NIACRO’S RESPONSE TO DEL CONSULTATION PAPER

TRAINING FOR SUCCESS:

Professional and Technical Training

                             September 2006

1 Introduction

NIACRO, the Northern Ireland Association for the Care and Resettlement of Offenders, is a voluntary organisation, working for 35 years to reduce crime and its impact on people and communities.  NIACRO provides services under the headings of: promoting safer communities; working with children and young people who offend; providing services to families and children of offenders; supporting offenders and ex-prisoners in the community; working with prisoners. 

NIACRO works in partnership with all the main criminal justice agencies in Northern Ireland. 

 We welcome the opportunity to respond to DEL’s consultation document “TRAINING FOR SUCCESS: Professional and Technical Training” 

 NIACRO. has over 30 years experience in working with service users and relevant organisations in the field of training and employment. This work is core to the organisations crime reduction strategy and is based on substantial research that clearly demonstrates the co-relation between unemployment and offending behaviour. 

 The experience from both Adult and Youth employability programmes demonstrates the importance of flexible, individual needs- led models which offer a range of interventions to support individual progression. Such an approach has proven successful in recruiting and sustaining Offenders and those at risk of offending who are disproportionately represented within the most socially excluded, low skilled, long term unemployed.

 NIACRO currently operate YOUTH EMPOLYABILITY, an employability programme targeting young people aged 15-17 who have been involved with the Criminal Justice System in partnership with the NIO; PBNI & YJA.

AIM: “to increase the employability of Youth Offenders”

The primary objective of YOUTH EMPLOYABILITY is to provide appropriate / relevant assessment of need/motivation/ability and offer intensive support to progress participants onto a range of training and /or employment opportunities. The partnership agencies view this approach as crucial given the negative experiences many young offenders have of formal education and training provision. In essence our experience is that young people coming through the Criminal Justice system will not immediately engage with or are unable to sustain the mainstream Jobskills programme. Instead there requires a more flexible and phased approach to engagement and progression.

Whilst NIACRO is concerned in general at the inadequacies of the existing arrangements for young people who are unemployed its main focus of concern, and the basis of this response, will be in relation to a particular target group ie offenders and young people involved in the Criminal Justice system.

2. Response to Consultation:

2.1 Underlying Principles

NIACRO welcomes the principles on which the new proposals presented in this consultation paper are based. In particular  the recognition at ministerial level that “a one size fits all” approach should be eradicated with the needs of the learner becoming paramount and a focus on  particular groups who experience multiple barriers in entering the labour market are key messages that NIACRO have long since advocated for.

Therefore, NIACRO supports the key findings from informal consultation but would have a range of concerns in relation to the proposed implementation framework presented. These are presented and discussed under thematic headings.

2.2Themes

2.2.1Apprenticeships

NIACRO welcomes this focus in the expectation that this will address sector skill shortages. Significant emphasis is placed on the participatory role of the Sector Skills Councils in realising these proposals. However the extent of their involvement to date and commitment into the future is unclear. It is imperative that the Sector Skills are committed and actively contribute to the realisation of this new apprenticeship model.

NIACRO would encourage DEL to develop this model in cooperation with the NIO to ensure delivery of such within all adult prisons and Juvenile Justice Centre. This model would provide those in custody with the opportunity to participate in training relevant to labour market needs and therefore increase employment opportunities on release. Where training was not completed within the custodial setting then systems should be established that would link individuals to local training organisations or community provision, to enable completion, immediately upon release.

NIACRO questions which Department will have responsibility for the development of apprenticeships within the school system – this is particularly important with regard to placement with employers.

2.2.2AgeRange

The extension of provision of vocational training for school age (14-16) should encourage those young people who are less academically able to undertake courses which will focus on and lead to future employment opportunities. If this approach supports and motivates young people to stay in school and thus reduces levels of truancy /drop-out /low achievement then NIACRO views this as a positive contribution to reducing offending behaviour.

Whilst supporting a more flexible approach NIACRO does not believe that the proposals, as set out, accommodate the needs of those young people who are not ready to decide on career option at age of 14 or who do not have the necessary skills levels to do so.

The inference made within the report to age range extending to include adults requires more detailed explanation. Is the view of the Department that this new model will replace New Deal & other existing adult provision? If relevant and sufficient commentary is to be made then this issue needs to be presented in similar detail incorporating financial/funding implications/proposals/structures

2.2.3Joined Up Approach

The move to a more joined – up approach by two key Departments – DEL and Department of Education is welcomed The Consultation document, whilst noting greater collaboration between the Departments does not provide any indication of whether or not this proposal has been agreed with Department of Education nor does it detail implications for funding arrangements. It is expected that such changes to school curriculum (timing of Careers Advice) will have major implications yet this report does not determine if necessary changes/agreements have been reached.

In short, the fundamental question is what is the enabling mechanism that allows the above to happen. It is NIACRO’s view that without such the proposal is untenable.

The proposals to develop/expand Modern apprenticeships with greater emphasis on the role of employers are considered by NIACRO as fundamental to improving arrangements and opportunities for young unemployed. However, our experience in working with Employers across sectors shows a general reluctance or hesitancy and lack of understanding to engage with individuals who have criminal convictions.

In relation to these particular proposals such actual barriers may well be exacerbated as any changes to current arrangements, particularly in relation to 16-18 year olds may place greater legislative requirements on employers.

If under the proposed new apprenticeship arrangements employers become responsible for recruitment of 16 year olds there will be discriminatory practice and a lack of consideration about circumstances of convictions, which may preclude young offenders from previously accessible training positions available under the traineeship route.  

NIACRO operate training in Fair Recruitment and an Advice Line as a specialist support service. If the Departmental focus is to encourage /promote employment opportunities for Offenders then significant work is required to realise such with employers and the specialist services of NIACRO should be integral to such.

2.2.4Specialist Groups

Reference to training frameworks and “Expert Panel” (p9) is ambiguous and raises questions as to the process/basis for selection. NIACRO expects that representation would include all sectors including that of NGO. A fundamental concern is the question of who will deliver services to such.

Our experience of the introduction of P2W was that key specialist agencies would be able to provide services. As it happened agencies near to the core of the Criminal Justice System were not appointed, yet in the outworking of the programme NIACRO has been invited by a number of P2W delivery agents to provide specialist advice and training (on an ongoing basis.) Thus the expectation was for NIACRO to provide this service without financial renumeration.

NIACRO would expect that the proposed changes will provide the Department with the opportunity to reassess current providers and widen its scope of specialist agencies even on a sub – contractual arrangement.

2.2.5Funding

I.Education Maintenance Allowance – it would appear that this proposal is detrimental to current arrangements and to participants. EMA was introduced to encourage young people from low income families who wish to pursue academic qualifications to stay on in school.  The allowance is awarded to cover the cost of travel, books and equipment. It should also be noted that EMA is means tested and in our view this could act as a deterrent to young people from higher income families participating in the programme.

The example of family income given on page 16 is misleading in that the EMA will be paid directly to the young person and will not form part of the family income.

II.Output Related Funding – NIACRO is disappointed to note that the principle of flexibility inherent throughout this report does not relate to funding arrangements. ORF has proven extremely unsatisfactory for organisations working with less motivated, less skilled and therefore most socially excluded individuals. This system does not address the difficulties associated with those young people who perpetually “drop – out” of mainstream training provision and formal education systems and yet are the very cohort that the Department seek to engage with. Such individuals require ongoing, intensive support but the ORF funding arrangements do not support necessary investment through financial incentives for organisations such as NIACRO to do this vital work.

Whilst recognising the importance of financial incentives for employers NIACRO sees the proposed contributions as inadequate particularly at level 2. Individuals at this level will likely be amongst the most difficult cohort; therefore employers will require a great deal of assistance and encouragement to engage on an ongoing basis.

III.Travel– The proposed travel payments undoubtedly take account of differences between urban and rural circumstances. However they do not acknowledge those areas where either training provision or employment opportunities are limited. NIACRO’s experience demonstrates that where individuals have to travel outside of their immediate localities and are financially disadvantaged in doing so that this will decrease levels of motivation & participation.

A more flexible approach should be taken in this regard based on individual and local circumstances and agreed action plans.  Unemployed individuals should not be financially disadvantaged in their endeavours to increase skills and employability opportunities.

2.2.6Time Frames

Addressing Barriers – the consultation paper alludes to “short provision” to address particular difficulties however it is not clear what the proposal is with regard to time frame for such. Given the multiple difficulties many offenders experience NIACRO would warn against a “quick fix” approach. This period must reflect and allow for the individual and flexible approach that the Department commits to throughout the paper.

It is also unclear from the consultation paper whether or not individuals will be supported and permitted to re-enter programmes should they leave or “drop out”. Given the points previously noted regarding difficulties associated with working with offenders NIACRO believe that it is crucial to promote and accommodate re-entry as quickly as possible.

Given such it is questionable as to how effective ORF will be in the support of this more intensive, flexible approach. 

2.2.7 Consultation & Implementation Process

NIACRO is particularly disappointed regarding the time frame for consultation and proposed commencement of tendering process as stated on p19. Given the very limited period between such it would seem that the Department has already taken decisions in this regard and therefore genuine and meaningful consideration of responses made will not happen.

It is unfortunate that the Department has not learnt from previous experience in this regard.

3. Conclusion.

NIACRO welcomes the principals on which these new proposals are based and particularly a more flexible and needs-led programme. The emphasis on the involvement of Sector Skills Councils and Employers should go some way in addressing relevancy of training provision to meet labour market needs.

However, it is the view of NIACRO that the proposals outlined in the consultation document do not go far enough in addressing the complex needs of young people who are socially disadvantaged as a result of their offending behaviour or criminal convictions.

NIACRO hopes that the points presented are a useful contribution in this debate and would welcome a further engagement to elaborate on the points made.

20^th September 2006

 Amelia House

4 Amelia Street

BELFAST 

BT2 7GS

Tel: (028) 90 320157

Fax: 07870432141

www.niacro.co.uk

Mr Tommy McVeigh

Training Programmes Branch

Department for Employment and Learning

Lesley Buildings

Fountain Street

Belfast

BT1 5EX  

Dear Tommy

I enclose NIACRO’s response to the consultation document “Training For Success: Professional and Technical Training.”

This issue is of particular concern to NIACRO given our experience in delivering employability programmes to Young Offenders and those at risk of offending, in partnership with key Criminal Justice agencies.  The learning from this experience clearly demonstrates that young people coming through the Criminal Justice system will not immediately engage with or often are unable to sustain mainstream programmes such as Jobskills. Instead there requires a more flexible and phased approach to engagement and progression.

A model which affords flexibility and provides relevant assessment of need, motivation, and ability and offers intensive support to ensure individual progression is in our view crucial to positive engagement with Offenders. This is particularly prevalent (but not exclusive) to young offenders the majority of whom have very negative experiences of formal education and training provision.

NIACRO hopes that the points presented are a useful contribution in this debate and would welcome a further engagement to elaborate on the points made.

Yours sincerely

HEATHER REID

SERVICES MANAGER

Northern Ireland Association for the Care and Resettlement of Offenders

Recognised by the Inland Revenue as a charity XN 48280 Company Limited by Guarantee No. N.I 18121.

President: Lord Hylton. Chairman: R. Buchanan. Chief Executive: O.Lyner.Chairman Finance Committee: Patrick L Farry BSc.FCCA