NALA submission (19/1/2012) to the consultation paper on the establishment of SOLAS

NALA provided the following response (19/1/2012) to the consultation paper issued by the Department of Education and Skills (20/12/2011) on the establishment of SOLAS. The submission responds to the set of specific questions provided in that paper, in the order they were asked. If you have any feedback on this submission, please

A consultation on the establishment of SOLAS

1. The questions in this survey relate to the text of the consultation document which has been circulated. Questions 2 - 7 relate to Policy Area 1: How we administer and fund Further Education and Training in Ireland. Questions 8 - 13 relate to Policy Area 2: How to decide what courses to deliver? Questions 14 - 18 relate to Policy Area 3: How we guide and support learners and potential learners in choosing the right course. Questions 19 - 21 relate to Policy Area 4: How we manage and support our staff. There are also some final questions at the end of the survey.

Your organisation and contact details National Adult Literacy Agency Sandford Lodge Sandford Close Ranelagh Dublin 6 Website: www.nala.ie Contact person: Inez Bailey Email: ibailey@nala.ie Telephone: 01 412 7900 2. Policy Area One - How we manage, fund and administer FET
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How can we use funding and administration structures to improve outputs and outcomes? Our response to this question focuses on two elements: building on examples of proven best practice, and connecting funding to targets and monitoring their progress. Building on examples of proven best practice The National Qualifications Authority of Ireland (NQAI) is a good example of an established organisation which could usefully inform the development of SOLAS. Over the last 10 years it overcame many challenges, in particular the way it balanced the legal functions that impacted on a significant number of institutions and organisations across the education and training sector. It: successfully bridged the education and training divide, and, developed good working relationships with all stakeholders. A key element of their success lay in their approach and their strong values and principles, formulated in their first and successive strategic plans. A set of values and principles is contained in their current strategic plan see http://www.nqai.ie/documents/strategyreport2008-2012.pdf page 11 or below: ____________________________________
NQAI Values and Principles Focus on the learner We will promote a culture of lifelong learning and the continued development of an accessible, responsive, flexible and integrated qualifications system. The learner is the focus of the qualifications system. We will promote equality for all learners and access to the qualifications system for all in society. Partnership with stakeholders We place particular importance on working effectively and efficiently with all stakeholders in education and training and beyond to achieve our goals. We will work in consultation and co-operation with national stakeholders and international partners to achieve our goals. We will respect their individual roles and responsibilities. We will seek, where appropriate, to lead change and to develop co-ordinated approaches to qualifications issues. Quality Quality is integral to the qualifications system and to how we approach our work. We will work to the highest standards of public service with due regard to best management practices, value for money, accountability and service delivery.

Transparency and clarity We will maintain an open and transparent approach to our work and make optimum use of information technology and communication tools. Clarity and simplicity will inform our engagement with stakeholders. Research and evaluation Our work will be informed by evidence, research and evaluation. This comprises awareness of qualifications needs and major trends and developments in relation to both qualifications and the public service context in which we operate.

____________________________________ SOLAS could use the above values and principles as a basis to determine and publish their own values and principles under which the organisational structures will operate. This will enable SOLAS to develop a transparent and consistent way of working with a diverse range of stakeholders, and assist in the building of common understanding and goodwill within and between organisations. It should also assist SOLAS to recognise the distinct traditions and values of education and training in order to ensure that both continue to evolve and flourish within the new system. This will contribute to improved outputs and outcomes. Examples of how the NQAI values worked 1) In their Consultative Group they asked stakeholders to discuss particular issues with them when necessary. This meant NQAI staff developed good working relationships with staff in other bodies, understood the perspectives of multiple stakeholders as well as shared information about their work in a positive and open way. Meetings were very well attended and well received. The NQAI also published much of their documentation on the web which showed their transparency. 2) The NQAI has much experience of working with other groups that SOLAS need to consider: The Authority considers that the interdependence among stakeholders for the achievement of the goals and objectives set out in this plan is a positive aspect of the nature of the work of the Authority. Nevertheless, the Authority recognises that there are risks associated with this and will work with stakeholders to mitigate risks, while also recognising that the nature of the risks can equally enhance the potential for effective implementation. (Strategic Plan)

Connecting funding to targets and monitor progress The following need to be set and agreed with providers: Objectives and targets for funding received;
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Costs of interventions and programmes for specific target groups; and Monitoring of these targets and their resourcing

People with the lowest educational attainment have benefitted least from education and training, including FET. Funding incentives to work with identified target groups need to be put in place. Funding for priority groups, for example, people with low educational attainment, should be estimated for each Local Education and Training Board (LETBs) and aligned to national targets (for example, National Anti Poverty and Social Inclusion Strategy (NAPs Inc) and National Skills Strategy (NSS)). This can be best achieved through the Central Statistics Office (CSO) figures for people with less than a level 4 qualification. Funding should be made available based on the estimated need in an area and numbers who can be supported within the FET infrastructure. Existing FET infrastructure should be expanded through the use of distance, self-directed and blended learning provision. Greater flexibility in provision should also be required by SOLAS, such as weekend provision. In relation to people with literacy and numeracy needs, there should also be a relationship between the national target to reduce the number of people with low literacy and a related target set for each of the LETBs. The provider should collate information and report each year on progress made as a result of an FET intervention based on: initial and final assessments, and certification achievement, if appropriate. Progress at an individual level can be recorded using a personal identification number (PIN), such as the PPS number, while evaluations can provide efficacy data at programme level. Progress towards adult literacy and numeracy targets can be informed by international studies such as PIAAC (Programme for the International Assessment for Adult Competencies) and evaluations of progress at LETB level. Adult literacy targets are identified in the NAPS Inc and in a broader sense the Programme for Government 2011, which commits to: address the widespread and persistent problem of adult literacy through the integration of literacy in vocational training and through community education.
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3.

Is there a particular funding model which works best?

Currently, 0.3% of the total education budget is allocated to discrete adult literacy development, with funding for other further education and training containing no obligation to raise adult literacy and numeracy standards as part of their programmes. There is simply not enough value being gained from the resources allocated to all further education and training. There needs to be a policy shift to make sure that scarce resources are prioritised for those with the greatest need, that is, people with less than a Level 4 qualification. This should be done by: ring-fencing dedicated resources for adult literacy to respond to the significant demand for discrete adult literacy services. connecting funding to the raising of adult literacy and numeracy standards as part of all FET programmes. Irish evaluation results The evaluation of the Labour Market Activation Fund (LMAF) programme has made recommendations about the strengths of the LMAF funding model. One of the areas it highlighted was the difficulty of reaching and supporting certain groups of people. Some key learning points from this evaluation relevant to funding are: To ensure a comprehensive approach to meeting particular labour market activation needs, consideration should be given to splitting any future funds into dedicated theme-based streams. These funding streams would offer packages of funding for which providers could compete based on demonstration of how they would address, for example: a particular activation issue or target cohort; skills needs in a particular sector (or issues arising from decline in a particular sector); or roll-out of a proven activation level at a wider regional or national level. A multi-annual approach to funding labour market activation projects should be considered in any future Fund to maximise the impact of interventions which are able to demonstrate success. As part of the approach to funding, potential should be investigated for setting aside resources to address barriers to participation and engagement such as travel and childcare barriers, allowing proposals for holistic responses to meet target group needs. International evaluated approaches

Early in the 1990s, Sweden suffered a severe recession, with unemployment soaring 482% between 1990 (1.7%) and 1993 (8.2%). In 1997 Sweden launched the Adult Education Initiative (AEI), a five-year adult education and training programme with the aim of halving Sweden's unemployment rate. Also known as the "Knowledge Lift, the initiative sought to reduce unemployment not through providing specific workplace vocational training, but by achieving a general, rapid boost in the overall knowledge and skills of the population, with particular emphasis on individuals with lower levels of education (Ministry of Education and Science Sweden, 1999). The unemployment rate was reduced to 4% by 2000. Finland's Noste initiative (2003-2009) was similar to the Swedish approach. Both were large scale policies, targeted at workers with relatively poor skills, with the aim to increase qualification and participation rates. It enabled the achievement of a large number of qualifications, and has been shown to have provided a range of employability-related benefits for those with the lowest skills. In the US, the state of Massachusetts has been particularly successful at improving adult literacy provision. External evaluations found a high rate of progression for adult literacy students, with 56% gaining at least one grade equivalent and approximately 30% gaining at least two grade equivalents (Comings and Soricone, 2005). This occurred as policy shifted its focus to improved service quality. For example, in 1991 funding was very low but the system took on 40,000 learners. Soon after, Massachusetts decided to cut its numbers of learners by two-thirds to enable a focus on delivering quality services. Over time, funding levels have risen and Massachusetts again serves nearly 40,000 learners per year, but with much greater effectiveness than it did in 1991. Quantity has followed quality.

4.

How can we better measure value for money?

Value for money is usually defined in terms of economy, efficiency and effectiveness and is concerned with rationale, continuing relevance and impact. We can better measure value for money by: a) Agreeing a shared understanding between all stakeholders at the start about what is meant by value for money and how it will be measured; and b) Regularly measuring value of money internally and externally. SOLAS and the LETBs need to:
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Develop and embed a culture of evaluation using tools such as the Balance Scorecard system which encompasses a number of perspectives to be considered when measuring value for money in a continuous systematic fashion. The Evolving Quality Framework for Adult Basic Education is another useful tool to support evaluation; Be properly resourced to do evaluations; and Publish evaluation results.

SOLAS also need to: Do a quality review within the timeframe of the SOLAS strategic plan; Be subject to a performance review by the Minister for Education and Skills in line with the provisions of the Qualifications and Quality Assurance (Education and Training) Act 2011 (this would be in addition to the work of the Comptroller and Auditor Generals office); Review the performance of LETBs; and Ensure that self evaluation processes involving customers or learners should be a feature of all FET funded programmes. Value for money in adult basic education When assessing adult basic education initiatives, international policymakers tend to focus either on achievement or participation rates. Measures of achievement tend to be based on qualifications, as these are more readily measured than improvements in skill levels. Both England and the US focus primarily on measures of achievement; however, the alternative offers a broader range of positive outcomes. Most countries focus on participation levels, an approach supported by research evidence (See A Literature Review of International Adult Literacy Policies NALA / NRDC, March 2011) which finds a wide range of individual benefits associated with taking part in adult education including adult basic education. A focus on participation also suggests a policy emphasis on adult literacy as a means for improving social capital and civic engagement. Therefore, metrics for people who are most in need should include participation and persistence as well as achievement. In the late 1990s, NALA with the VEC adult literacy service devised an Evolving Quality Framework for Adult Basic Education. This Framework outlines what a good adult literacy service looks like and a means by which it can evaluate itself. This work informed the development of quality frameworks in other programmes (Youthreach and Community Education).

5. What criteria or requirements should be included in Service Level Agreements? Service Level Agreements should include the following: success criteria and how they will be measured; data collection and reporting responsibilities; and demonstration of processes to ensure learner involvement, as well as other local stakeholders in decision making. The following are specific inclusions around adult literacy: Service Level Agreements should have specific success criteria of making improvements in literacy and numeracy levels. Service Level Agreements should allocate a set minimum of funding for adult literacy provision for those with the greatest need. Service Level Agreements should require providers to have a policy, implementation plan, and evaluation system to integrate literacy into FET. Service Level Agreements should require providers to build comprehensive blended learning approaches into programmes, such as www.writeon.ie.

6. How can we ensure an appropriate mix between public and private provision? SOLAS should have public tendering opportunities to enable the appropriate mix of provision.

7. How can we improve our IT systems in an integrated way while avoiding the risks associated with big IT infrastructure projects? Not applicable.

8.

Policy Area Two: How do we decide what courses to deliver?

What information does SOLAS need to inform the delivery of courses and how can it access that information? SOLAS needs information to show they are funding courses that are increasingly relevant, effective and that meet individual needs and national targets. To do this SOLAS needs to coordinate the existing research information being provided and share it with the providers it funds. Building
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on the work of the CSO, Expert Group on Future Skills Needs (EGFSN) and FS Skills and Labour Market Research Unit (SLMRU), it should ensure there is a commonly understood and easily accessed annual report comparing future needs with current and planned provision to identify new course requirements to providers. Informed by such analysis, SOLAS should include key objectives and targets in Service Level Agreements. Reports from providers should be designed in such a way that they can contribute to the strategic information needs as well as indicate emerging demand and regional or national issues. SOLAS should create a mechanism, such as a national forum, to facilitate discussion between employers, trade unions, learners and providers to better match provision to demand and guide instructional design and development of new courses. SOLAS should also commission research studies in key strategic areas as required. Longitudinal studies of learner cohorts would be particularly useful, and may be a more cost effective way of providing robust data.

9. How can SOLAS encourage the design of new courses for the jobs of tomorrow? SOLAS should: create a system to facilitate the sharing of publicly funded resources and programmes through a national resource repository, for example the National Digital Learning Repository, and a programme bank. resource the professional development of instructional designers and programme developers, as well as those tasked with the training of staff delivering new programmes. develop a policy on the use of technology and blended learning in FET. develop a policy on the integration of literacy and numeracy which would lead to the explicit inclusion of these skills in the design of new courses.

identify and publicise success stories relating to new courses in the FET sector which have lead to graduate employment, as well as employment pathways via higher education.
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10. How can SOLAS encourage the appropriate provision of basic skills courses and provide for the important role of community education? Provision of basic skills courses SOLAS should develop an Adult Literacy and Numeracy Strategy that would be underpinned by Guidelines for Good Adult Literacy Work (NALA, 2005). The Adult Literacy and Numeracy Strategy should include: Integration of language, literacy, numeracy and technology across FET programmes at levels 3-6. Support for family literacy programmes for adults through the LETBs, on the basis that schools and adult education providers work with parents to combat educational disadvantage for children and adults. Extending the range of quality and flexible learning opportunities prioritising adults with less than a Level 4 qualification. Providing supports and pathways to progression for adults with the greatest need. Prioritise funding to providers that build technology and comprehensive blended learning approaches into programmes.

Background The International Adult Literacy Survey (IALS) in 1997 highlighted the extent of literacy difficulties among Irish adults (Morgan, M. et al (1998) International Adult Literacy Survey: Results for Ireland. Dublin: Stationery Office). According to the survey, one in four Irish adults has a significant literacy difficulty. This remains the most up-to-date information on adult literacy levels in Ireland. The most recent results from the OECD (PISA) point to a dramatic decline in standards among Irish 15year-olds in literacy and mathematics. (Educational Research Centre (2010) PISA 2009: The Performance and Progress of 15-year-olds in Ireland Summary Report. Dublin: Department of Education and Skills) Missing out on the skills of literacy and numeracy is not just a tragedy for the individual: that personal tragedy is also an enormous loss for all of us in Irish society. Research has shown clearly that mastering the skills of literacy and numeracy brings with it many social, economic and health benefits for the individual and society as a whole. We know too that children who do not learn to read, write and communicate effectively are more likely to leave school early, be unemployed or in low skilled jobs, to have poorer emotional and physical health, to have limited earning power, and to be more likely to be imprisoned. (Department of Education and Skills, 2010)
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Even with the policy commitments and increased resources in further education in recent years, there is insufficient progress in addressing adult literacy. A fifth of the labour force -383,800 has less than a level 4 qualification, of which 117,600 have primary level or no qualifications. (CSO website: http://www.cso.ie/en/qnhs/releasesandpublications/qnhscalendarquarters/ Table S9a, Q. 3, 2011) People with literacy difficulties are at greater risk of social exclusion and are among the most disadvantaged in Irish society. The Houses of the Oireachtas have consistently called for an adult literacy strategy. In 2006 this was described as the most urgent requirement to address the unacceptable adult literacy levels in Ireland (Houses of the Oireachtas Joint Committee on Education and Science (May 2006) Fourth Report: Adult Literacy in Ireland. Dublin: Stationery Office). A recent Report from the Houses of the Oireachtas named a key recommendation: In tandem with this Bill and the proposed legislation to establish Solas (new further education and training body), a National Adult Literacy Strategy should be developed and published as a matter of top priority. (Joint Committee on Jobs, Social Protection and Education, Report on Heads of the Education and Training Boards Bill, 2011) What is required is that SOLAS develops an Adult Literacy and Numeracy Strategy. It would represent the first time adult literacy and numeracy would be strategically considered across further education and training. Within the strategy three initiatives can make a critical difference in tackling the adult literacy and numeracy challenge. They involve new thinking more than new funding and contribute to the reform agenda in public services. These are integrating literacy, family literacy and flexible provision. (i) Integrating literacy and numeracy development into all publicly funded education and training Integrating literacy means designing and delivering education and training programmes in a way that develops core skills in different contexts and courses. This will produce the double duty dollar effect, where for example, the state pays for vocational training, but gets a second return improved literacy and numeracy levels. International evidence clearly indicates the efficacy of the integrating literacy approach (see Casey, H. et al (2006) and Hegarty & Feeley (2009)). Adopting an integrated approach is predominately cost neutral, but it involves the prioritisation of continuous professional development and training budgets. NALAs collaboration with the IVEA, through an integrating literacy working group,
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and with FS Community Training Services can provide practical examples of such an approach, most notably in relation to Level 4 programmes. SOLAS needs to oversee the delivery of the integration of literacy across further education and training programmes. SOLAS should prioritise funding to providers that have a policy, implementation plan, and evaluation system to integrate literacy into FET provision. (ii) Family literacy provides a win-win scenario to policy makers

Literacy standards in primary schools have not changed in 30 years (Department of Education and Skills (2011), The National Strategy to Improve Literacy and Numeracy among Children and Young People). Two-thirds of pupils in the most disadvantaged schools achieved at or below the 20th percentile on standardised tests (compared to 20% nationally) and performance declined as pupils progressed through the school. A national strategic approach to improving literacy and numeracy levels requires that there is a joined up approach across initial, further and higher education. As the new authority for FET, SOLAS must create links with other strategies including the National Strategy to Improve Literacy and Numeracy among Children and Young People (July 2011). For example, we know that parental engagement in a childs learning has a bigger impact on school performance than school effects (Desforges & Abouchar, 2003; Sacker et al 2002). Family literacy initiatives offer potential opportunities to break intergenerational cycles of under-achievement by working with those families who do not, or may not know how to, best support their childs learning. SOLAS should support family literacy programmes for adults through the LETBs, on the basis that schools and adult education providers work with parents, guardians and other family members to support literacy development and to combat educational disadvantage for children and adults.

(iii)

Flexible high quality adult education and training provision

In spite of the expansion of adult literacy learning opportunities, less than 10% of adults with literacy needs are accessing literacy tuition. Currently mainstream VEC adult literacy services provide an average of 2 to 4 hours tuition per week, which is equivalent to two full time study weeks per annum. There are limited intensive tuition options available of 6 hours per week the Intensive Tuition in Adult Basic Education (ITABE). UK and US research shows that at least 100-200 hours are required to move up a level on their National Framework of Qualifications. The Moser Report (1999) states that in the USA,
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the research shows that between 550-600 hours of instruction are needed to become fully literate and numerate. Intensive literacy offers adult literacy tuition on a more concentrated level and facilitates accelerated progress. It is essential to respond with targeted and flexible learning opportunities for people who wish to develop their literacy and numeracy. This means providing adult literacy and numeracy services across a wider range of settings, including the workplace, and by different modes, including distance and blended learning, intensive options and at weekends. The use of technology as a learning aid should be integral to all programmes at these levels. A distance learning service, where learners can progress their skills through self-directed learning should be a permanent feature of FET provision in Ireland. This could be based on the NALA distance learning portal www.writeon.ie which provides learning and certification options at levels 2 and 3. SOLAS needs to extend the range of quality learning opportunities prioritising adults with less than a Level 4 qualification. SOLAS should prioritise funding to providers that build technology and comprehensive blended learning approaches into programmes. SOLAS should also ensure that ESOL learners, who have literacy difficulties in their first language, have access to high quality language and literacy learning opportunities. Provide for the important role of Community Education Recent AONTAS research (2010) highlighted the valuable role of community education, particularly in supporting the most disadvantaged communities and sectors of Irish society. The AONTAS Community Education Network position paper (2010) outlined an effective and sustainable model of funding. SOLAS should use these as key documents in the development of community education. SOLAS should: Recognise the key role and value of Community Education within FET. Define Community Education and set defined guidelines for each LETB on Community Education provision, including working with community and voluntary sector providers. Set the national level of funding allocated and targets to be achieved for Community Education.
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 Facilitate joined-up opportunities between all providers of Community Education and those working in the wider FET system. Liaise with other government departments and state agencies involved in funding Community Education.

11. What role can IT systems play in this? How can we improve our IT systems while avoiding the risks associated with big IT infrastructure projects? IT systems across all providers should be standardised and consideration given to linking these into accreditation IT systems. There is a unique opportunity now to achieve greater efficiencies in this area and create a world class integrated IT system for further education and training on a national basis. IT system requirements include: A single central database to standardise tracking of learners progress and achievement using a personal identifier (for example PPS number). A single online reference bank for programme delivery, which links content and administration. Centralised programme and resource repositories (for example National Digital Learning Repository) for all public funded developments. Link with Qualifax.

12. There are a range of other providers of FET programmes what way should SOLAS and LETBs engage or deal with those bodies to ensure a joined-up approach? SOLAS should create a mechanism whereby they and the LETBs can meet altogether with other providers of FET programmes to discuss identified themes. This should happen at least annually and would establish an opportunity to create synergies between providers where appropriate. Building on Qualifax, all courses and provider information should be available on one central website. This website should be user-friendly to enhance the user experience of engaging with the FET sector. Clear, concise and easy access to information is the first step in an effective FET system.

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The Upskilling Coordination group is a good example of a DES initiative chaired by the Minister of State in which providers and other stakeholders came together to exchange information. This type of group could be enhanced by the development of detailed terms of reference making it clear the expectation on members to share information and contribute to a wider FET sector development.

13. How can SOLAS encourage new programme delivery methods, like distance learning or online provision, and what courses can be appropriately delivered through such methods? Firstly it will be necessary to promote the benefits of new delivery modes such as blended learning delivery and support using online and distance resources and methodologies. SOLAS should require that providers build distance and blended learning approaches into provision. This is essential to expand capacity sufficiently so that FET can respond to the challenge of ensuring that all unemployed persons are provided with learning opportunities as soon as possible, as well as impacting on adult literacy levels. There will need to be capacity building, as well as developments in technical, institutional and management areas to ensure the optimum use of technology in FET. Based on the experience of distance learning and blended learning since 2007, NALA advocate that a dedicated unit is established to facilitate and coordinate the use of technology in FET and to maximise the benefits to learners, providers and funders. This could take the form of an expert high level Learning Technology Team with the mandate to work with all public funded providers. The key role is to ensure consistent standards and sharing of technology in FET development. This would maximise the public investment in educational design and methodologies by achieving a consistency in instructional design, as well as in the coordination of shared programme and resource repositories. The unit would also contribute to high quality learning and content management systems. Synergy with the National Centre for Technology in Education should also be explored. This approach could be achieved by an external body or, using the following steps, within SOLAS itself. Create a dedicated Learning Technology Team, employing experienced Instructional Designers from industry. Perform an Instructional Design analysis of existing content types and delivery methods. This is an essential step to providing an objective account of what is currently happening, and to identify key gaps and priority areas.
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Map content to delivery methods. Every course should include some distance and/or blended and/or online elements. By promoting technical delivery approaches, SOLAS should be able to demonstrate greater efficiencies in course delivery costs across all areas of education and training in the future. Create a single online reference point for development of content and administration. For example, www.writeon.ie has a Learner and Content Management System that provides both these datasets. Set up dedicated Learning Labs in all LETBs with good broadband, projected screen, basic PCs with audio and graphics cards with headsets. (An example is the Open Learning Centre in Coliste de in the CDVEC.) Develop delivery models as templates. Create courses per delivery model to demonstrate practicalities. (An example is the FESS system of common programme development for VECs.) Create a central repository of learning content within the National Digital Learning Repository. (The NDLR has already created a robust system, and its use would also bring an alignment between FE and HE.) Develop case studies of best practice from Ireland and internationally. Showcase these case studies, focussing on advantages such as improved results, increased capacity, integrated learning content, reusability of content, more effective use of teaching hours, reduction in administrative time and costs, etc. This is critical to ensure buy in from providers and practitioners. This could be achieved with a social media site, including video content. Provide training to tutors and teachers on how technology can help them in their work. (An example is the WIT Digital Literacies module on the Higher Certificate in Literacy Development.) Create content between the Technology Learning Team and the providers content experts. Set up a system of ongoing mentoring and support from the Learning Technology Team. Ideally every centre should have one dedicated learning technologist within 2 years of starting this process. (NALAs experience of working with the VECs and community education highlighted that blended learning using writeon.ie worked best when there was good internal mentoring and support.) Standardise tracking of learners so a single database is collated centrally this will massively reduce administration and greatly improve access, transfer and progression options for learners.
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SOLAS should fund a distance learning service to provide free self directed learning opportunities at levels 1-4 for people who are not in learning programmes. SOLAS should require that this service provides a suite of short online courses that are: (i) easy to access, (ii) offer short, interesting and challenging modules, (iii) are accredited nationally, and (iv) offer progression to other courses. SOLAS should develop an integrated national system for the recognition of prior learning (RPL), based on the EGFSN report Developing Recognition of Prior Learning (RPL), (April 2011). RPL development can be a catalyst in the ongoing transformation of the Irish further education and training system of provision. On the demand side, it would facilitate a more direct focus on learner needs, interests, and progression, while on the supply side, it can lead to streamlined and more efficient responses from providers. All FET courses can be delivered with online and technological resources and support, and through blended learning. All learners in FET would benefit from blended learning delivery modes and supports.

14. Policy Area Three: How we guide and support learners and potential learners in choosing the right course Do the benchmarks that the Group has set make sense? Yes Are there others? Yes Following profiling and PEX score by the National Employment and Entitlement Service (NEES), the provider should carry out a learning assessment of needs to ensure appropriate course placement. As part of this, every client would be helped to identify course related literacy, numeracy and other needs in relation to their intended programme. The EU Action Plan on Adult Learning: Basic skills provision for adults: policy and practice guidelines (Final Report 2010) recommends that Guidance personnel carry out initial screening (preliminary assessment) to identify whether an individual may have a literacy and/or numeracy need. If such a need is identified a more thorough assessment is undertaken by staff with specific training in teaching adult literacy and/or numeracy. (Guideline No. 3.1.7 The role of Guidance, page 14.)
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Every learner should have an individual learning plan (ILP), agreed with the provider, responding to individual needs, goals, interests, skills and abilities; social development; and employment pathways. ILPs are central to the EU Action Plan on Adult Learning: Guidelines. Other supports include an assessment framework for adult basic education called Mapping the Learning Journey, and there are also built in learning plans as of the distance learning service on www.writeon.ie. There should be input from learners into the development and monitoring of the system of referral and guidance to facilitate an increasingly user friendly system and ensure customer experience helps drive improvements. This could be achieved by inclusion of learner representative bodies in the new structures and through evaluations. Literacy and numeracy issues should be taken into account in the policy and procedures for enrolment and in the Equality checklist.

15. How can we simplify the system of eligibility criteria for different FET programmes so that we minimise delays and differences, perceived or otherwise, in the administration of income support and participant allowances There are currently no eligibility criteria for the adult literacy service and this should be maintained. SOLAS should ensure access to all FET programmes for anyone who has less than a level 4 qualification and is in receipt of state benefit. This would reinforce a priority within FET to those with the greatest need. In addition there should be no time waiting period before you can enrol on a programme. This suggestion is in line with European policy. The EU Action Plan on Adult Learning: Basic skills provision for adults: policy and practice guidelines (Final Report 2010) recommends A statutory right to education equivalent to primary and secondary level exists for low skilled and low-qualified adults. (Guideline No. 1.1.8 Policy-making, page 14) In NALAs experience of running a project under the Labour Market Activation Fund in 2010-11, we encountered many people who met different labour market criteria which impacted on their eligibility to enter programmes. In the case of people with less than a level 4 qualification
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and in need of literacy and numeracy support, it would be beneficial to classify them all as a priority irrespective of which unemployment benefit they receive. The system of eligibility could be further simplified by allowing anyone who is identified through PEX at being high risk immediate access to a learning programme.

16. How can we marshal our often fragmented system of referral and guidance into an integrated service while maintaining resources in critical areas? There should be one central referral and guidance service that is nationally advertised and branded, where the customer can access information on all services and options available to them. This would include one website, email, freephone, text that would be developed in plain English. It should be clear that the national service corresponds to a local system of referral and guidance operated in the LETBS. There should be a clear distinction and link between educational guidance services and employment guidance services. In addition, prioritisation of target groups within further education and training should be given to those with the least educational achievement. The Evaluation of the Labour Market Activation Fund (LMAF) 2010 recommends: To facilitate a more integrated approach to identifying individual needs, tracking upskilling (including major, minor and special purpose awards at NFQ level) and recording progression outcomes, the feasibility of establishing shared databases across the key agencies along the progression pathway should be investigated, taking full account of data protection implications. It is important that such databases not only record completion, accreditation and progression but also gather robust information on drop outs from programmes. (page viii) Using the National Framework of Qualifications, a chart of further education and training should be devised for the public. It should capture the types and levels of learning opportunity available and should be the key communications visual used by all providers and stakeholders. This would significantly reduce the confusion around FET and reduce the need for spending on multiple branding of courses, colleges, providers, quality assurers and funders.

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17. Course placement based on course availability rather than participant needs or desires and continued delivery of courses that are not relevant to national skills needs. SOLAS needs to ensure that the most appropriate courses are delivered to learners most in need. A review of existing course provision as part of the quality assurance process should be undertaken every five years to determine the validity of courses. In order that education and training programmes should respond to skills needs, SOLAS and NEES should have a defined way of working with providers, potential learners and employers. Use of self directed distance learning resources (such as www.writeon.ie), and the proposed nationally integrated system for RPL, can facilitate a more direct focus on learners needs and interests, and lead to more streamlined and efficient programme offers from providers. They can also contribute to significantly raising the capacity of the FET system to meet the challenges of servicing the unemployed and adults with literacy needs. 18. What do we need to do to ensure appropriate tracking of learners between NEES and LETBs and between LETBs to minimise information gathering and maximise progression opportunities? One major weakness in governance in FET is the lack of data on the progress made as a result of adult education and adult literacy interventions. At national level, the Irish adult literacy targets have never been measured or evaluated. At provider level, the relative value of programmes has not been systematically evaluated, and the progress individuals make is not adequately recorded. SOLAS should ensure there are robust evaluative processes at national, provider, programme and individual levels. SOLAS should have one central database that allows for tracking of learners between NEES and LETBs and accessible by personnel in both. A central system would minimise duplicate information gathering and show trends that would inform policy and practice going forward. For this purpose, every client should have a personal identification number (currently it is their PPS number). It is important to design learner input into the development and operation of tracking systems. This could be achieved through quality and evaluative processes. The NALA Evolving Quality Framework is an example of a quality support process that involves learners. Learners
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should be encouraged to keep an account of their own learning journeys so that they can see how they are realising their Individual Learning Plan.

19.

Policy Area Four: How we manage and support your staff

What kind of qualifications would be required of staff in the FET sector-pedagogical and otherwise? To ensure a consistent standard of service provision and to support continuous professional development, clear career paths and qualifications should be identified for adult educators and trainers. Any qualifications selected should include the integration of adult literacy and numeracy in FET and provisions should be made to skill up specialists in literacy and numeracy development. Suggested qualifications are from Waterford Institute of Technology (WIT), who in partnership with NALA, has supported professional development for adult literacy practitioners since 1997, with Higher Certificate and degree programmes qualifications at Levels 6 to 9 on the National Framework of Qualifications. These qualifications are recognised as appropriate qualifications for Adult Literacy Organisers. However, there is currently no formal agreement on appropriate qualifications for adult literacy tutors. This should be formalised in order to support and manage staff, ensuring equality of opportunity and the provision of clear career paths. It is vital to the future development of FET that there is parity of esteem for all FET tutors.

20. What kinds of skills would staff need, in terms of management, as well as delivering tuition? The WIT professional development programmes in adult literacy and adult education cover the broad extent of expertise required of adult educators, including pedagogic and management expertise. Key areas include: Social marketing, Curriculum development and management, Assessment including initial, formative and summative assessment and accreditation processes, Basic counselling / guidance skills, Literacies development (for example, digital, family, literacy, numeracy, as well as ESOL), Integrating literacy,
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Blended learning, Management, and Research and evaluation.

There will be significant change involved in the reorganisation of Further Education and Training. We recommend that managers across the new organisation are appropriately equipped with competencies in strategic management, change management and strategic planning in education. Guidance staff should have specific expertise in screening for learning needs, including literacy and numeracy and specific learning difficulties, particularly with hard to reach groups. Staff with specific training in adult literacy and/or numeracy will also be required to carry out diagnostic literacy /numeracy assessments, as recommended by the EU Action Plan on Adult Learning: Basic skills provision for adults: policy and practice guidelines (Final Report 2010).

21. What should be the nature and extent of the SOLAS role in managing and supporting staff? LETBs and other providers are best placed to manage and support staff. However SOLAS should maintain a quality control role, ensuring that all providers / trainers are appropriately qualified to deliver their contracted training. Work by the IVEA with a range of higher education providers should feed in to this work. SOLAS should identify the minimum qualification requirements for the various roles in FET, including for adult literacy and numeracy tutors. Appropriate qualifications for adult basic education and training include the suite of programmes developed by WIT at Levels 6 to 9 on the National Framework of Qualifications. NALA advocate that FET tutors delivering literacy and basic skills development should have literacy/numeracy specific expertise to the minimum standard of the WIT Higher Certificate in Literacy Development or equivalent. All FET tutors should have professional development in the integration of adult literacy and numeracy in FET programmes at NFQ levels 4-6. Volunteers have an important role in adult literacy and community education and a volunteer charter should be developed and adopted nationally. This charter should identify initial, continuing training and support requirements.
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22.

Final questions

What other things could SOLAS do to improve the customer service overall? SOLAS should have a structured process to hear customer voices. There should be a dedicated learner sub-group and learner representatives within the SOLAS operational structures. This formal consultation and feedback agreements should be reviewed each year. SOLAS should require details on communication arrangements with and between providers, such as LETBs and private providers, and learner representatives. As part of our consultation process on this Paper, NALA convened a focus group of adult literacy learners to inform our submission. Learners emphasised in particular that SOLAS measurement metrics should not be focussed on certification only, as literacy students do not base their progression solely on certification. They also stressed that in any SOLAS reporting, it is important to ensure that literacy learners can maintain their confidentiality.

23. Should Youthreach and Community Training Centres be merged and should SOLAS continue to administer them? X Merge.

Do not merge. X Solas should administer. Solas should not administer. Comment These services should be merged and administered by SOLAS through the LETBs following a consultation process. 24. Should FET delivered in specialised or atypical outreach settings like prisons or care services be managed by SOLAS or another Department or agency?
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Should be managed by Solas. Should be managed by relevant agency. Depends on nature of provision.

Comment As the further education and training authority, SOLAS should have oversight of all FET programmes. A consultation process should inform this development.

25. Any other comments? NALA understand and agree that there should be a focus on retraining the unemployed, however, they would also petition SOLAS to retain literacy learning as a separate group, remembering that some unemployed literacy learners have a long road to travel before becoming job ready. In essence it is important that literacy learning and other forms of adult education continue to be funded for all adults and not be limited to the unemployed. As promised in this document, learners were most keen that SOLAS and the LETBs ensure consistency of standard and service. This would require every front line member of staff to: adopt the same customer service module, and have equal access to one online, central referral system. The new customer service approach should be clearly explained to the public before implementation and any referral system should have a public portal for transparency and reference purposes. SOLAS and the LETBs should be under the Freedom of Information Act whilst at the same time endeavouring to be as open and as transparent as possible. NALA appreciate the opportunity to feed in to the consultation process and wish the Department of Education and Skills well in their deliberations. NALA looks forward to contributing to the ongoing dialogue and consultation on the development of the SOLAS Action Plan, and to our future collaboration in raising adult literacy and numeracy levels in Ireland.

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NALA, 19 January 2012

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