Post-School Education and Skills Reform legislation: consultation analysis

Enhanced functions for the SFC

This section sought views on SFC collection and reporting of data from funded organisations, and any additional duties and powers that may be required.

New duties to provide better information to SFC

Question 8. Do you think we need to introduce new duties on organisations receiving public funding to provide better information to SFC?

The largest group (46%) saw a need for new duties on all organisations in receipt of public funding, while 17% wished to see new duties only for some organisations, and 16% did not see a need for any such new duties. This balance of views was broadly similar between organisations and individuals, although fundable education bodies were most likely to see a need for new duties only for some organisations.

Note: 54 respondents (28% of the total) did not answer Question 8. Percentages may not sum to 100% due to rounding.

Around 110 respondents provided further comment at Question 8.

New duties for all organisations

Of the 64 respondents who saw a need for new duties on all organisations (46% of those answering the question), 48 provided written comment. Key points from these and other respondents who did not select a preferred option are summarised below.

Among respondents choosing this option there was broad agreement that any organisation receiving public funding should have a duty to provide evidence of impact and that this should be done in a transparent and consistent way. Comments on why this was important included the need to ensure that public funds are being used to achieve outcomes, and that where and how money is spent is relevant to ensuring value for money for the public purse.

Further comments, including from training providers, supported consistency in information requirements across all organisations, with a single system applying to colleges, employers and training providers, comprising standardised data returns. Reducing duplication was also highlighted, with the example given by an individual educator of current reporting on apprenticeships to SDS, SQA and in Further Education Statistics (FES) returns.

Sector/business representatives were amongst those observing that better information would support SFC oversight and governance and improve efficiency. A related comment was that enforceable guidelines would enable under-performance to be identified and addressed early. Examples given of key metrics included learner progression, pass rates, employer feedback, learner feedback, and completion rates. There was also support from some respondents, including from fundable education bodies, and sector/business representatives for using information for benchmarking.

Other suggestions included:

• Information requirements should vary according to the type of provider, with data collection streamlined to reduce the administrative burden, for smaller organisations in particular.
• Organisations in receipt of funding should be required to provide information on their contribution to tackling poverty and inequality and how they were making a wider social impact through training and development.
• Gathering a larger breadth of information on student experience, including dissatisfaction, and more general student/apprenticeship wellbeing.
• Current information systems and processes should be strengthened to support careers information and skills/workforce planning. Renewables and sectors supporting low carbon solutions and sustainability were referred to, as was health.

In relation to who should have access to published data, suggestions included providers, policy makers, delivery partners (such as careers services). A few respondents commented that organisations should report on their Fair Work employer credentials and paying the Living Wage.

New duties for some organisations

Of the 24 respondents who saw a need for new duties only for some organisations (17% of those answering the question), 22 provided written comment. Key points from these and other respondents who did not select a preferred option are summarised below.

As at earlier comments, there were calls for an appropriate balance to be struck. This included comments in favour of a proportionate approach, avoiding duplication of information, with fundable education bodies amongst those advocating utilising existing data.

In terms of which organisations might or might not have additional requirements placed on them, several respondents, including fundable education bodies, addressed why they thought current reporting requirements were sufficient. These comments tended to be focused on universities. It was highlighted that these institutions already provide detailed information, including through the Higher Education Statistics Agency (HESA) and UCAS, with some university data used in wider UK and global settings. HESA data was mentioned as enabling benchmarking across the UK. From a college perspective, it was observed that reporting responsibilities were already considerable, with FES returns providing information to SFC and SDS.

There was also a view from fundable education bodies that the public sector was already providing sufficient reassurance on meeting key priorities. It was suggested that private sector should operate under the same mechanisms, enabling consistent reporting on apprentice numbers, progress and outcomes.

There was a suggestion that information requirements for organisations should be linked to their relationships with SFC as a funding body (for example, if SFC takes responsibility for funding private providers). The role and scope of Ministers' powers in these funding relationships were also highlighted.

No new duties required

The 17 respondents – including fundable education bodies – providing comment who did not support introducing new duties tended to focus on there already being sufficient data collected. It was suggested that this should not be increased without discussions on why additional data was needed. There were comments that there was an emphasis on data mining, without any evidence of how it fed into a continuous development loop or how it enhanced sector efficiency or effectiveness.

Don't know

As previously, respondents felt that data collection should be transparent, without being onerous on organisations. It was suggested that current information could be used more efficiently and effectively and shared with stakeholder agencies to minimise duplication of effort. It could also be used to support better understanding of the learner journey.

Systems for collecting data

Question 9. Do you think there is a need to strengthen existing systems and processes for collecting data? If your answer is yes, then please explain why the data is needed.

The majority of respondents (66%) saw a need to strengthen existing data collection systems and processes. This balance of views broadly similar between organisations (63%) and individuals (71%), although training providers were less likely to agree than other organisation respondents.

Note: 50 respondents (26% of the total) did not answer Question 9. Percentages may not sum to 100% due to rounding.

Around 105 respondents provided further comment at Question 9.

A need to strengthen existing systems and processes

Of the 95 respondents who saw a need to strengthen existing systems (66% of those answering the question), 75 provided written comment. Key points from these and other respondents who did not select a preferred option are summarised below.

Respondents – including training providers and sector/business representatives – highlighted the role of accurate and meaningful data in helping stakeholders identify areas for improvement in education programmes and ensuring programmes aligned with the needs of the broader economy. However, it was also noted that it could sometimes appear that data was being gathered for no defined purpose and in multiple formats, with several fundable education body and local authority or school respondents suggesting that there should be an assessment of what was being collected and why.

In terms of how existing systems could be strengthened, suggestions included:

Better alignment of data collection formats, including to allow for comparison.

Developing more agile data systems that could collect and make data available in real time. Respondents observed that there were significant lags in reporting timelines for colleges and universities and that a real-time predictive approach would allow learning providers to make efficient and effective use of the data intelligence.

Integrating existing datasets and reporting to create a more joined up approach to education, skills development and research. There was also support for creating better linkages between datasets, to help follow the learner journey.

Several training provider and sector/business representative respondents made comparisons with the SDS FIPS which allowed users to tailor it to their needs, and which provided real time data – although there was a contrary view that FIPS could be complicated to use and required review.

Other specific comments on systems and technology included:

Moving to a digital system would streamline data capture and analysis.

Standardised data collection will allow benchmarking and mapping to support planning, monitoring and reporting.

Rationalising the system across sectors could result in economies of scale which could help cover the purchasing costs of a new system. Investment could be ring-fenced for a Customer Relationship Management (CRM) system or similar.

If SFC and SAAS merged, data collection processes and dissemination should be strengthened to align data insights, at national and regional levels.

No need to strengthen existing systems

Of the 20 respondents who did not see a need to strengthen existing systems (14% of those answering the question), 13 provided written comment. Key points from these and other respondents who did not select a preferred option are summarised below.

Those who did not support changes often reasoned that current systems were sufficient. Comments, including from training provider respondents, once again referred to FIPS as working well.

Other suggested that the SFC's Outcomes Framework and Assurance Model should be given time before introducing new reporting requirements. A few fundable education body respondents referred to higher education's engagement with HESA Data Futures and again mentioned that current systems and processes are sufficient for university data. The SDS systems were also described as robust.

Don't know responses which included comments

A small number of written responses came from those selecting this option. Comments made were:

FIPS was a good system, with real time information. It could respond to mid-year changes, and monitored learners through surveys.

HESA and FES returns seemed to have strong processes.

SDS already had effective systems for collecting data.

Didn't answer the question, but gave comments

Respondents in this category reiterated many of the comments outlined earlier, including the need to streamline data collection, the role of data in strategic decision-making and observations that current data could be utilised better instead of increasing reporting requirements.

It was also suggested that the SFC should be required to produce a cohesive plan on equalities data across the learning and skills sectors which Scottish Government should sign off and which the Scottish Parliament should scrutinise.

Systems for reporting and publishing data

Question 10. Do you think there is a need to strengthen existing systems and processes for reporting and publishing data? If your answer is yes, then please explain the purposes for which you or others might use the information.

The majority of respondents (66%) saw a need to strengthen existing data reporting systems and processes. Organisations and individuals showed a similar balance of views (67% and 64% respectively). However, there was some variation across organisation types; fundable education bodies and other public sector respondents were most likely to agree, while training providers were least likely.

Note: 52 respondents (27% of the total) did not answer Question 10. Percentages may not sum to 100% due to rounding.

Around 95 respondents provided comment at Question 10.

Reflecting some of the points noted previously at Question 9, comments emphasised the importance of effective reporting and publishing of data. This included reference to the role of data reporting in:

Supporting transparency, accountability and demonstrating value for money. A comprehensive understanding of how public funds were being used was seen as essential, including to build public trust.

Improving understanding of activity and outcomes being delivered across the skills landscape. Respondents noted the importance of outcomes data in measuring the contribution made to national policy objectives, and data on current training and apprenticeship activity for providers and others.

Evidencing skills need and demand to inform forward planning for providers, public bodies (including local authorities, local employability partnerships, and development of apprenticeship frameworks), employers and other stakeholders.

Enabling learners to make more informed decisions between provision options.

Supporting improvement in skills provision, including reference to the potential value of SFC data in quality frameworks.

Respondents also highlighted specific aspects of the current SFC data reporting approach. This included reference to ongoing reform under the new Outcomes Framework, to modernisation of the reporting approach (e.g. expanded digital functionality) and to specific data streams such as Further Education Statistics. Other relevant data reporting was also highlighted, most commonly SDS publications, and higher education reporting through HESA and UCAS.

Making best use of currently collected data

Current SFC reporting was generally seen as effective. However, it was suggested that better use could be made of existing data collection and reporting systems, to avoid unnecessary development of new reporting mechanisms and to minimise duplication of effort. The resourcing required of funded organisations to support existing data collection was highlighted, and there was a view that there was little appetite for more data reporting unless this added value.

Some felt that the skills sector could make better use of published data (e.g. in forward planning), but a more common view was that more of the data currently collected from funded organisations should be published. There were calls for this aspect of the data reporting approach to be improved before additional data requirements were added. It was also observed that making better use of collected data might result in providers being more receptive to any additional data requirements.

Key areas to strengthen existing systems

Of the 94 respondents who did see a need to strengthen existing systems (66% of those answering the question), 13 provided written comment. These respondents highlighted several areas for improvement.

Consistency and comparability were commonly cited issues, and there was a perceived need for a more consistent approach to reporting across all sectors, including private providers. This was thought to be a particular priority if SFC's remit was expanded to include additional providers. There was also a perceived discrepancy between FE and HE sectors in reporting of data, and a view that there was currently less transparency in relation to HE skills provision.

Enabling meaningful comparison of data across sectors, and internationally, was highlighted as of particular value. Benchmarking of performance between providers and sectors was seen as key to driving improvements in provision. It was suggested that data already held by SFC and/or publicly available could be better used to enable more meaningful comparison.

Comment on the quality of current publications acknowledged recent improvement, but some saw scope for further change to aid understanding, for example in the visual presentation of data. This included a particular focus on making publications more accessible for learners. Development of online dashboards was proposed to present data in a more accessible and useable way, with reference to dashboards developed by the Office for Students as a positive example.

The timing and speed of publication was also highlighted as an area for improvement, most commonly a perceived need to shorten the time between data collection and publication to ensure published data was more current. Respondents saw this as a having potential to improve the usefulness of published data, with respondents referring to publication of data up to 12 months after collection as significantly diminishing its value.

SDS FIPS reporting was cited as a positive example of a responsive and flexible data reporting system. Greater use of digital technologies to collect, validate and process data was recommended to speed up publication. It was also noted that reducing the volume of data collected could streamline this process.

Specific proposed improvements to current reporting systems focused on the following areas.

• Ensuring the reporting approach addressed skills policy priorities, such as demonstrating how funded provision contributed to national skills priorities and regional need/demand, and supported access and equity issues. In addition to skills policy, respondents wished to see reporting take account of wider policy priorities such as around sustainability and equality.
• More detailed reporting in relation to specific sectors and funding streams was most commonly focused on apprenticeship funding. This included calls for more detailed data on: equity of provision across programmes, sectors and regions; contract values, ownership structures of bidders and use of subcontracting arrangements; and greater transparency in relation to HE skills provision. It was also suggested that apprenticeship data could be better integrated into wider SFC reporting.
• A focus on ensuring the trustworthiness and honesty of reporting was a particular concern for some individual respondents who wished to ensure that the reporting approach could demonstrate the accuracy of data.
• Respondents highlighted potential to strengthen specific reporting streams, including:
  • More detailed FES reports, providing an account of the logic modelling used, and incorporating all data required for reporting.
  • Retaining current SDS reporting such as Regional Skills Assessments, Sectoral Skills Assessments and the Data Matrix. These were seen as providing essential data on the labour market and skills demand.
  • Establishing a replacement for previous INFACT database reporting capabilities.
  • More granular detail in publication of data on graduate apprenticeships.
• Calls for SFC to provide a detailed schedule of recurrent publications, similar to that provided by HESA.
• Perceived scope for better linking of SFC data with other relevant sources, such as local authorities, to add value to reporting (e.g. to support widening access work).
• A proposal for SFC to produce sector-level "horizon scanning" reports, for example around projected demographic shifts, to aid skills planning.
• A view that SFC could be more transparent with funded organisations through better sharing of data in a way that could be integrated with internal systems, and calls for raw data to be provided.
• Comment on the value of engagement with stakeholders to inform the reporting approach, including specifically where SFC was considering a change to data reporting. There was reference to a recent SFC consultation with skills providers as providing useful insight that could inform ongoing improvement.

No need to strengthen systems

Of the 18 respondents who did not see any need to strengthen existing systems (13% of those answering the question), 9 provided written comment. These respondents described current national and local reporting as proportionate and sufficient to meet needs, and felt that the approach was transparent and trusted. This included specific reference to SDS data reporting such as FIPS and Sector Skills Assessment. Some also repeated the view that better use could be made of the extensive data already provided by institutions and skills providers.

Information to be collected

Question 11. What information about funded organisations would you most like to know and why?

Around 105 respondents provided comment at Question 11.

The value of skills data

The importance of access to robust information on funded organisations was highlighted, including to ensure transparency around allocation of public funds to assess value for money. Respondents referred to several skills sectors (such as apprenticeship and FE sector funding) where it was suggested that data reporting could improve transparency and understanding. There were also calls for SFC to lead by example on transparency by publishing organisational information around governance and allocation of funding.

The role of data reporting in quality assurance was also discussed. This included reference to use of data to compare performance and outcomes across providers and sectors, and to improve understanding of demand, for example to inform workforce planning and recruitment. It was also noted that published data could enable prospective learners to make more informed decisions on their education and skills development.

Respondents highlighted several key principles seen as relevant to the scope of data collection, with reference to the current SFC approach to data collection and reporting. This included a perceived need to ensure that data collection was proportionate and focused on what was relevant, did not unnecessarily burden funded organisations, and was consistent and coordinated across sectors, ensuring the same reporting and transparency standards applied to all organisations. It was also suggested that the reporting approach should recognise the potential for information collected from providers to be confidential or commercially sensitive.

Enabling comparability of outcomes across sectors and internationally was identified as a key priority, especially if SFC's remit was expanded under proposals 2 or 3. Respondents highlighted the importance of enabling global comparison in particular, and observed that the Purpose and Principles included "globally respected" as a principle for post-16 education.

It was suggested that further work was required to enable meaningful comparison of outcomes across sectors, including to ensure consistency of reporting and transparency standards across funded organisations. There was also reference to the value of longitudinal trends, and for reporting to track key measures over time to inform ongoing improvement activity.

Specific data types

In terms of specific data to be collected, some made reference to the range of data currently collected and held by SFC. It was suggested that the new Outcomes Framework and Assurance Model provided an opportunity for SFC to disseminate this information. There were calls to make better use of existing data and documents produced by organisations, such as annual reports and audits, governance documents and equalities reports.

Other specific information suggested by respondents is summarised below.

• Reference to financial information and forecasts was most commonly related to the level and profile of funding awards, including information on the criteria or rationale used in allocation of funding, and to demonstrate how funding had been used. This included interest in the profile of awards by organisation type, geographic distribution (and how this fits with local/regional priorities), provision type and specific vocational pathway. Other financial information suggested by respondents included:
  • Information on award of apprenticeship contracts was mentioned by several fundable education body and local authority respondents. There was specific interest in contract value, organisation type, ownership structures and any subcontracting arrangements, and management/overhead costs – the latter reflected interest in maximising the amount of allocated funding that was directly spent on skills delivery for learners.
  • Data on the qualifications, learning aims and expected outcomes linked to funding. There was particular interest in information on how these deliverables fitted with skills requirements and wider policy priorities.
  • There were also calls for up to date information on the financial sustainability of institutions and skills providers, and the financial health of the skills sector as a whole.
• Information on funded organisations' activity included reference to the profile of provision, and uptake data including the number and profile of learners (e.g. geographic and equalities information). Calls for more detailed information on the profile of learners were linked to a perceived need for greater transparency around quality and widening access information for providers. Other information on funded activity referenced by respondents included:
  • The quality of provision and learner satisfaction, including calls for more qualitative information reflecting learners' experiences, especially in relation to widening access and participation.
  • How funding was used for student support and development including reference to additional support needs, mental health support, safeguarding, and access to careers support.
  • The extent to which provision was meeting local, regional and national skills requirements, and sector-specific skills priorities.
  • Information on contribution to wider public policy commitments such as Fair Work First, sustainability and climate policy, sustainable development goals, and the needs of rural and remote communities.
• Organisational information including delivery capacity, governance and oversight (e.g. structure, leadership, compliance and risk management), and organisational strategies.
• Delivery of outcomes was seen by some as the most important information on funded organisations, including to enable monitoring of delivery against agreed targets and ensure public funds were delivering value. Respondents made specific reference to: retention and completion rates; learner outcomes including post-course destinations (e.g. the number of learners entering employment or continuing to other study); and wider value in relation to research and innovation, social value, and economic impact.

Additional powers for SFC

Question 12. What, if any, additional powers should SFC have in order to help ensure the post-school education and skills system operates effectively?

Around 95 respondents provided comment at Question 12.

This included a number of fundable education bodies, individuals and others who did not see any need for additional powers for SFC. These respondents suggested that SFC had all of the powers required for their current role, and that proposed reforms should be implemented before reviewing the need for new powers. This was also linked to a view that implementation of reforms should initially focus on policy and support.

Other respondents – including several fundable education bodies – saw a need for additional powers to ensure that SFC could deliver the new responsibilities being proposed. This was reflected in calls to ensure that any new powers were tailored and proportionate to SFC's role and duties. It was also suggested that new powers must enable SFC to support a diversity of funded organisations across sectors, including reference to the differing legal status and regulatory contexts of funded organisations.

While recognising the diversity of providers, there was a perceived need for greater consistency and parity of approach across skills sectors – and for this to be reflected in the requirements placed on different funded organisations. This included with reference to the Further and Higher Education (Scotland) Act 2005. It was noted that SFC also needed to take account of UK-wide policy and regulation for some sectors.

There were calls for SFC to be permitted some flexibility in funding approach, including to ensure sufficient autonomy for funded organisations. It was noted that the legal status of universities, for example, granted them some autonomy. There was also a perceived need to provide other organisations with flexibility to undertake institution-led projects. Balancing the need for flexibility within a more coordinated and consistent approach was seen by some as a key challenge for SFC if proposals 2 or 3 were preferred.

Additional proposed powers

Specific additional powers suggested by respondents typically focused on apprenticeship provision, ensuring the balance of provision met skills requirements, and data collection/reporting. These are summarised below.

Powers relating to apprenticeship provision were the most common specific suggestion. Respondents noted that new powers will be required if SFC were given the ability to fund different types of organisations, such as independent training providers (ITPs) and local authorities. This included a perceived need for SFC to better recognise differences in operating models and legal status. It was noted that a substantial number and range of training providers were currently involved in delivery of modern apprenticeships alone.

There were also calls for SFC to amend allocation of modern apprenticeship funding to ensure this is commercially viable, to enable greater flexibility in use of apprenticeship funding, and to have the power to mandate delivery of apprenticeship opportunities under the Outcomes Framework and Assurance Model. Changes to current information collection around apprenticeships were also proposed to reduce the burden on funded organisations. It was suggested that a requirement should be placed on the Minister to consult with SFC regarding any proposed changes in policy or funding for apprenticeships.

Proposed data collection and reporting powers included new duties to collect and report data, and to enforce compliance with data reporting requirements. It was noted that these powers needed to integrate with existing HESA and UCAS data functions for the higher education sector. Changes to the current SDS FIPS were also proposed to reduce the burden on funded organisations and improve administrative processes.

Ensuring the right volume and mix of provision across funded sectors and organisations was seen by some as a key priority. Respondents proposed new powers for SFC to ensure provision met skills requirements and to support equity of access across all skills and learning pathways and learner groups. This included the power to prioritise specific sectors or types of provision (e.g. based on skills requirements and outcomes), and to promote the diversity of learners (including mature learners, those from disadvantaged backgrounds, and those with protected characteristics).

Other additional powers proposed for SFC included:

Powers related to SFC's regulatory oversight to ensure accountability for funded organisations including the power to specify governance requirements, prevention of 'double funding', and assuring the quality of funded provision.

Powers to facilitate effective collaboration across sectors and funded organisations, and to ensure that teaching, research and knowledge exchange is supported. Respondents also referred to closer working with other key stakeholders, such as qualifications authorities and skills sector organisations, and integrating more sector-based expertise within SFC.

Supporting development and piloting of new models, including the power to take a co-design approach to delivery.