UVAC Response to the:Draft Strategic Guidance to the Institute for Apprenticeship

UVAC is the not-for profit national higher education representative organisation established to champion higher level vocational learning. UVAC has approximately fifty Higher Education Institutions (HEIs) in membership, drawn from all mission groups, and works closely with HEFCE and SFA to ensure HEI can play a full role in the development and delivery of Higher and Degree Apprenticeship on the basis of employer demand. UVAC welcomes the establishment of the Institute for Apprenticeship. We look forward to working with the Institute and the higher education sector to ensure employers can use and benefit from the significant range of Higher and Degree Apprenticeships developed by employers through the Trailblazer process.

We would offer the following general comments:

  • The draft strategic guidance does not sufficiently emphasise the role of the Institute for Apprenticeship as an independent ‘employer body’ championing ‘employer interests’ and ensuring the Apprenticeship system will deliver the apprenticeships employers demand and the apprenticeships needed to enhance social mobility and productivity. Will the Institute have a vision for the Apprenticeship system of the future? How will the Institute work with and indeed challenge the Government or SFA?Will the Institute be asked to produce an annual review on the implementation of the Apprenticeship reforms and their impact on productivity and social mobility?
  • Our experience to date from contact with the shadow Institute for Apprenticeship suggest that it is developing (following the SFA example) as a body that is focused on and prioritises the development of Apprenticeship delivered by further education providers rather than range of Apprenticeships at levels 2 to 7 being developed by employers through the Trailblazer process. The inaccuracies and omissions in the draft guidance e.g. not referring to HE quality assurance (paragraph 5) and not mentioning the integrated degree apprenticeship (paragraph 13) illustrate this point. If the IfA is to effectively support the delivery of the Apprenticeship reforms it should champion Apprenticeship as an employer led programme available at levels 2 to 7 and delivered on the basis of employer demand by a range of providers; independent training providers, colleges and universities. Key to its role should be to ensure employers have the range of Apprenticeship programmes available that are needed to develop their workforce. One of the key challenges for the IfA will be to challenge and work with the SFA to ensure the substantial barriers to market entry (widely reported and analysed) to the Apprenticeship market for new providers of Higher and Degree Apprenticeships, particularly HEIs are overcome.
  • In the development of its staff base the IfA will need to ensure it has a comprehensive knowledge and understanding of skills and Apprenticeship at all levels. Key will be developing anunderstanding of the role of Professional, Statutory and Regulatory Bodies (PSRBs) and the operation of higher education systems and approaches to delivery which differ markedly to further education delivery at level 2 - 5. The IfA will also want to develop as an outward focused learning organisation with a desire to seek out UK and international good practice in the development of learning programmes that develop occupational competence. Building on UK and international good practice we would imagine the IfA will want to create one of the best Apprenticeship systems in the world.

Putting Employers at the Centre of Apprenticeship Quality

Rightly, employers should lead the development of Apprenticeships and define knowledge, skills and behaviours required for specific occupations. We would, however, note a number of issues with the current implementation of the Apprenticeship reforms:

  • Some Apprenticeship standards and assessment plans have been developed by Trailblazers with insufficient consultation with providers. Providers and assessment organisations need to be involved to advise on the feasibility and affordability of both training delivery and assessment. Few employers have sufficient expertise to develop appropriate approaches to assessment and in many cases such responsibility rests by practice or statute with other organisations, HEIs and PSRBs being good examples. Employers will often not be aware of new pedagogic approaches to the delivery of training programmes and new opportunities in using blended learning, peer based learning and innovative approaches to work-based learning and assessment. We believe it will be important for the Institute to emphasise the importance of profound and early engagement of both training providers and assessment organisations by Trailblazers.
  • We acknowledge that as an employer led organisation the IfA Board will comprise employers. To ensure the successful implementation of the Apprenticeship reforms the IfA will, however, need to engage training providers on a systematic and regular basis. Such engagement should be based on employers’ likely future demand for Apprenticeships and not on the historic patterns of how SFA has fundedapprenticeship training providers, which has an inherent bias to level 2 training provision. PSRBs will also need to be engaged in the work of the IfA and their presence on any provider stakeholder board would add considerable value. The engagement of Apprentices (paragraph 15) will ensure engagement of the other key beneficiary of the Apprenticeship reforms.

We note the Institute is being established to act‘as the guarantor of the apprenticeship system’. We would question whether the core statutory functions set out for the Institute (paragraphs 6 and 7) will by themselves enable the Institute to fulfil this function. Setting quality criteria for apprenticeship standards and assessment plans, ensuring end point assessments are quality assured and advising on the maximum level of Government funding available for standards are vital functions, but will not in themselves guarantee the development of an apprenticeship system that delivers the apprenticeships employers require or the Government’s Apprenticeship policy objectives of increases in productivity and social mobility.

As we outline in our comments on paragraph 6,Apprenticeship is changing in many ways. One key change involves a movement upwards in employer interest in Apprenticeship from the lower level Apprenticeships in roles such as business administration and customer service to Higher and Degree Apprenticeships in occupational areas (digital, engineering, construction, management, nursing, social work etc.) which when used will make a major impact on productivity and social mobility. Indeed, 35% - 40% of Apprenticeship standards developed by Trailblazers have been developed at HE level. Not specifically asking the IfA to establish a vision, or plan and report back on how Apprenticeship is making an impact on productivity and social mobility or the industrial strategy and employer satisfaction with the Apprenticeship ‘system’ seems a missed opportunity. The change required here should not be under-estimated. The trailblazer process has truly put employers in the driving seat in the development of Apprenticeship, but the delivery structure being fostered and managed by the Skills Funding Agency is based on process developed for lower level apprenticeships in ‘occupational’ areas such as business administration and customer service which have a minimum impact on productivity. SFA systems are acting as a substantial barrier to market entry for the providers needed to deliver the Higher and Degree Apprenticeships employers will demand, as demonstrated through the Trailblazer process.

Role of the Institute for Apprenticeship

Paragraph 5 - Only quoting Ofqual and Ofsted does not reflect quality assurance arrangements for the range of Apprenticeship provision employers have identified, through the Trailblazer process, they want delivered. A significant proportion of Apprenticeship standards (35% – 40%) have been developed at HE level and not to reflect the organisation with statutory responsibility (HEFCE and its sub-contractor QAA) for quality assurance for HE and therefore Degree Apprenticeships is an omission. Such an omission undermines and contradicts the employer ownership and focus of the Institute – it could be seen to imply that one type of Apprenticeship is more important or significant than another. Could this omission be corrected?

Paragraph 6- We would question which organisation will have responsibility to ensure the provider base for Apprenticeship is able to deliver the Apprenticeships employers will demand. To date SFA has, on most occasions, acted as a further education funding agency rather than a 'skills' funding agency. As examples, data reporting is based on the Further Education based ILR (not HESA requirements), quality assurance often assumes Ofsted oversight when Ministers agreed QAA/HEFCE oversight, sub-contracting requirements reflect past FE experience not the HE Quality Code, funding rules are based on earlier FE approaches and provider support is commissioned through the further education owned Education and Training Foundation. The SFA focus and prioritisation on further education process which either duplicates or is incompatible with higher education process has acted as a substantial barrier to market entry for HEIs and for HEIs to gear up to respond to the potential employer demand for Apprenticeships at levels 4 to 7. As the institute will act ‘as the guarantor of the apprenticeship system’should not the Institute have a role in ensuring the SFA develops the provider base needed to respond to employer demand for a full range of Apprenticeships at levels 2 to 7?

The Strategic Guidance

Paragraph 8 – There is the potential for substantial tension between a focus on supporting high quality apprenticeships and the aim to deliver three million apprenticeship starts. In the past targets have resulted in an explosion through the LSC/SFA system of low cost level 2 Apprenticeships in areas (some retail, customer service or business administration apprenticeships) which have little impact on productivity or social mobility. In 2013/14 65% of Apprenticeship starts were at level 2. This is not a focus that will enable UK business to increase productivity and compete with our OECD and BRIC competitors. If the focus of Apprenticeship is productivity and social mobility the emphasis must be on quality and not quantity.

Paragraph 9 – The 15 technical educational routes are restrictive, may not reflect likely future employer demand for skills and do not necessarily translate to employer interest or demand for Apprenticeships at higher levels (level 6 and 7). The route titles translate poorly to level 6 and 7 occupations that employers have and are focusing on the development of Apprenticeships e.g. management, nursing, social work, logistics, policing etc. A separate route for hair and beauty – but no specific reference to the above occupations hardly demonstrates a focus on the occupations vital to enhanced public service or UK productivity. It will be important for the Institute to include a focus and ensureApprenticeship at level 6 and 7 are appropriately supported and that there is not an over emphasis on technical education (whilst of fundamental importance) vis-à-vis professional and higher education. An over focus on the 15 technical educational routes particularly in the way they are titled could severely restrict the potential of Apprenticeship to deliver the cutting edge skills employers will demand in new and emerging sectors of the economy critical to business performance and productivity.

Paragraph 13 – This paragraph is inaccurate as it does not reflect the existence and potential to use an 'integrated degree apprenticeship' where the degree also acts as the end point assessment. Several integrated Degree Apprenticeships are already delivered and we are aware that employers in some very significant occupational areas such as social work, policing and nursing where employersare interested in adopting this model.

Standards development and approval

Paragraph 15– Preparation of apprenticeship standards and assessment plans through the Trailblazer process has generally been very successful. We are, however, aware that sometimes there have been substantial delays in the process of development that do need to be tackled. We are also aware that there are ‘gaps’ in the development or availability of standards that may be critical to productivity in some sectors. Based on the industrial strategy and clear evidence of skills needs (based on productivity or the provision of public service arguments) could the Institute help foster and support employer and provider groups establish trailblazers?

Paragraph 17 – Reference is needed to PSRBs which will have a pivotal role in determining the appropriateness of Apprenticeship Standards and Assessment Plans.

Paragraph 18 – Apprenticeships go further than technical education. If employer demand is to be met and Apprenticeship is to realise its full potential in raising productivity the Institute should ensure technical education routes do not distort the approval and development of ‘professional’ level Apprenticeships at level 6 and 7.

External quality assurance

HEIs operate in the context of a well-defined and internationally defined QAA code. This code is internationally recognised. The IfA would, we believe, find it of considerable value to explore the varied and proven approaches to end point assessment HEIs and PSBRs have adopted to demonstrate occupational competence outside of the Apprenticeship system. As with other sections of the draft guidance paragraphs 19 – 20 are written from an FE stand point.

Paragraph 23 – The Institute will need to liaise and work closely with HEIs re Degree Apprenticeship certificates and the legal protection conferred to ‘Degree’ and ‘Apprenticeship’ awarding arrangements.

Paragraph 25 – We are surprised no reference is specifically given to the impact on productivity in the context of the industrial strategy. A key purpose of the Apprenticeship reforms was to enhance productivity. In the past a desire to grow Apprenticeship numbers has focused on a vast expansion of many arguably low quality apprenticeships in retail, customer service and business administration and relatively little growth in STEM areas and key public sector occupations. Is such growth something the Institute should guard against in the future? Should the Institute be asked to consider productivity and improvements in public service provision in the advice provided?

Paragraphs 30 and 31 - We fully support the concept and establishment of the Quality Partnership. PSRBs will also have specific roles in terms of quality. How will the Institute work with PSBRs?

Paragraph 33 - We strongly support plans to engage apprentices. It is, however, important that such approaches reflect the range of individuals following apprenticeship programmes which will include 16 and 17 year-olds following level 2 programmes to adults completing professional qualifications and masters’ degrees through Apprenticeships at level 7. One of the issues the Institute may wish to consider is how Apprenticeship supports individuals develop transferable skills to support progression throughout their careers and the individual as the customer of the Apprenticeship. Key here is how an Apprenticeship particularly at level 2 or 3 is recognised and supports progression to higher level Apprenticeships, higher education and professional qualifications. UVAC has long argued for clear, understood and available work-based progression pathways through craft (level 2), technician (level 3 - 5) to professional (level 6 – 7) job roles

Overseeing a Fair and Open System

Paragraph 34 - As outlined earlier we believe the Institute needs to ensure employers can utilise the type of provider needed to deliver the Apprenticeships required by their organisations. To date the processes developed by SFA have acted as significant and unnecessary barriers to market entry for new providers, particularly HEIs. We trust that the Institute will be able to challenge the Skills Funding Agency so that in its role in Apprenticeship operational system it moves away from operating as ‘the funder for skills training for further education (FE) in England.’ (SFA Website accessed 18/1/17) to a position where it develops process that ensures employers will have available the provider base to deliver the Apprenticeships they will demand.

Some of the services developed by the sector bodies described in the draft guidance have proved useful in developing the market for new Apprenticeships – the development of these services has also been fostered (not discouraged) by the Apprenticeship reforms. We do, however, believe there are ‘issues’ in the development of monopoly service and unregulated charges for market entry levied by such organisation. The Institute will need to consider the relative value of these services vis-à-vis their cost and how they restrict market entry. We are also concerned that some organisations seem to be developing a monopoly for the supply of end point assessment for certain standards. Again, while appropriate in some circumstances, this needs to be reviewed, regulated and controlled.

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