Implementation Consultation Response

Question 1: Do you agree that the principles outlined above are the right ones on which to base a review of which level threequalifications we should continue to fund in the new system, alongside T Levels and A Levels? Yes/No. If no, what other principles do you think we should consider?

The IMI is the automotive industry’s professional body as well as the sector’s leading awarding organisation. As such, we have a close relationship with employers including manufacturers and SMEs across the automotive industry. The IMI supports the government’s ambition in creating a world-class technical education, as these are the very same ambitions that the IMI promotes with its current global partners. The IMI’s work with manufactures accredits 34,000 professionals a year exhibiting the professionalism and skill the DfE/IfA is aiming to achieve with the T-level programme.

The IMI is committed to continuous improvement in the technical education system. However, there are aspects of the T-level programme that are yet to be addressed and raise questions on intent. For instance, we are yet to see any real indication as to the added value of T-levels in the education landscape, which is well served by apprenticeships, traineeships, tech awards and vocational qualifications at all levels. The T-level narrative speaks of simplification of choice, however, fails to identify weaknesses in the quality of current qualification provision, which is far more critical to employers. Clarity on the purpose of T-levels would be welcomed.

A further point of concern for the IMI is the anticipated timescales of delivery. The DfE/IfA have set an ambitious timeline to have the programme up and running by 2021, and although the IMI understands the need for such haste, we do urge that the DfE/IfA consider the impact to AOs. We would recommend that the IfA/DFE consider pushing the date of the first implementation back to at least 2021 which would assist in the system being implemented while reducing the risk of failure.

On the principles outlined in the T-level consultation, the IMI can only agree in part with the principles on which a review of funding for Level 3 qualifications should be based on. It is felt that the current principles fail to address the need of employers directly, here the IMI believe that a fourth principle of ‘meeting employers need’ should also be included.

Further, the IMI’s outlined experience and ongoing relationship with employers such as Ford and Toyota indicate employers are training and recruiting skilled technicians at level 2 or level 3, with the level 3 principally being the highest required level of expertise. There are, therefore, far fewer progressions to a Level 4 qualification with zero Level 4 Apprenticeship Standard progressions in this field. Consequently, it is vital that funding at Level 2 qualification continues, and that these qualifications are protected so that they continue to serve the industry but also offer potential progression onto Apprenticeship Standards and T-levels in the future.

The DfE/IfA must acknowledge that current level 3 qualifications support good outcomes for students and that T-levels must in a similar vein demonstrate an adequate route of progression for candidates. The IMI would urge that DfE/IfA publish candidate journey map that they believe adequately illustrates a candidates progression into work and or an apprenticeship. The IMI would advise that when reviewing which qualifications should continue to receive funding that the government balance the progression of young people with the needs of employers in our industry and consider the value T-level attainment to employers.

Question 2: Do you agree that we should review qualifications at level 2 and below based on the principles that these qualifications should support progression into employment or higher-level study and have a value in their own right alongside T-Levels? Yes/No. If no, what other principles should we consider?

The IMI supports the notion that Level 2 qualifications outside of the current T-Level programme should lead to progression and or higher-level education. However, the IMI caveats this by stressing that current Level 2 or lower qualifications have value in their own right, and indeed lead to job progression and or apprenticeships. Therefore, we must urge that provision of Entry level to level 2 qualifications are continued alongside the T-Levels.

The IMI would also urge that to ensure parity with the automotive sector that the DfE/IfA consider one of the following options:

Option 1: The T-level of the engineering route should have a mechanism to recognise knowledge and skills which could be mapped to a level 2 qualification and permit candidates that cannot achieve the full programme an opportunity to progress to an appropriate apprenticeship standard such as Autocare acting almost like “stop-off”. It would also be advantageous that these candidates receive recognition for progression and not leave with nothing.

Option 2: The DfE/IfA should consider ring-fencing apprenticeship standards at level 2 as apprenticeship only, as there is a danger that candidates completing the T-Level will be overqualified but under skilled for these roles and could be overlooked by employers.

The IMI would urge that sector reviews are conducted to ensure that where regional skills are assessed for T-levels that there is the evidential requirement for their delivery.

Question 3: Do you agree with proposed approach to assessing technical qualifications? Yes/No – please give reasons for your response

The IMI agrees with principles 1 and 2, outlined in the proposed approach to assessing the underpinning knowledge of the core and employment skills. However, the IMI ask for more clarity and guidance concerning principle 3. The IMI is unclear as to what is meant by ‘threshold competence’, and from our perspective, we would want to see any occupational specialisms developed to be able to add sufficient value for candidates to progress into apprenticeships or employment. As a result, T-Level panels will need to play an active role and work with our sector in designing such occupational specialisms.

Additionally, it is desirable to see practical assignments used as a method of assessment in developing the practical skills of candidates. However, consideration will need to be given to the required level of equipment for students to be able to demonstrate ‘threshold competence’ as this will vary between different occupations within a route. Further, employer groups will undoubtedly require clarification on what the prospective journey from occupationally skilled to competent is and how this could lead to employment. Therefore, the IMI asserts that any documentation including, but limited to promotional material, clearly defines a candidate’s level of work readiness and possible progression to apprenticeship standards.

Also, the IMI would like to point to a few areas of the implementation consultation that cause some ambiguity:

• “Threshold Competence” – We would like to know what this term means and how the DfE/IfE believe it will be assessed? Furthermore, we want to understand what communications will be going out to employers to explain the level of experience that these candidates may have.

• T-level structure – it is evident that there has been further progress in the formation of the T-level. However, the core being sub-divided into 1 and 2 and how they are aggregated to be graded A*-E is unclear. Moreover, it would seem that Core 2 is consistent with the initial thinking that the Core would be constant across all occupations. However, Core 1 seems to relate to a specific pathway. Also, there is evidence that literacy and numeracy digital skills are discussed as part of the Core but Maths, English and Digital Skills are also considered as a separate component of learning.

Therefore, the IMI would request that DfE/IfA revisit the T-level structure and assess the components concerning duplication of learning and complexity of delivery.

Question 4: Do you agree with the approach to grading technical components? Yes/No – please give reasons for your response?

The IMI believes that mixing the grading scales with A*-E, Pass, Merit, and Distinction could create confusion for the candidate and their eventual employers.

Moreover, using the formula P(n,r) = n! / (n - r)! The IMI has calculated that from the four grade scales and 15 possible grades T-levels could lead to 32,760 different permutations. The possible mix of grades that employers would have to sift through to pick the best candidates will become almost impossible. For example, would an employer have sufficient understanding to be able to select between a learner who has achieved a Grade A, Pass, Merit, and Distinction from another who has achieved Grade A, Merit, Pass, and Distinction?

Aside from the complexity that the T-level programme introduces from a grading perspective the concept behind T-levels is anticipated to provide some parity to A-levels. Therefore, the IMI suggests consideration is given to an overall grading scale for T-levels, which would be essential for comparability.

The IMI recognise that the vocational environment is fundamentally different, and employers will seek technical knowledge, as well as basic core skills. With that said, the IMI supports the idea that each component is individually graded and presented as a transcript of T-Level certification, to provide employers with a clear indication as to what was achieved. However, as aforementioned mix-grading scales could be confusing to employers and therefore, reviewing, would be advantageous at this time.

Question 5: Do you agree with the approach to maintaining comparable standards of performance for technical qualifications? Yes/No – please give reasons for your response

Although, the IMI agrees with the sentiment of the approach in setting and maintaining comparable standards. The consultation seems to allude to the proposition that employers would be involved in setting grade boundaries and standards, which in all likelihood they are not equipped to do. The IMI would request that the DfE/IfA provide more detail on what employers are expected to do. As an AO the IMI continually involves employers in the development and review of standardisation activities for Apprenticeship Standards and qualifications. However, employers are not setting grades in these instances, and we would like to know what the DfE/IfA would expect in the future. It is the IMI’s view that as an AO that has decades of industry and technical education experience we are the best place to identify employer needs and establish standards for T level qualifications.

Question 6: Do you agree that prior attainment of the core could count if students switch to another T-Level within the same route? Yes/No – Please give reasons for your response

Yes

The IMI agree that having a transferable core is essential. The core as illustrated by the Implementation annex has two components.

Core 1, which includesthe concepts, theories, and wider context to an occupation;

Core 2, whichincludes the employability skills, transferable skills and relevant numeracy, literacy and digital skills

Consequently, it would seem that core 2 is most likelyelementtransferable across all occupational pathway. The IMI would recommend that consideration be given to how these segments are aggregated and presented to employers.

Question 7: Do you agree with the proposed approach integrating the work placement within the T-Level Programme? Yes/No. Explain your answer. If no, what would be a preferable approach?

The IMI disagree with the proposed approach and instead argue that in essence, the proposed work placement component of the T-Level Programme places an unrealistic expectation on the employer’s role within the work placement. The IMI insists that it will be difficult to find sufficient high-quality work placements in our sector, and this availability will only remain hindered by the lack of incentive for employers to take on work placement students in the first instance. Students in disadvantaged areas of the country will inevitably find access to a high-quality work placement problematic due to factors such as geographical disparity and poor transport links. Moreover, it will be challenging for employers in our sector to manage work placement students with existing and recently increased employer responsibilities, namely their obligations owed to existing apprentices.

A work placement will need robust quality assurance and measurability to ensure that the student meets progress against their learning objectives supporting achievement of work placement criteria. The issue of work placements raises the question of what mechanisms or resources will be available to employers to ensure that work placements will consistently retain a high quality and that students will periodically be monitored throughout their work placement.

To replicate the strong work placement links that already exist between colleges and providers, a higher level of consultation is required with employers. A consultation will aid further understanding of the feasibility of work placements.

Question 8: Do you agree with the proposed method of appraising the student’s performance on their work placement, including the Employer Reference? Yes/No. please explain your answer. If no, what would be a preferable approach?

The IMI disagree with the proposed approach of appraisal as it raises concerns as to the method in which grading of work placements will be kept consistent and moderated. Presently, employers are not trained to carry out such assessments, and it is unclear how quality assurance will be monitored and measured. While an employer reference will be designed to provide truth concerning the students’ performance during a work placement, a reference will inevitably be subjective and therefore, we would desire an objective assessment carried out by a trained and impartial individual to give a fair appraisal of the student’s performance.

Question 9: Do you agree with the proposed approach to quality assurance set out above? Yes/No – please explain. If no, please explain how we can ensure work placements are quality assured?

The IMI agree that the process of quality assurance is necessary for an effective approach we disagree with the proposed plan of quality assurance outlined in this paper and consider the criteria listed to be directed at questions concerning necessary background checks, rather than quality assuring the work placement in itself.

It should be appreciated that such checks will place more responsibilities on the provider of the work placement. Therefore support and guidance in the form of a detailed cost analysis should be given to providers to ensure that the process is as cost-efficient as possible. To guarantee a safe working environment for the student, the IMI would also want to see employers undertake a range of health and safety checks and criminal background checks. More guidance will also need to be given to the role of the designated ‘line manager’ to ensure that this is a reliable individual in the business that who can suitably assume responsibility for overseeing the student on their work placement. Furthermore, the IMI would want to see an adequate reviewing service in place to ensure that the progress of the student is frequently monitored on their work placement.

The DfE/IfA should also consider how the work placement aides the achievement of a candidate when receiving their T-level and whether the on the job exposure benefits candidates potential to gain employment or an apprenticeship. Additionally, we believe that T-level candidates should receive a fair wage for their employment. In not paying candidates for their time it undermines the value of the work placement and does not instil the work ethic seen in a valuable career path.

Question 10: What additional support or further modifications should be available to those with greater needs or special circumstances (such as caring responsibilities) during a work placement?

The IMI would support employers in ensuring that they comply with the provisions of the Equality Act 2010, namely the duty for employers to provide ‘reasonable adjustments’ in the workplace to support workers with a disability.

Question 11: How can we support students to access work placements relevant to their course in areas where there are no employers to offer work placements nearby?

It will be essential for students to receive full travel and sustenance funding to provide them with access to a high-quality placement if such placements are not available in their local area.

The government could also entertain the idea of developing commercial entities within training providers, as a way of generating work placements if they are unlikely to exist. Professions such as catering, hair, beauty, and marketing have used.

Question 12: Do you agree with our suggested approach to providing students with financial support whilst on a work placement?

Yes

However, the approach could place an unnecessary burden on training providers and FE Colleges. Therefore, the IMI suggest that students are directly compensated for their time on the work placement either by the Government or employers.