Written by Heather Akehurst OBE, in response to the Education Committee's call for evidence on post-16 education.
As an awarding body and non-profit organisation, Open Awards is committed to advocating for the needs of the learners. Our response provides practical advice on how The Education Committee can help all learners achieve their goals.
We respond to the government on the following points:
The post-16 curriculum
We are not sure that there is a post-16 ‘curriculum’ as such as it would encompass everyone from age 16 onwards including adult education. It still feels like a choice between vocational, technical and academic routes. We need increased flexibility for learners to package a mix of qualifications at post-16 to support a holistic curriculum.
As the new technical qualifications align to apprenticeship Standards, they are big qualifications that would be delivered as the core learning aim for a learner. This makes it a choice between GCSE/A Level route or Level 2/3 Technical qualifications. There isn't room in the curriculum to do a mix of both currently.
The 16-19 Curriculum is still largely qualification-focused, and we would like to see room for shorter programmes of learning to support specific skills development, perhaps alongside A Levels or T Levels. Micro-credentials would be useful as part of the curriculum to respond to employers and individual learner aspirations/learning goals.
We believe that financial literacy and the promised Oracy should feature within the curriculum. With regards to financial literacy, a welcome review of Maths L2 could embed it within there. Too many young people (and adults) have poor verbal communication skills and poor financial understanding. We would see this including interest rates, student loans, mortgages, income balancing, etc.
GCSE resits
Functional Skills remain a vastly under used qualification. We would suggest that it should be greater utilised within school settings as it offers learners a chance to build skills more gradually and gain confidence.
Moreover, Functional Skills use practical skills such as problem solving and so are better suited for some learners who will progress along a vocational route. Use of Entry to Level 2 also allows learners to achieve a Maths or English qualification – it is then for HEIs and employers to decide if it meets their needs.
The need for constant GCSE resits is de-motivating and crushes self-esteem and it can ensure young learners never want to undertake learning in any field again. Whilst we understand GCSEs are the hallmark for some learners' achievement, Functional Skills does provide a maths or English qualification. We would strongly recommend students are assessed if they do not attain a Grade 4 or above and that Functional Skills should be offered.
Functional Skills are also more suited to learners with special educational needs and those with low level Maths and/or English skills as each level acts as a stepping stone, enabling them to gain knowledge and confidence as they progress.
Employers need workers with strong literacy and numeracy skills for tasks like administration, communication, problem-solving, and financial management. In an increasingly data driven world, we need to understand what the data is telling us but also be able to present it effectively and imaginatively. A skilled multi-faceted workforce boosts productivity and innovation, driving economic growth, whilst low literacy and numeracy levels contribute to unemployment and lower wages for individuals with fewer chances for advancement.
Good literacy skills help individuals access and understand information, improving learning and societal outcomes, whereas low numeracy skills can lead to financial struggles, health risks, and difficulty accessing services.
We know there are gaps in literacy and numeracy attainment that contribute to inequality across different social groups. Education is the leveller in this, creating opportunities for personal and community advancement and affecting other areas of life such as positive health understanding and actions.
Moreover, studies show a strong link between low literacy levels and crime whilst improving literacy and numeracy can help prevent reoffending by offering the chance for education with a real hope of leading to employment. The new Minister for prisons, James Timpson understands this, and Open Awards was pleased to see him advocate for apprenticeships in prisons and education programmes that focus on Functional Skills to seek to rehabilitate offenders.
Within the UK, approximately 18% of adults aged 16 to 65 in England (equating to 6.6 million people) have "very poor literacy skills” (literacytrust.org.uk) and government data indicates that 17 million adults—49% of the working-age population in England—have numeracy skills at or below the level expected of primary school children. Whilst we’ve seen an increase in attainment of children, we still have a task ahead with the working age population, an issue that stubbornly continues. Functional Skills with their practical approach play an important role in addressing this. More investment is needed to encourage their uptake within employers, communities and individuals.
Indeed, the Leitch Review of Skills, commissioned in 2004, recommended that 95% of adults achieve functional literacy and numeracy, highlighting the shared responsibility among individuals, employers, and the government in achieving these goals.
Functional Skills are crucial in improving literacy and numeracy in the UK because they provide practical, real-world applications of English and Maths, helping individuals develop essential life and workplace skills. They help people to read and understand bills, contracts, and medical information, manage finances, calculate budgets, and understand interest rates. Importantly they enable people to communicate effectively in work and social settings.
T Levels
The work experience element of some T Levels is not practical, creates geographical disparity and does not give the right experience to lead to sustained employment. In T Levels such as Marketing it works very well – for other T Levels such as Construction it is a misnomer – it is industry experience. The length of the placement does not allow a learner to achieve all the elements needed to progress. We would suggest that it is re-named, and due consideration is given to industry experience that can be replicated within colleges to give equality of opportunity.
The use of T Levels also closes down vocational and academic routes for the learner at a much earlier age, potentially reducing their career choices. We believe they are a flawed qualification with little opportunity for later innovation in a fast-moving landscape.
Reform of Level 3 qualifications
The current pause and review under the section on Level 3 reforms is now creating a two, or even three, tier system with some new technical qualifications approved for delivery, another submission window imminently and then no clear plans after that. Qualifications previously confirmed as defunded are now extended, including some with overlap to T Levels etc. The reforms were meant to simplify the choices and make occupational routes clearer, but it feels like we're back in a messy situation with no clear route for learners/ providers through available qualifications and no clear process or timeline for the development of new qualifications moving forward. Level 2 reforms are still paused e.g., progression and foundation qualifications. This makes choice for learners difficult to articulate, and investment by education providers hard to determine.
Depending on the outcome of the review, there either needs to be a simplification of the funding approval process to enable awarding bodies to work with local employers, education providers and to respond to their needs effectively, or a clear commitment to the new technical qualifications that must align to the apprenticeship Standards. Whilst the apprenticeship Standards provide a strong foundation for qualification development, it is very restrictive when designing qualifications e.g., it is more difficult to respond to employer feedback (despite employer engagement being a requirement of approval) as we must ensure that all content aligns to the Standard. It has also led to qualifications that are almost identical to the apprenticeship delivery (and in some cases, assessment) making it more difficult to articulate the difference between an apprenticeship route and a technical qualification route. Why would a learner do a technical qualification that has the same requirements as an apprenticeship but without the salary?
The reformed system is going to make it harder long-term to respond quickly to employer demand or changing skills requirements e.g., waiting for IfATE/ Skills England to update an apprenticeship Standard, for the AO to then update the technical qualification. It is potentially unmanageable long-term e.g., reviews of qualifications will need to respond to changes to apprenticeship Standards. We get little notice of these changes, and they are on a rolling basis throughout the year meaning we could end up having to review qualifications in-year or ready for the new academic year with limited notice to providers.
The use of ‘windows’ for the development of new qualifications that need funding on a sectoral basis also appears to be short sighted. This is a fast-changing world, and it can result in learners having to be taught a curriculum that is already out of date, thereby disadvantaging the learner and damaging the credibility of the qualification/apprenticeship.
Apprenticeship challenges
A particular problem encountered within apprenticeship delivery is the demand placed on the apprentices and the tendency to treat them as fully trained and employed staff as opposed to trainees. This can include a reluctance to be flexible in releasing them for training and support even when they need it. Also, there can be inconsistency of the support they are receiving from their employer mentors.
Additionally, the most widespread challenge is for learners to keep on top of the ‘off the job’ records and meet the level of depth and detail required to meet the funding and compliance requirements; this is not always helped by employers commonly failing to protect their weekly study time. Many learners are trying to keep on top of everything within their own time. This leads to added pressures at home and ultimately impacts on mental health.
We would look to the Kickstart scheme and would like to see incentives for employers to take young apprentices at levels 2 and 3 whilst understanding that they may not be ‘job ready’ at the start of their apprenticeship.
We also understand that HMRC were supposed to record retention of apprentices once they had completed their apprenticeship to prevent employers abusing the scheme. We are not sure if this happened as we have not seen any reports. It would also be useful to have a much clearer breakdown of when and why apprentices leave before completion to understand if there is value in an apprenticeship without a formal qualification.
Mental health
There can be significant metal health issues for apprentices of all ages. Whilst there can be internal health and wellbeing officers, the volume of referrals far outweighs their support capacity and other tangible mechanisms are not always in place due to the lack of funding. Significant time is needed to support mental health challenges, however due to funding constraints, this is not factored into the staff workload. More funding for pastoral support is certainly required so that learners are provided the support they need.
There are increasing difficulties facing further education students, including mental health issues and access to mental health support, and cost of living pressures. There are some examples of really good work in pockets e.g., mental health practitioners based in schools (42nd Street in Manchester), but this continues to be a postcode lottery. We need to see an increase in central funding for third sector and early intervention teams to have this support consistently available rather than relying on individual school budgets.
EHCP also have a time limited life and even when they are in place are not always carried between school to the next provider and onwards. This is where it has been possible to obtain an EHCP, the NAO report of 28th February 2025 found significant delays in local government meeting their 20-week target, leading to increased mental health challenges for individuals and their educational establishments.
It appears to us that there is a fundamental issue with how we view mental health. Instead of focusing on prevention, early intervention and maintaining good health, we only focus on mental health when it is negative. It’s vital for early intervention to become a part of education and training. This is where we can establish the skillsets and toolkits needed to maintain good mental health and overcome challenges.
Learners with SEND
Our experience is that far too many children with SEND are not supported at mainstream schools (usually due to funding issues, LAs refusing to issue EHCPs despite clear documented needs, lack of specialist places available (all SEN places in Sefton were full and oversubscribed as of 2022); and the perception by some staff that it was ‘unfair’ to other children that SEND children be treated differently). Therefore, in our experience, one of the barriers in SEND young people accessing FE begins much earlier than age 16.
To access FE, they need to be supported to achieve and thrive in school to have the confidence in themselves to continue in education. So many end up out of school, losing confidence, isolated, and not fulfilling their potential.
As referenced above the NAO found there are continued delays to young people being assessed for an EHCP with many parents paying privately for autism assessments.
Young people with SEND are presenting with more complex issues e.g., increase in emotional and behavioural difficulties, mental health disorders, poverty. Education providers need more funding for specialist training/ staff to support learners effectively.
There has been an increased use of RARPA to focus on individual outcomes, which is positive in terms of flexibility of provision and creating individual pathways, but the downside is learners can leave without qualifications. Employers still recognise qualifications and ask for these on job descriptions. We are potentially disadvantaging learners longer term by not ensuring they have comparable qualifications to their peers.
Where RARPA is effective is in employability and independent living skills, but we see a real mix of quality in how this framework is applied. An increase in training and support for ISPs and mainstream provision on the use of RARPA would be welcomed. NATSPEC is doing some really good work in this space. It would also be advantageous to review the framework at the same time as reviewing the wider curriculum.
There is also a lack of uptake of apprenticeships for young people with learning disabilities, despite the maths/English flexibilities that have been available for some time for learners with an EHCP. This suggests that it isn't only maths/ English that was causing a barrier. Funding isn't clear for specialist colleges looking to offer apprenticeships and it is difficult for independent specialist colleges to be approved as an apprenticeship training provider. They don't in many cases have the track record of delivering apprenticeships, but they do have the track record of supporting learners with disabilities and learning difficulties into employment. Additional support for ISPs in this context would see an increase in supported apprenticeships.
Access to HE
It is well documented through several reviews that the Access to Higher Education diploma outperforms Foundation Degrees in terms of achievement and retention and we would therefore question the continuation of funding for them. The latest date from the 2021-2 cohort tells us that:
- 29% of Access to HE students entering higher education were from ethnic minority backgrounds, compared to 24% of students with other Level 3 qualifications.
- 6% of Access to HE students entering higher education had a disability, whereas this figure was 15% among those with other Level 3 qualifications.
- 24% of Access to HE students entering higher education were from disadvantaged areas, in contrast to 11% of students with other Level 3 qualifications.
Among Access to HE Diploma students who graduated, 25% achieved a first-class degree, closely aligning with the 26% rate among students with other Level 3 qualifications. Careers guidance, particularly within schools is patchy and often lacks independent knowledge and understanding.