Consultation on school, early years and 14-16 funding 2008-11

Consultation Response Form

The closing date for this consultation is: 1 June 2007
Your comments must reach us by that date.

Please tick if you want us to keep your response confidential.

Name

Organisation (if applicable)

Address:

X

Local Authority

Schools Forum

Joint LA and Schools Forum

Headteacher Association

Teacher or Support Staff Union

School Leader

School Governor

Bursar/School Business Manager

Other School Staff

Early Years Provider

14-19 Provider

14-19 Partnership

Parent

Pupil or student

Other (please specify)

Please Specify:

Hampshire County Council

Yes

No

Please Specify:

Comments:

Nursery

Primary

Secondary

Special

Other (please specify)

Please Specify:

Early Years Providers - Private

Early Years Provider - Voluntary

Children's Centre

Please Specify:

X

Strongly agree

Agree

Neither agree nor disagree

Disagree

Strongly disagree

Comments:

This proposal is to be strongly welcomed in encouraging more partnership working for local authorities and their schools to deliver the Every Child Matters agenda.

X

Spend plus

Single Formula

Comments:

There are still significant concerns about the principles of Spend Plus where the formula is based on ministerial judgement. The County Council and Schools Forum supports this in the short term but has significant concerns over a political distribution methodology, and seeks a clearer and more open approach which better represents the Local Government Association principles for defining an appropriate distribution methodology for a specific grant.

Strongly agree

Agree

Neither agree nor disagree

Disagree

X

Strongly disagree

Comments:

Any system using pupil numbers for funding purposes must fairly reflect the number of pupils which authorities provide for. This means that when the number of children receiving education differs significantly over the year a suitable mid-point should be the basis of funding. In respect of the Early Years provision the Early Years Census in January provides this but an autumn count would not. In those authorities (including Hampshire) where the pupils numbers used for DSG purposes would be reduced noticeably the whole system would be at risk. The Early Years Entitlement would still exist but could only be funded by reducing school budgets and that would be constrained by the minimum funding guarantee. Thus at the very least January numbers still need to be used for Early Years.

The consultation paper does consider a hybrid using January early years numbers, but with a one year lag, and an autumn count for all other ages. The comments below address that possibility but conclude that because of the highly destabilising impact on early years funding, a move to an autumn pupil count for any pupils is undesirable.

The proposal to move the pupil count for DSG allocations from the preceding January to the preceding autumn term has attractions if it would increase certainty to local authorities as they plan budgets . However, to implement this significant change alongside a move to three year budgets is considered to carry risks.

These risks include :

· the lack of time to resolve any data quality issues in the first year of a new approach to pupil numbers;

· system problems as there is substantial evidence of a September/ October peak in problems and support calls;

· the unfamiliarity of primary schools with a national data collection exercise at this time;

· the need to change behaviours and culture to ensure that schools give the autumn count the focus that the January count already has;

· unmodelled and unintended redistribution effects;

· potential conflicts between financial impact and admissions policies as regard autumn term part timers;

· changes to school and authority data systems could be needed in a short timescale;

· imbalance with a January Early Years Census.

Accordingly although further examination of any use of an autumn count to apply from 2011 onwards would provide time for many of these risks to be eliminated or managed, it is our belief that the destabilising impact on the early years funding and the lack of advantage form the point of view of time line for budget share allocations, means that the County Council and the Schools Forum favour retaining a January pupil count for all.

X

Headcount

Provision based

Comments:

As indicated above any Early Years count which does not reflect a reasonable mid point for the year as a whole would be very destabilising. Thus these comments are based on the premise that a January count applies.

These changes need modelling. The potential impact on local authorities from these changes is unknown.

The entitlement will be changing from 12½ hours a week for 38 weeks to 15 hours a week for 38 weeks, taken up flexibly. The implications of this are currently being tested in 20 local authorities, including Hampshire, in a pathfinder project with the DfES prior to national implementation by 2010. It is important to learn the lessons from these before changing the system.

Furthermore a link was established in the new school funding arrangements in 2005 between funding from the DfES to local authorities and from local authorities to their schools and providers. Currently in Hampshire there is a diversity, with Reception funded on the PLASC (effectively a headcount) basis and a mixture of place (provision) and pupil numbers termly (claims basis, effectively head count). Whilst PLASC pupil numbers for Reception is probably common practice across the country it is likely that there will be varying practices for the rest of under fives. Accordingly the practicality and desirability of a consistent link between national and local practice in respect of early years needs careful examination.

The preferred approach is the headcount one as this is less disruptive and accords with the main local funding approaches.

Any provision based approach as regards maintained pupils would produce real extra costs in adapting systems to accommodate the extra data that would have to be collected and stored. This would apply at both school and authority level. Any potential benefits from a change to provision based funding for maintained school under 5s, including Reception, are unclear.

Whilst the entitlement changes are being piloted no changes to the current system should be made.

The consultation paper refers to the fact that currently those authorities,

like Hampshire, which are building up their early years participation rates are funded on the basis of an assumed 90% participation rate for three year olds. It is not clear whether this will continue over the 2008-2011 period but if it ceased it would disrupt funding for both early years and schools as it distributed money away from these authorities. Accordingly its retention is advocated.

Current

X

Recoupment

Comments:

It seems that the recoupment method will better avoid local anomalies and should be supported.

There has to be a more general concern at the noticeably higher costs of academies for instance in 2006/07 an additional £33.3m from the national total for DSG was required. In order to ensure that the general funds for all pupils is not unduly squeezed, there is a need to demonstrate that funds for the higher costs are transferred into DSG from elsewhere within the DfES cash limit.

Strongly agree

X

Agree

Neither agree nor disagree

Disagree

Strongly disagree

Comments:

Providing additional funds are moved into DSG from elsewhere within the Department's expenditure limit.

Strongly agree

Agree

Neither agree nor disagree

Disagree

X

Strongly disagree

Comments:

The full methodology for the ACORN and the other commercial data is not likely to be disclosed. On this basis its use can't be modelled or tested, it isn't tried in terms of its long term viability. Local evidence did not support these as being worthwhile for our own distributions to schools in preference to IMD.

Comments:

There should be some proposals to develop measures of rural deprivation which pick up the issues of sparsity and pockets of such deprivation which could work in a formula model.

X

Strongly agree

Agree

Neither agree nor disagree

Disagree

Strongly disagree

Comments:

It is key to ensure the basic amount per pupil is set at an appropriate level. As such the view that more needs to be done to recognise incidence of deprivation within affluent areas is supported. This should be done through a higher basic amount referred to in option two as the threshold basis, and earmarking should not be extended. Funding for deprivation at school level is for local authorities and their School Forums to address.

Per pupil grant

X

Threshold based

Comments:

This would be more effective in targeting terms.

Strongly agree

Agree

Neither agree nor disagree

Disagree

X

Strongly disagree

Comments:

This runs counter to the concept of three year budgets and predictability and stability and introduces a further specific grant into the system. It should not be necessary. Exceptional circumstances should generally be predictable within a three year period for the overall pupil population.

Current method

X

Cash comparison

Comments:

This would be far simpler and more transparent.

X

Strongly agree

Agree

Neither agree nor disagree

Disagree

Strongly disagree

Comments:

We welcome any move to simplify the MFG and therefore fully support the proposal to remove the asymmetry from the MFG methodology.

X

Strongly agree

Agree

Neither agree nor disagree

Disagree

Strongly disagree

Comments:

We fully support this proposal and agree that local authorities and their Schools Forums should be able to take decisions on variations which affect up to 50% of their schools as this allows more local flexibility which is always favourable and beneficial to schools

Comments:

We do not support the proposal to require there to be a majority of both primary and secondary school representatives in favour of a proposal. We believe this would work against the notion that each Schools Forum acts in order to reach decisions which are in the best interests of all maintained schools. There are no other changes to the decision making process on MFG variations that we would like to see considered.

X

1% headroom

Reduce margin

Comments:

As a local authority that has been at the minimum level of DSG and had low levels of deprivation funding, a lower minimum increase in DSG will be unhelpful to us and our schools. We would want to be able to maximise the amount of headroom available to deliver funding into local needs and priorities and so we support leaving the headroom margin at 1%.

Strongly agree

Agree

Neither agree nor disagree

X

Disagree

Strongly disagree

Comments:

We recognise the arguments for taking account of efficiency savings in the assessment of cost pressures, but can see little linkage between efficiency and the areas covered and the reason for having the MFG so it doesn't present itself as an appropriate mechanism to deliver the anticipated outcome.

X

Strongly agree

Agree

Neither agree nor disagree

Disagree

Strongly disagree

Comments:

We would like to minimise the cost of MFG and maximise the headroom available to direct to local priorities. We are confident that we had meaningful and non anomalous protection measures in place before MFG. The MFG has created a new round of local anomalies without improving funding systems. We would like to see a phased and planned reduction in the level of MFG leading ultimately to its removal. Whilst firmly of the view that the overall DSG must more than fully cover all identified cost pressures, we wish to maximize local flexibility. In that context we would therefore support the proposal to set MFG below average cost pressures and would like to see it set as low as possible.

Strongly agree

Agree

Neither agree nor disagree

Disagree

X

Strongly disagree

Comments:

In fact primary and special schools in Hampshire already operate this type of approach voluntarily, by foregoing interest on balances for use in other budgets, and this is the case elsewhere so this change is unlikely to introduce new approaches. The measures introduced in April 2007 need to be given sufficient time to have an impact and then the position should be reviewed. A levy on balances is therefore not supported.

It will however be critical that future levels of DfES funding (a particular cause of balances has been various additional grant top ups) are more certain over the medium term and announced early in the financial cycle as late announcements of extra funds tend to increase balances.

Strongly agree

Agree

Neither agree nor disagree

Disagree

X

Strongly disagree

Comments:

There are real issues as to their accountability to the whole community of schools. If such a measure was proceeded with they would have to be approved by the whole community of headteachers and a reporting mechanism to that group adopted.

Strongly agree

X

Agree

Neither agree nor disagree

Disagree

Strongly disagree

Comments:

This should be achieved by way of strong advice not legislative action. The Schools Forum in Hampshire has always had two Early Years representatives. Consideration needs to be given to whether 14 to 19 Partnerships need voting rights as opposed to observer rights.

The County Council retains its preference for the Executive Lead Member for Children's Services to be able to be a formal member of the Schools Forum. (Regulations have prohibited this since August 2006.) This membership reflects the considerable responsibilities which fall to the Lead Member and the important role of schools in the implementation of the Every Child Matters agenda.

X

Strongly agree

Agree

Neither agree nor disagree

Disagree

Strongly disagree

Comments:

Wider representation of the 14 to 19 and early years sectors is unachievable for many Forums within the current restrictions. However a maximum above 30% is likely to change the schools' focus.

Strongly agree

X

Agree

Neither agree nor disagree

Disagree

Strongly disagree

Comments:

In the short term (2008 - 2011) this is clearly necessary in order to establish partnership provision as an standard option at KS4. In the long term such funding should be within school budgets so that they can tailor the curriculum to the individual needs of each student through partnership with other institutions.

It will be essential to local delivery for a simple, single and clear approach to the additional transport costs involved in 14 to 16 diplomas to be reflected in the specific grant arrangements.

Comments:

Yes. They represent an appropriate range from total central control to total delegation with the option of compromise where funding is held centrally to which schools contribute in order to access tailored provision.

X

Strongly agree

Agree

Neither agree nor disagree

Disagree

Strongly disagree

Comments:

Progress on the implementation of the14-19 agenda varies considerably across the country and within local areas. The level of delegation will need to vary with the maturity of partnership working. In addition to this, large shire counties, such as Hampshire, have a responsibility to ensure entitlement across a large and diverse geographical area and need to be in a position to commission provision where it does not develop within partnerships. Local discretion is vital in using this funding to best effect.

Strongly agree

X

Agree

Neither agree nor disagree

Disagree

Strongly disagree

Comments:

A methodology which is transparent and equitable is a vital component and 14-16 is an increasingly complex curriculum area. The LSC funding methodology is already in use and it, therefore, seems sensible to employ it in this way. Local discretion in relation to deprivation, rurality, transport and other factors is, however, important.

Strongly agree

Agree

Neither agree nor disagree

Disagree

X

Strongly disagree

Comments:

We agree there should be a comparable level of funding in maintained and PVI settings, but creating a standardised method for calculating the unit of funding in maintained and PVI settings is complex and may not deliver better outcomes. To have it in place for the coming CSR period is impractical because the new entitlement will be rolling out through this period and will not be complete until 2010. Thus 2011 would be the appropriate date should it be implemented. Furthermore Year R pupils who have been formally admitted through the primary school admissions process need to be considered in the context of primary school funding more generally. Thus such standardisation should not include them.

Comments:

At least two years. This is because the PVI sector is fragmented, volatile, less robust and many settings lack confidence and expertise in funding approaches. We believe that the changing nature of the entitlement makes 2011 the earliest sensible operational date.

It is also noted, that special schools are not covered anywhere within the consultation .

Strongly agree

Agree

Neither agree nor disagree

Disagree

X

Strongly disagree

Comments:

We agree local authorities should aim towards using the same methods to calculate pupil numbers in maintained and PVI settings. Similar count methods may be needed and certainly different count dates can lead to double funding or no funding. To have it place for the coming CSR period is impractical because the new entitlement will be rolling out through this period and will not be complete until 2010.

Again Year R pupils who have been formally admitted through the primary school admissions process need to be considered in the context of primary school funding more generally. Their count method has to relate properly to that for Years 1 to 6 as they are in the same establishments.

Strongly agree

x

Agree

Neither agree nor disagree

Disagree

Strongly disagree

Comments:

This has to be true for Year R pupils. In the case of nursery school and unit pupils, flexibility at local level with the freedom to decide whether one or more dates is suitable is the better solution.

Places

Termly estimates

X

Guaranteed Minimum

Other.

Comments:

Option (b) - termly estimates is the least preferred option. The guaranteed minimum option (c) is probably preferable to Option (a) as it is likely to reduce the risk of unfilled places. In any case to have it in place for the coming CSR period is impractical because the new entitlement will be rolling out through this period and will not be complete until 2010.

Strongly agree

Agree

Neither agree nor disagree

X

Disagree

Strongly disagree

Comments:

Not necessarily.

Comments:

Over two years but not until the new entitlement is fully in place in 2010.

Comments:

Change and development are inevitable. Guidance based on successful local practice would be useful.

Strongly agree

Agree

Neither agree nor disagree

X

Disagree

Strongly disagree

Comments:

There is a concern to secure greater transparency across the sectors. However any separate identification that included Year R funding is likely to confuse rather than clarify. The balance between sectors and dates of admission to primary school vary. This can probably be best achieved locally on the basis of case studies of good practice.

Strongly agree

X

Agree

Neither agree nor disagree

Disagree

Strongly disagree

Comments:

In principle we support the proposal to merge SSG and SSG(P). One basis for data and distribution will be easier to understand and manage for both schools and the local authority. However, we would be worried about individual schools losing out. Some schools acquired very anomalous SSG allocations when the move from banding occurred and we would not want them to be protected on figures which do not bear any relation to need. The transitional arrangements should be short and clear so that everybody knows the cost of transition and can model it for the three years 2008-2011.The funding for transition would have to come from the money already budgeted for SSG or elsewhere within the DfES budget as a top slice from main DSG would go counter to the clear government policy of the additionality of SSG.

Cash (0%)

X

Below 0% DfES

Comments:

We share the long term aim to merge SDG into DSG, but recognise that transition issues make it impossible in the short term. We welcome the wish to move SDG away from current historical basis to one which more closely reflects need. We support option (b) which would allow for greater local flexibility but would ensure no school lost more than a given amount of its 2007-08 SDG allocation by using a small negative floor.

Strongly agree

Agree

Neither agree nor disagree

X

Disagree

Strongly disagree

Comments:

Although the task may seem an administrative burden that is a price worth paying for a retention of the principle of local authority based school funding and comparability. This would be particularly important if moves to bring more grants into the main funding formula occur.

Comments:

Notification of DSG

In view of the fact that the DfES has already received it's SR 2007 control total, an early announcement of DSG by October is sought to enable authorities to prepare their schools three year budgets in a timely manner.

Supported Borrowing

The consultation fails to acknowledge the issues related to the removal of funding for supported borrowing. This funding issue needs to be resolved for this coming spending review period if full borrowing approvals for schools capital projects are to be taken up by local authorities. Options include: making a floor adjustment, allocation of a new capital grant or allowing future borrowing costs to be reflected in DSG.

Three year budgets

This consultation has not addressed some of the detail of producing three year budgets. For example will all three budget shares be required by the same deadline in the first year? Will complete Section 52 Statements (S52) for all three years be required in the first year? Hampshire would like to take this opportunity to express our worry about how realistic it is to produce three sets of detailed budget shares and three S52 statements by a 31 March deadline. We would like to suggest consider staggering the deadlines for the different years, so that whilst the 2008-09 budget shares and S52 should be published by 31 March 2008, there should be a delay in the deadline for the budget shares and S52 of the forward years. This would ease pressure on staff at what is already a very busy time and would enable us to be able to more realistically meet any deadlines set.

Year R pupils

The consultation seems to confuse the position of Year R pupils with other under fives.

Single pupil count

The consultation takes for granted the single pupil count. our experience indicates that this issue needs further examination.

Comments:

As our comments above in 39 show we are not convinced that all the relevant questions were included.

X Yes

No