social partners and employee representatives.
Partnership in the Workplace The consultation is completely silent on the role of collective bargaining and how this positively impacts on the learning and skills agenda in unionised workplaces in wide-ranging ways. The reality is that in many workplaces where activity by ULRs is most productive, it is intrinsically linked to a wider collective approach to negotiation of workplace training and development issues. Ways to strengthen the partnership role of unions in the workplace are discussed in more detail below in the section on ‘Collective Rights to Training’.
A POST VOLUNTARY FRAMEWORK? The Guild strongly agrees with the recent assessment by the Chief Economic Adviser to the Chancellor of the Exchequer that there is 'a growing recognition that the old voluntary and ad-hoc approaches to skills policy did not work' and that the UK needs to move to a 'post-voluntary approach to skills training' (Speech by Ed Balls, 26 March 2003). In addition, in his recent Budget speech the Chancellor of the Exchequer reaffirmed this approach when he stated 'the right to education to 16 must be complemented by the right to lifelong learning'. However, one of the key failings of the Skills Strategy is that it does not in any way set out a post-voluntary framework.
Individual Entitlements At the core of the Skills Strategy consultation is the proposal in the 'Progress Report' that there should be priorities for targeting public funds on three key groups/areas. According to the Progress Report they could be:
adults seeking a first level 2 qualification (or a programme leading directly to it) irrespective of age
young adults returning to learning to achieve a first level 3 qualification
individuals who fall within 'specific skill priorities determined at regional or sectoral level 1 '
These priority groups are also discussed in the LSC funding consultation document, but interestingly, the second and third target groups are defined more precisely. This requires further clarification. The LSC definitions of these two particular priority groups are as follows:
young adults (19-30 years old) without a level 3
adults who wish to gain level 3 qualifications in an identified area of skills shortage.
In principle we endorse an entitlement approach for priority groups, but with some substantive qualifications, set out below. In general the idea of having priority groups such as these are not new. For example, the National Skills Task Force (NSTF) recommended that 'all adults should be entitled to free education and training, including basic skills, to attain their first Level 2 qualification, enhanced where necessary by a system of income contingent loans for living, study and travel costs' (with a similar commitment for a 'level 3 entitlement' for young people).
Our first qualification to the priority groups outlined in the Skills Strategy consultation is that the concept of an entitlement expressed in the NSTF Final Report has now been reduced to 'key target groups for the investment of public funds'. An individual’s entitlement to take advantage of their priority group status will be largely dependent on circumstances outside their control. This is especially the case for those who wish to take advantage of this via the work-based route.
Second, the consultation does not address the fact that 'priority group' status cannot be translated into an entitlement in the absence of any statutory underpinning. For example, if the Government intends to partly meet provision for the adult level 2 target group by extending the Employer Training Pilots nationwide, that will disenfranchise employees working for employers who refuse to engage in this provision in spite of financial incentives. There could be similar situations applying to young people with a theoretical funding entitlement to pursue a level 3 qualification (e.g. if their employer refuses to offer Modern Apprenticeships).
The Guild has supported the Employer Training Pilots (ETPs). Early evaluations of the ETPs have been largely positive, with learning outcomes achieved in workplaces where training has not been previously made available. The Guild wants these opportunities to be universalised. Yet there remains a swathe of employers in pilot areas who still cannot be convinced to engage in training on this voluntary basis. Some employers will not train their workforce, regardless of the level of subsidy.
The Progress Report is also conspicuously silent about the existing right for 16- and 17-year-old employees to reasonable paid time off work to pursue approved qualifications if they have not achieved NVQ level 2 (or equivalent). This new employment right came into force in 1999 and the Guild believes that there is a strong case for extending this in some form as a central plank of a post-voluntary skills system. At the very minimum there is a clear need to provide a similar employment right to those employees falling within the priority groups - without such statutory underpinning their entitlement will be an 'empty shell'.
Additional points There is a degree of ambiguity regarding the definition of the 'young adult priority group', with only the LSC consultation document specifying an age range (19-30). The Guild is highly supportive of the definition of young people being 30 rather than 25, as was the case in the earlier NSTF recommendation. It means that young adults will have a longer 'window of opportunity' to return to learning to achieve level 3 and there will be more chance of tackling the shortfall in intermediate qualifications in the UK workforce. However, extending an entitlement to level 3 up to the age of 30 has implications for the Modern Apprenticeship (MA) programme and its age-related eligibility of 16-24. There are already companies piloting MAs aimed at older employees in collaboration with local LSCs (e.g. the Swan Hunter shipyard on Tyneside) and in Wales the entire MA programme is open to older individuals. The Guild supports extending the Modern Apprenticeship programme to older employees as a mechanism to open up pathways for intermediate vocational skills for all workers.
Collective Rights to Training If learning at the workplace is to be more demand-led then it has to be employee as well as employer-led. This requires enhanced capacity for unions and employee representatives such as the Guild. While ULRs have been given new rights to time off, there is however no statutory duty on employers to consult on training with ULRs as a whole, even if such representatives want to be formally consulted. In the Guilds forthcoming submission to the review of the Employment Relations Act, we will be making the case that strengthening negotiating rights for unions and employee representative bodies on workplace training would, in the long-term, accelerate the upskilling of the nation’s workforce and help to close the productivity gap between the UK and its major competitors. There is little or no discussion in the consultation documents about the relationship between the 'low skills equilibrium' that too many UK firms are locked into and the inadequate nature of workplace organisation and employee voice in such firms. Research by a number of influential academics, such as Ewart Keep, have highlighted the inter-relationship between skills deficiencies and organisational deficiencies and that strategies to tackle the former cannot be undertaken in isolation from the latter. The Government must place its Skills Strategy in the context of wider reforms to workplace organisation in order that employees will be able to take advantage of and achieve basic qualifications. The danger is that state subsidies will be used to upskill employees in firms that remain locked in the 'low skills equilibrium' due to organisational deficiencies. In these circumstances both the individual and the organisation will not be enabled to put the newly acquired skills to good use and this will frustrate employees and limit the productivity spin-off for the wider economy. Many companies considered to be 'high performance workplaces' with highly skilled employees are underpinned by the presence of employee representatives. This is why the Guild will recommended that when the Government transposes the Information and Consultation Directive into UK law, it should prescribe in regulation the items on which consultation must take place and this must include training and workforce development.
Sectoral arrangements In its last Manifesto the Government made a commitment to introduce statutory training levies in sectors with serious skills deficits, as follows - 'Where both sides of industry in a sector agree, we will help set up a statutory framework for training'. On this particular point, the Skills Strategy consultation says that 'there may, therefore, be a case to provide support for collaborative arrangements between employers to raise skills and productivity in appropriate sectors, as a means of addressing the skill gaps caused by these types of market failure' (Progress Report, paragraph 49). The Guild is concerned that this latest form of wording dilutes the commitment in the Manifesto and that the Skills Strategy White Paper needs to reaffirm this commitment without any qualification.
The Progress Report also specifies the different types of voluntary and statutory mechanisms currently in place, including:
construction and engineering construction statutory levy system
certification and qualifications required of employees under health & safety and consumer protection legislation
'licences to operate'
voluntary training levies
skill passport schemes
While the Guild believes that voluntary levies have inherent problems (see below), it is broadly supportive of many of these arrangements and would encourage the Government to support and strengthen these measures.
The 'Progress Report' identifies that the model of ‘licences to practice’ or ‘licenses to operate’ are being considered more widely as a means of establishing common expectations of skills and knowledge. The Guild strongly supports this measure as a mechanism to raise demand for training.
While voluntary levies are welcome, it is still the case that there are some employers that do not contribute. For example, in the film industry around 40 per cent of productions fail to contribute to the Skills Investment Fund, which is considered to be quite a successful scheme. The Guild calls upon the Government to take forward its commitment to introduce statutory underpinnings for levies where it can be demonstrated that sectors are not meeting sector targets or training obligations. EQUALITIES The issue of equalities has been largely ignored in the consultation documents. Furthermore, the focus on skills and productivity does not give sufficient attention to the relationship between skills and social inclusion. While the principle of focusing on people with lower level skills is welcome, it should be recognised that access to skills is not equal with regard to issues of gender, race, disability and age. Inequity is apparent even in flagship schemes like Modern Apprenticeships (e.g. 99 per cent of the participants in the construction scheme are men). Young black people are also less likely to have access to these more prestigious forms of training. There is also recent anecdotal evidence that the Employer Training Pilots are having difficulties reaching out to black and Asian employees. These are critical issues firstly on the grounds of social inclusion. Too many people are denied opportunities based on their gender, colour, disability or age, a fact which is indefensible. Secondly, the Government has committed to ensuring that all citizens have equitable opportunities to obtain a minimum foundation of learning for their future employability. The Skills Strategy must put this commitment into practice. Thirdly, there is an economic dimension, as opportunities to take account of the diverse talents of the workforce are currently being missed. The Guild believes that equal opportunities must form a central part of the proposed National Skills Strategy . SKILLS PROGRESSION The accepted theory running through the Skills Strategy consultation is that level 2 skills are important in their own right but also that they provide an essential platform for progression to higher-level skills. However, there is a serious gap in the thinking on this idea of progression and especially on the willingness of employers to facilitate employees progressing to higher skills once all government incentives and any statutory measures are removed. Moving as many employees as possible to higher level skills will also be a central element of the forthcoming Review of Innovation being led by the DTI. There is a serious danger that if the focus of the Skills Strategy on tackling low skills is not accompanied by parallel strategies to promote higher level skills among all employees, this will create a chasm between the outcomes of the Skills Strategy and the Innovation Review. The Guild also believes there may be a case for further consideration to be given to providing financial incentives to employers who are willing to establish workplace arrangements (e.g. employee development schemes) to deliver learning and skills that supplement learning covered by 'priority group' status arrangements or industry specific training. This could take the form of an employer tax credit and faclitatae a clear joint commitment by the employer and employees to work together on any qualifying workplace skills initiative of this kind and so incentivise voluntary collective action. It is also crucial that the Skills Strategy puts in place measures to facilitate progression from basic skills to higher level skills. There are also some specific measures that could lead to improvements in the delivery of skills for life learning, such as the development of funding mechanisms that directly support skills for life learning and also enables learners to adopt blended approaches using Learndirect, ICT and traditional learning measures. This latter point particularly applies to learners in rural areas and workers without a regular base who don’t have access to learning centres. There also needs to be a coherent and integrated approach to ensure that Information, Advice and Guidance professionals and Skills for Life tutors work together effectively. The Guild believes it is critical that pathways from low-level skills to high-level skills are addressed seamlessly through the Skills Strategy and the Innovation Review. CURRICULUM REFORMS The LSC document considers reforms to the adult curriculum, in particular a more flexible approach to adult education and training. Unitisation is considered as a way to provide a more flexible and responsive curriculum, with the potential for extension into a framework where a full level 2 qualification could be gained incrementally. The Guild in principle endorses unitisation, particularly its capacity for transferable skills to be recognised leading to qualifications. This support is qualified by the need to ensure that quality is not diluted, and that is it not a disincentive for achieving full qualifications. The non-completion of almost half of the starters in Modern Apprenticeship indicates illustrates this concern. INDIVIDUAL SUBSIDIES & LOANS It is anticipated that the Skills Strategy White Paper will see the re-launch of Individual Learning Accounts and the expansion of Career Development Loans. These initiatives offer a degree of flexibility for individuals to pursue learning. However there is a danger that they could substitute for a collective and more strategic approach to workplace learning. There is a clear need for employees considering using these learning avenues to have support and guidance from trusted intermediaries in the workplace. These programmes should offer flexibilities that enable them to be adapted to a collective approach to delivering training and development in the workplace. Individual Learning Accounts ILAs proved that there is a big market for adult learning. However by opening up the market to new providers without effective regulation and monitoring, unscrupulous 'learning traders' defrauded the ILA system. The withdrawal of ILAs has had implications for everyone. As cost is a major barrier to learning for many employees, ILAs were often the hook to engage non-traditional learners. ILAs also formed a key component of broader strategies to work in partnership with employers and providers to develop the workplace as a site of learning. ILAs had been used collectively to access affordable, quality learning opportunities. ILAs were also useful in the uptake by Skills for Life learners and their progression to higher level skills. The Guild would strongly welcome the re-introduction of ILAs. However there are potential problems with some of the mooted ideas for the new version of ILAs: The likelihood of a restricted budget, and possible narrowing of the range of options, for example to IT courses up to level 2 Addressing how this will fit with any entitlements for learning up to level 2, as it may be confusing to the learner The potential that providers start charging for IT programmes that are currently free The need for effective mechanisms to stop misuse of the new model The Committee of Public Accounts report into the operation of the original ILA scheme noted that the DfES 'ignored evidence from the pilots that the scheme was most likely to be successful where new learners had advice from intermediaries such as community groups and trade unions' (House of Commons Committee of Public Accounts - Individual Learning Accounts, Tenth Report of Session 2002-03, March 2003). The practical experience of ILAs demonstrates that this advice should have been heeded. Any reconstituted ILA scheme should encourage a strong trade union role. In developing a new scheme for ILAs the Guild recommends that: The role of ULRs and other trusted intermediaries in promoting/engaging and supporting learners to access ILAs and learning purchased through them should be recognized and developed Individuals who open an ILA should have access to a free high quality Information and Advice session regarding their learning preferences The new system should include mechanisms to allow for the collective use of ILAs to purchase discounted quality learning ILAs should be able to be used to support the development of Employee Development Schemes and Collective Learning funds Any new ILA system should encourage employer contributions to ILAs. Career Development Loans (CDLs) The consultation documents suggest that CDLs are likely to be extended. Career Development Loans are a deferred repayment bank loan to help individuals pay for vocational learning or education. The DfES pays the interest on the loan while the individual is learning and for up to one month afterwards, when the individual takes responsibility for all repayments. While there is nothing wrong in principle with CDLs the Government must ensure that by expanding them they are not in effect moving the burden of financial responsibility for higher-level industry-specific training from the employer to individual workers. It is crucial that any expansion does not involve inappropriate targeting of individuals for whom loans running into thousands of pounds is both unaffordable and inappropriate, especially for low paid workers who want to obtain a level 2 qualification. OTHER FUNDING ISSUES It is welcome that the consultation documents highlight the need to address financial barriers other than tuition fees facing adult learners, including transport, childcare and other costs. Obviously, many of these financial barriers will impact on people who are not accessing learning via their employer (e.g. non-working lone parents attending FE college). The Government should also examine how new financial support arrangements could be used to facilitate the take-up of learning in workplaces where lack of commitment from the employer entails additional costs for individuals.