Are you ready for Functional English? Well it’s coming to a school near you soon. And you will probably be delivering it. We don’t know how yet. I don’t think the Qualifications and Curriculum Authority, which is formulating the qualification, knows yet either. But we’ll all be at it by 2009.

There will be separate tests in Functional English to run alongside GCSE, though the QCA says the aim is for the test to be flexible enough for anyone to take it at any time from the age of 11 and beyond 19. How this will happen in logistical terms is yet to be decided, as are the methods of assessment. The proposed mark scheme is not a compensatory or best-fit one as is the case at GCSE. If you can’t prove you meet all the criteria for a certain level, you don’t achieve it. The gold standard for achievement is “level 2” which is supposed to equate to national curriculum level 6, or grade C at GCSE.

If your students can’t use apostrophes and inverted commas correctly, they won’t achieve the desired level of “functionality” and won’t pass at level 2I which means they won’t be able to get a C or above in their GCSE English language either. Anyone worried yet?

It appears that employers have driven this initiative believing a good grade in GCSE English language does not necessarily reflect an adequate level of linguistic “functionality” for the workplace. No concrete evidence, however, has been given to support such a position. Without models of the perceived failings of the current provisions within English, it is hard to see how the profession can respond in any meaningful way.

Who is expected to deliver Functional English? If it is to be teachers of English, what will be omitted from the already overcrowded curriculum in order to make time for it? If it is something that can be assessed within the current English curriculum, what is the point of it?

There will be many professionals subjected to meeting employers’ targets who are experienced, creative and thoughtful practitioners able to adapt their work - if indeed this is necessary - but they are insufficient in number to deliver this mandatory qualification effectively. Functionality will end up being taught separately and in a decontextualised way.

Those who have experience of delivering key andor basic skills know that bolt-on courses with functional purposes serve neither pupils’ nor teachers’ interests. Research has shown that literacy is best developed in a meaningful context, so that work-related literacies are best developed in the context of the workplace and not in the classroom.

In one sense, this proposal is a bold move by the Government. It would be churlish not to support efforts to help students punctuate accurately. It is something that is already taught at both primary and secondary stages.

However, to be able to punctuate is only a very small part of what it is to be a competent user of English yet it is proposed that no one will pass Functional English at level 2 unless they can “punctuate accurately using commas, apostrophes and inverted commas”. Although both punctuation and presentational skills are important, a preoccupation with them could prevent many candidates who are talented in other areas of English from being seen as “non-functional”, with the consequent loss of confidence and self-respect that comes from being labelled as failing in one’s own language. Are the QCA and by extension, employers, seriously arguing that people are linguistically “non-functional” if they cannot master certain aspects of punctuation? And, by the way - can anyone explain to me what “non-functional English” might be?

Ian McNeilly is director of communications and development at the National Association for the Teaching of English www.nate.org.uk