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CHAPTER FIVE: PROCEDURES ASSOCIATED WITH THE ILA SCOTLAND SCHEME
ILA Scotland learning provider registration processes and eligibility
5.1 ILA Scotland has established a fairly rigorous set of administrative procedures associated with the operation of the scheme. This is partly associated with the problems which led to the suspension of the original ILA Scheme. The perceptions of these procedures and their impact on learning providers, learners and potential learners was an important focus for the research.
5.2 The initial step for learning providers who wish to participate in the ILA Scotland scheme is to register as a provider. The process of registering as a learning provider was generally viewed as a positive and straightforward experience for most. Participants from Scotland's Colleges and HEIs were particularly satisfied with this aspect of the scheme. Some private providers commented that previous involvement with the scheme and close working links with learndirect scotland had helped in ensuring a continuum of support and guidance. Respondents from the community/ voluntary sector, however, commented that the process had the potential to be time-consuming and bureaucratic.
"Yeah, our nominated person at ILA Scotland has been really helpful in setting up our status as a provider and getting our courses onto prompt because we were unable to do it ourselves and also sorted out any anomalies or problems that we have." (Higher Education 4, LP interview (1))
5.3 Though some respondents from the community/ voluntary sector commented that the registration process had the potential to be time-consuming and bureaucratic, the rigour of the registration process was understood and regarded as appropriate by the majority respondents.
"I would just feel, you know it would have to be a high standard because it's government money that we're playing with I feel that it is important that we have a high criteria of people to deliver ILAs." (Private Provider 8, LP interview (1))
ILA Scotland course eligibility processes
5.4 In Phase One of the research, learning providers commented on the additional workload that they experienced due to the administrative demands associated with course eligibility. However, in Phase Two, more learning providers stated that the administration involved in the scheme was subsumed into their roles as part of overall involvement in the scheme. The more positive attitudes towards ILA procedures were in some cases associated with changes which learning providers themselves had introduced as a result of their involvement in the ILA scheme.
5.5 The eligibility criteria for approving courses for inclusion in the ILA Scotland scheme were described as straightforward by the majority of learning providers. The changes made to the ILA100 and ILA200 offers were recognised by participant from all sectors as having improved the variety of courses and approved learning opportunities available to learners and potential learners, and cited by participants from the community/ voluntary sector as being instrumental in encouraging learners to undertake vocationally directed learning to improve employability or professional development. There were some participants, however, in both phases of the research, who discussed the potential for ambiguity and lack of clarity in the process, through which a course was recognised as eligible.
"Well we never know exactly what courses are going to be approved and what's not going to be approved. We seem to think it would be approved and then perhaps if we put a word in the text that they don't like then its not approved…and secondly the time scale it takes for them to come back and say that the course is approved or not is an issue to us." (Scotland's colleges 10, LP interview (2))
PROMT tool
5.6 ILA Scotland have established the Provider Opportunity Management Tool ( PROMT) to provide an on-line method for learning providers to register the learning opportunities which are available. Learners can then access them via the ILA website. There were very mixed responses to use of the PROMT tool. Some providers reported no difficulties and welcomed the increased automation of the registration process, though getting used to the PROMT tool presented a number of initial obstacles. Support from the ILA Scotland call centre and email contact with staff helped to alleviate these obstacles.
5.7 In Phase One of the research the PROMT system was described as cumbersome by many larger LPs who report that the processes for entering and updating data were both lengthy and time consuming. Data from other sources could not be imported into the PROMT system resulting in laborious manual data entry and the duplication of other work.
"You also have to re type everything in, its not as if you can send a disc or a data base, we actually have to put in each course one by one, now that's also very difficult when there's changing provision semester by semester. So there's no doubt about the fact that it is an onerous administrative task." (Higher Education 1, LP interview (1))
5.8 However, by Phase Two of the research responses were generally more positive, and it appeared that learning providers felt they had greater competency regarding the use of the tool. This also reflected changes which had been introduced. An important change which has been widely welcomed by providers has been the introduction of flexible start dates (in May 2006). This enables learning providers to enter courses which do not have a designated start or end date in the PROMT tool without the need for the monthly updates which were previously required. The very positive response to the alteration in procedures can be seen in the following comment.
" The flexible start date, my wee friend, the flexible start date! Yeah it's made a big difference to the time it takes me to keep it going." (Private provider 8, LP interview (2))
5.9 However although learning providers were increasingly more satisfied with the procedures associated with registering for the ILA Scotland scheme, some intermediaries suggested that there were continuing issues which had had an impact on potential learners. In some cases, it was suggested that the website was not up to date, and that this lack of current information 'put learners off' applying to the scheme. It was suggested that this may be linked to difficulties providers face in using the PROMT tool. At times, intermediaries were aware of inconsistencies in how courses were described and that sometimes course searches on the website would not show all options available as different learning providers may describe the same opportunities slightly differently. It was felt that administrative procedures could be simplified for providers which would have a positive impact upon learners.
Learner application process
5.10 The application process has been noted by a number of respondents as being bureaucratic and creating barriers to participation. Intermediaries in particular described the process as time-consuming, and noted that this was one of the least successful aspects of the scheme. There was a general view that the application process was 'tedious' and ILA Scotland had 'tied themselves up with red tape'. This has resulted in some confusion amongst client groups.
"…and I think probably for workers and you know the client group it is sometimes quite confused with the procedures of how you apply; that you have to get the form sent off, get an application pack, you know complete the application and send it away and wait to get your student number and then to get a token, you know that can be quite confusing" (Learning Uncovered delegate 1, Formal intermediary interview (1))
5.11 The application form itself was described as cumbersome and difficult to complete. Agencies suggested that it should be made more streamlined and user-friendly. Representatives whose client groups include learners with learning difficulties highlight that the application pack is inaccessible for these learners.
"I would just reiterate that point, we can see that it's inaccessible to some of our learners when they approach us so we would prefer it if it was more accessible." (Voluntary 2, Formal intermediary interview (1))
5.12 Intermediaries were in general more critical than learning providers. This may reflect the different roles of these groups of respondents, with intermediaries dealing with a wider cross-section of potential learners, many of whom have not yet established firm involvement with learning providers.
5.13 While a number of learning providers describe the application process as straightforward, a number mention the complicated and demanding nature of the application process, and the dangers that this discourages learners from the key target groups. In this context they refer to the need to provide a supportive role in assisting learners with their applications. In particular learning providers in the community and voluntary sector commented on the need to provide support of this kind.
5.14 Some learning providers have also noted that on occasion, the time taken to complete the application process has meant that people have had difficulty accessing the learning opportunities for which they are eligible.
"…the difficulty for the learner of the scheme is simply the timing. For instance they may have seen an advert in the paper for some evening classes and it's said that you might be eligible for ILA funding. They would come into the college on the open evening as was advertised and of course it may start within a week and they've not registered yet so with the timing sometimes they don't get registered in time to be able to utilise the funding, because it's all centralised and they can't just register at the college with the funding that has often delayed it and some people couldn't access their ILA." (Scotland's colleges 20, LP interview (2))
5.16 Overall the application process has been described as putting barriers in place for certain groups of learners including those with literacy or numeracy problems, older people, learners with disabilities and those from lower socio-economic backgrounds.
Initial learner telephone call
5.17 In both phases of the research both learning providers and intermediaries have identified the telephone call that the learner is obliged to make to request an application form as a potential barrier. This relates to issues surrounding the confidence and communication skills of the learner, and it was suggested that learners are often daunted by the prospect of phoning. It was suggested that the process could be made easier for the learner if the learning provider was more involved.
"I feel first time round people would say 'how do I apply for it', and providers were allowed to sit down with them and fill in an application. This time we give them the leaflet, say there's the number to phone, you can use the phone in here, and we explain what's going to happen, even then, they find it quite daunting some of our customers,. Our confident ones they'll do it no bother, they'll have it done within the next day, but there are people that it's taken a lot of courage to come through the door and speak to us, and then they're told to go and phone this number before they do anything else, and they find it quite daunting. I just think if it was possible for us to sit down with them at the phone, but that's not the same because they're meant to be doing it themselves." (Private provider 5, LP interview (1))
5.18 Difficulties associated with the initial learner telephone call continued to be discussed in Phase Two, and have been recognised as posing particular difficulties for certain types of learners and potential learners, particularly those from lower socio-economic backgrounds, and those with mental health needs or learning disabilities.
5.19 Intermediaries and learning providers report their attempts to provide support for applicants, but suggest that the current arrangements make this difficult. Intermediaries who have tried to phone on behalf of clients have been told that this is not possible.
"…a lot of people we work with just don't like using the telephone, you know and I feel it would be easier if I was able to phone on their behalf. But I mean I did initially try that and they said no but I do understand that due to data protection and that they can't give me, you know any information sort of thing, but you see I was going to give them the information because I had the consent of the client." (Learning Uncovered Delegate 1, Formal intermediary interview (2))
5.20 There was a particular concern that the scheme could discriminate against people with disabilities, and in response to this one respondent was able to recount how they had made use of the Disability Discrimination Act ( DDA 2005), which requires organisations to make reasonable adjustments for people with disabilities. On this basis 'ad-hoc' arrangement had been made with ILA Scotland allowing someone else to apply for an ILA account on behalf of an applicant with disabilities.
"There's only an ad-hoc administrative system allowing applicants with disabilities which precludes them from applying themselves to allow someone else to apply on their behalf. In other words, I've arranged with one of the supervisors or one of the managers of ILA that I can email the applications into them in effect." (Local authority 3, Formal intermediary interview (1))
5.21 Another group who were identified as having particular problems in this respect are those serving prison sentences. They may wish to take up an ILA opportunity whilst serving their sentence or as a rehabilitative measure on their release. Not only does the phone call cause logistical problems in actually being made but also carries implications of declaration of personal details such as address and employer. One respondent was able to indicate that these problems had been addressed.
"… we did sit down and work through a structure because a prisoner with an application form is a requirement to state where they live and what their income is, etc. So their home at the time would be HMP and their employer, if you think about it, is the prison so there was a need to set that in process. And also if you wanted support from the learning contractor that works within the prison then it needed to go through a process that was agreed in advance, so we worked all that through and we did come up with a process." (Other 1, Intermediary focus group (2))
5.22 In response to these all of these problems, there is a strong feeling amongst some intermediaries that they could provide an alternative to the initial telephone call through acting as a channel for the dissemination of application packs. It was highlighted that certain agencies, for example Trade Unions and local authority agencies, are fully accountable bodies and could provide a mechanism through which to supply application packs to members or employees. Voluntary groups also suggested that their roles in providing the distinctive forms of support which they do provide could be more clearly recognised, and enhanced within the scheme.
5.23 It was also noted that the facility to apply online has been described by learning providers as a sought after tool. Learndirect scotland are currently piloting an online application tool for use by learners and this has been welcomed.
"The thing I gather now is that learners can now apply online for an information pack, an application pack so we're going to be making that part of the…we interview all of our access students so we're going to have a computer set up in the interview room and have them, you know, get online and request an application pack before they leave the interview room. So we've found that's a useful innovation." (Higher Education 6, LP interview (2))
5.24 Intermediaries stated that they felt that such a function would be highly valuable and would make the application processes more accessible. They have indicated their readiness to collaborate with learndirect scotland in developing provision of this kind. It has also been noted that online registration may not be suitable for some learners with disabilities, and email registration was highlighted as an appropriate mechanism for some of this group, in particular those with visual impairments or who use alternative internet browsing techniques.
"I'd like to see an email process, I think it would suit a lot of our client groups... through email because online forms are not always accessible." (Voluntary 2, Intermediary focus group (1))
Income assessment procedures
5.25 Learners wishing to access the ILA200 offer must provide proof of income. Both learning providers and intermediaries in Phase One of this research described income assessment procedures as often time consuming, cumbersome and complicated. They were highlighted as a barrier to accessing ILA Scotland opportunities. Problems associated with income assessment procedures were continued to be noted in Phase Two of the study.
"I do believe that they ( ILA Scotland) should be looking at what they're doing and relaxing it because if they do relax it, the criteria, the evidence they're asking for, that would speed the process up and people would be more inclined to apply." (Trade Union 1, Intermediary focus group (2))
5.26 Applicants in employment are required to provide three most recent payslips. It is suggested that this can create problems for low-paid workers, and discourage them from making an application to ILA Scotland. The requirement to supply payslips was identified as presenting several different types of problematic issues. Many individuals have difficulty submitting wage slips due to loss, or not holding on to them. In such cases applicants were advised to go through their employer's personnel department, whose speed in returning the required information was variable, and therefore had the potential to impact on the application process. Respondents also suggested that learners may be reluctant to go to their employer's personnel department to get copies of wage slips as they are worried that their employer would realise that they were going on a course and that this may affect their job security.
"I would say that the asking of the wage slips is certainly a barrier because, it's perhaps the wrong way to look at it, but they look at it as going to personnel to get wage slips, if they haven't kept them for the last 3 months then personnel know that they're going on a course…. and they're quite wary on going on courses in case they're going to have a reaction that 'oh well they're not getting any over time, they're going to leave the company anyway' and that has been said to me." (Trade Union 1, Formal intermediary interview (1))
5.27 A second point raised was that of overtime payments and their effect on an individual's overall income assessment. It was feared that this would cause certain types of workers, for example factory workers, to have their annual salary over-estimated due to additional and often inconsistent overtime payments. It was suggested that overtime and bonuses should be considered outside of income assessment processes. Additionally, some difficulties have been highlighted in relation to expenses added to salaries.
"…a member of staff that we had sent in her things and she was only on about £12,000 a year, but because she has travel expenses and travel expenses are paid with your pay, but they are not part of your pay, she was told that she didn't qualify and we took it up and we didn't really get anywhere with it" (Trade Union 6, Formal intermediary interview (2))
5.28 For those who are self-employed, but on relatively low incomes, the requirement to provide audited accounts can act as a barrier. This was described as a costly extra burden resulting in this group applying only for ILA100, which does not require proof of income. For example, child minders who are self-employed have found it difficult to access ILA200 because of the problems and cost involved in accessing audited accounts.
"The £15,000 threshold [which was operational at the time of the interview] works against our client group because they are self employed and one of the criteria to access the £200 is you must have audited accounts for self employed people. Well we come under the threshold, most of our child minders are self employed and they earn less than £15,000, so they're not required to have audited accounts. The accounts they do themselves on an annual basis and they do self assessment and that's acceptable to the Inland Revenue and to the National Insurance and when applying for the £200 ILA they get knocked back, they cannot access it at all, even though they fit the criteria perfectly well." (Voluntary 2, Intermediary focus group (1))
5.29 It was also suggested that there are people in a range of positions who have no regular income, e.g. women who are not in paid employment outside the home, but find it difficult to obtain proof of this position, and procedures involved in securing a National Insurance Statement can be complicated and drawn out.
"…people who fall into the grey area of eligibility, for example who are at home, who are in positions where maybe they've had part time jobs so their National Insurance contribution statement is not at zero, but they're not registered unemployed and they don't have any pay slips and they're obviously eligible for the funding but they've got no way of proving it." (Private provider 1, LP interview (1))
5.30 For those in receipt of benefits, including incapacity benefit, and tax credits, it is suggested that many are already uncertain about the rules and regulations regarding entitlements, and requiring evidence for eligibility for ILAs adds to this uncertainty.
"I think there is a general confusion, I mean there are so many financial things… everything's different and I just think people are so confused by all the financial information they're dealing with, particularly with our client group where every benefit, every training opportunity has different criteria, but it's an absolute mine field. So its part of a general mine field I think." (Local authority 2, Intermediary focus group (1)
5.31 In many cases, intermediaries commented that, in situations where it was difficult for the learner to obtain proof of income, it often became a time consuming and expensive exercise, and led to the learner missing out on the course.
"…a lot of the clients I work with they don't keep stuff like that, you know saying you have been awarded so much that will be paid into your bank account sort of thing, so we have to take the form into a housing agency for it to get stamped. And the housing scheme's irrelevant, it's quite a long bus journey to get into the centre of town and when one woman wanted to do a course she was actually too late because of this sort of thing. She had four children, she then had to pay the bus fare into the town and back with these four children to get this form stamped. So if there's any other way of getting evidence of income. I mean I know other organisations have asked to see a bank statement with all the other bits blacked out saying income support, or invalidity or whatever paid into the bank account, you know." (Learning Uncovered delegate 1, Formal intermediary interview (1))
5.32 Respondents also commented on the additional burdens which are associated with having to update this evidence on an annual basis if entitlement to the ILA 200 is to be maintained.
"We have had a number of issues lately with students who have previously been eligible for the £200 scheme. When they try to book a course in the following year, they only have the £100 available and have to contact ILA Scotland to retrieve the extra funding. I understand it is because ILA Scotland are waiting on confirmation of their earnings but most do not realise that this will cause problems to their funding. If they were more aware of the importance of this it would save many of the problems we have." (Private provider 20, LP interview (2))
5.33 This led to the suggestion that rolling information might be a way to minimise the burden associated with this requirement.
"One problem that people face is if they've had to prove that they're earning less than the £15,000, that can be a bit of a hassle and it might be enough to put people off, actually. And another point that someone raised the other day with me actually is if they've been approved the first year for the £200, it would be good if there was like a box on the application form saying, my circumstances haven't changed, so they would just tick that box and it means they don't actually have to send proof of their earnings. That might be a better way but it depends on how the ILA are. For their audit purposes, they might need to see proof, I don't know." (Private provider 18, LP interview (2))
Income threshold
5.34 The £15,000 income threshold had been identified as problematic by a number of respondents during Phase One and the earlier part of Phase Two. In particular reference was made to a number of employees who had relatively low incomes which were just over £15,000, and who might also have family commitments. As a result the respondents in the later stages of Phase Two, who were aware of the raising of the income threshold to £18,000 in June 2007, welcomed this development. This is seen by learning providers as a significant step towards enabling those people whose salaries are marginally above this to access ILA approved learning opportunities.
"…people were quite surprised when I had said about the recent changes to the threshold. People hadn't known that and were welcoming it. We have quite a lot of people who are in that gap £16,000/£17,000 - a lot of part-time workers…so it was good - that wider sweep gave a lot of people the opportunity." (Employer 2, Formal intermediary interview (2))
Learning token system
5.35 The learning token is the means through which learners pay providers for their course with their ILA funding. While some respondents, and particularly some providers, regard it as an accepted part of the administrative process, a considerable number of others, both learning providers and intermediaries, found the process cumbersome and problematic. The token itself is sent to the learner, who is then required to ensure that the provider takes receipt of it before they registration on a course can take place. However a number of learning providers describe efforts made in having to 'chase' learners to return their token.
"…with students it's that problem of chasing up constantly and then chasing up the token constantly you know." (Scotland's colleges 20, LP interview (2))
5.36 Intermediary representatives were generally critical regarding the learning token system describing it as confusing, both for themselves and for the client groups. In particular, participants describe the terminology as confusing and that the term 'token' generates expectations that it is a plastic coin or a card similar to a bank card as opposed to paper documentation.
"Well I don't know if its just me or not, but I had this idea in my head that it would be a bank card and you could swipe it and it had £200 on it…" (Trade Union 1, Intermediary focus group (1))
5.37 It can be noted that even in Phase Two a participant expressed a lack of knowledge regarding the learning token as part of the ILA system.
"I don't know the term 'learning token', what does that mean? I don't know that expression, I mean I know what that means, but I don't know what that means in regard to ILA." (Learning Uncovered delegate 3, Formal intermediary interview (2))
5.38 This lack of clarity on the term 'learning token' on the part of intermediaries has resulted in many learners not understanding the significance of the learning token which has knock-on effects for learning providers in gaining access to ILA funding and the time taken to encourage learners to submit tokens.
5.39 Suggested improvements to the learning token system centred around making the process more automated and keeping all parties informed ( ILA Scotland as well as the learner and provider).
"…we thought the system would be electronic that would go through the college; there seems to be a lot of admin involved in the whole procedures with booking and getting the token to the student and actually getting the student to bring the token in. You know it's quite long winded. We would quite like to see the scheme where the learning token was electronic and again it was sent to the actual provider." (Scotland's colleges 20, LP interview (2))
£10 contribution
5.40 All learners are required to make a payment of £10 towards their course to encourage an element of personal commitment. The £10 contribution was viewed by participants in HEIs and Scotland's Colleges as an appropriate and reasonable investment on the part of the learner to access a learning opportunity. Representatives from these sectors thought the personal contribution increased personal investment in learning and the likelihood that learners would complete their chosen course.
"I think that people have to make the commitment, more commitment, or else they're going to go… Because the thing is if there's no real commitment in this then it's so easy to drop out, drop the course you know and not continue it and see things through so at least if you've put some commitment on it you're more motivated to you know achieve that and stay on board." (Learning Uncovered delegate 2, Formal intermediary interview (1))
5.41 This potential for learners to make a personal investment in their learning was also highlighted by participants in Phase Two of the research.
5.42 However, representatives from Private providers, the community/ voluntary sector and various intermediaries described how £10 is a more significant financial investment for learners or potential learners on benefits or low incomes, and that funding for these learners may be problematic. Some agencies have been reported as paying the £10 on behalf of their client groups.
"It is a barrier, again for someone on minimum income it is a lot of money, I know I see it as a good it's great that people will commit that, you know it's a big chunk out of someone's income or it can be." (Learning Uncovered delegate 5, Formal intermediary interview (2))
5.43 A further argument presented by some learning providers was that the £10 contribution presented an additional administrative task.
"…its time consuming, you've got to make out an invoice, you've got to put it through…for the sake of £10 is it worth it?... there's lot's of work involved for it. I'm not sure it's necessary." (Private provider 1, LP interview (2))
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