The Department for Education’s long-running review of post-16 qualifications at level 3 in England came to something of a head this month with the publication of its response to the latest consultation. Sadly, though, despite lots of discussion and engagement and high numbers of responses, a consensus has not been achieved on what is a complex policy arena. Indeed, in many areas, the proposed policy was opposed by a majority of the respondents, but it would be wrong to simply put that down to a reluctance for change.

My overarching concern is that the proposals risk leaving many students with no realistic option to study at level 3 in the rush to ensure the success of T levels. Colleges generally are happy with the DfE ambition of “ensuring that as many young people as possible benefit from our rigorous, employer-led T levels” because they look likely to work well for many young people and employers in many sectors. They are also attracting financial support from the government to support their development and implementation, which will probably continue.

The phrase “as many young people as possible” is worth unpacking here, because on the one hand it allows for a different mix of qualifications for adults and on the other for qualifications to be available to meet the full needs of young people and employers. This is where the main difficulties with the proposals flood in because there is a marked difference of opinion between those who think T levels will meet most of the needs and those who think there will still need to be a large number of other qualifications at level 3 to cater for all.

The reality is that none of us really know what that balance needs to look like, given that many T levels are yet to be designed, let alone implemented. It’s important to recognise that the DfE has rowed back from earlier proposals that the system would be binary, with only T and A levels funded. Critics would argue that it has not rowed back far enough because of the concept that any other qualification that “overlaps” (whatever that means) with a T level will no longer be funded.

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Our response pointed to the two fundamental barriers to implementing T levels: firstly the need for 45-day industry placements for every student in the sector of the T level, accessible nearby in all parts of the country. That may be possible one day (although I doubt even that) but it is risky to presume that it will be achievable before T levels are an established “brand” with employers, in every sector. The second barrier is that to achieve a T level students will need to achieve at least a grade 4 in GCSE English and maths (unlike for A levels or higher education entry).

T levels: The risk of defunding other technical qualifications

Currently, over 25 per cent of applied general qualifications students do not achieve that, so it would be wrong to put those students in the future on to a T level because they would not pass.

We also criticised the approach as being one of taking a sledgehammer to crack a nut. If T levels truly are going to be the new gold standard, then they will not need other qualifications to lose funding. A positive approach, moving as fast as the T-level numbers grow, would show faith that their quality will win by attracting students and employers to use them, rather than forcing things, with all of the risks involved.

Our focus now is to try to influence the criteria government will use for agreeing which other qualifications are available. We want the criteria and the process to be fair, transparent and reasonable. We will support criteria that ensure “that qualifications within the new landscape are high-quality and will lead to strong outcomes for every student in terms of further study and employment”. That seems fair enough, and should allow for a mixed economy of qualifications at level 3, including A levels, the new T levels and many existing qualifications (from the 232 that make up 90 per cent of those used by colleges).

This all matters so much to hundreds of thousands of students every year. We have urged ministers to back their belief in T levels and to take the time to allow T levels to grow and become respected and understood by employers, parents and students. Colleges are keen to use them and will make them work because they have the potential to improve the reputation and standing of technical education if they are implemented properly, alongside other qualifications.

We don’t need a strong-armed approach to force change - that change will happen if it is given the time and the space. Doing that will ensure that all students in all parts of the country are able to find the right course for them and their aspirations. The FE White Paper talked up the need for more collaboration in post-16, so I hope that DfE lives by that on this change programme.

David Hughes is chief executive of the Association of Colleges