Institute for Apprenticeships Statement: Quality Apprenticeships

Institute for Apprenticeships Statement: Quality Apprenticeships

UVAC Response

UVAC is the national representative organisation for higher education institutions committed to championing higher level vocational learning. UVAC has 60 higher education institution members drawn from all mission groups. UVAC also works extensively with the further education sector and awarding organisations to ensure individuals following level 3 vocational and technical learning programmes have the maximum opportunity to progress to and benefit from higher education.

UVAC welcomes the purpose of the IfA statement on Quality Apprenticeships. We welcome the greater emphasis placed on meeting the needs of the learner, which are not the same as the employer and which have not, so far, been sufficiently emphasised in the Apprenticeship Reforms. We do, however, believe the Quality Statement as it currently stands will not underpin the development of a world-class Apprenticeship system. Our main concerns involve the quality indicators proposed which will not ensure the contribution of Apprenticeship to increasing productivity or enhancing opportunities for social mobility is maximised.

We would offer the following observations on particular parts of the statement:

High Quality Apprenticeships

An Agreed Partnership - Specific reference needs to be made to PSRBs. In many key occupational areas PSRBs will be required partners of Apprenticeship development and delivery. It is essential that PSRBs are seen as part of the agreed partnership where an Apprenticeship acts as a licence to practise. The IfA could also learn much from PSRB/Higher Education approaches to the accreditation of occupational competence to a national and agreed standard. Their absence is particularly surprising when under certification the statement refers to apprenticeship certification as ‘a licence for the occupation and to access related professional status.’ Similarly, reference for completeness should be made to an Apprenticeship End-Point Assessment Organisation.

The statement gives the impression that training will be delivered by just one partner. Training may be delivered by more than one partner. For many high quality apprenticeships, a partnership in the delivery of the training programme will be required involving different partners i.e. an independent training provider, college, university and the employer themselves. ESFA, largely due to historic problems with sub-contracting at level 2, has a negative perception of sub-contracting, partnership and collaboration which is hindering the development of new partnerships required to deliver the new Apprenticeship standards developed by Trailblazers. The ESFA position is in marked contrast to that of QAA:

‘The Quality Code is clear that the variety of arrangements for delivering learning

opportunities with others that exist within higher education, including apprenticeship models,

present a range of benefits and opportunities.’ Quality Assuring Higher Education in Apprenticeships, QAA 2017

We would hope that IfA encouraged and supported innovative delivery partnerships that delivered high quality apprenticeships. Perhaps the statement could be revised to reflect the importance of partnership for the delivery of some Apprenticeship standards.

The employer’s contribution in the ‘agreed partnership’ seems limited. Should not more be expected of the employer than ‘employing the apprentice to completion of their training’? Surely, in most cases, the employer should also be expected to continue to employ the Apprentice on completion of their apprenticeship? If this is not the expectation, why is the employer using an Apprenticeship to train an individual for an occupation/role for which they have no need?

The Training Programme - The rationale for the 20% of the job requirement is understood. Reality makes its implementation more difficult. It will be one of the biggest barriers to the take-up and use of Apprentices, particularly for existing employees.

We would offer the following observations:

• Substantial good practice focuses on a blended learning approach where the divide between 'on the job' and 'off the job' is not distinguished. A rigid approach to the 20% off-the job training requirement would run counter to this good practice. As an example, an Apprentice undertakes a project as part of their Apprenticeship to develop the skills, knowledge and behaviours required for competence. The project involves identifying how a business process can be improved.Firstly the Apprentice researches existing practice, then they present their findings to their tutor and line-manager, then they implement and finally they evaluate. This approach often represents the most effective approach to the development of competence - but each element of the project could be considered 'on the job' as it all relates to undertaking the Apprentice's actual job role. For the employer, the actual support for the individual undertaking the Apprentice is considerable, the Apprentice needs to be monitored and the work reviewed at each stage of the project and there is no doubt that active learning or training has occurred.

• One of the key issues with the 20% off-the job requirement is the Apprenticeship will at higher levels involve the individual in study in their own time. A Degree is typically 360 credits i.e. 3,600 notional learning hours. Some of this learning will be work-based, but there would typically be an expectation that as a key beneficiary of the degree, the learner would undertake significant study in their own time.Should the Quality statement reflect this and encourage Apprentices undertaking Higher and Degree Apprenticeships to invest their own time in undertaking learning to complete and excel in their Apprenticeship?

Finally, if we are to ensure Apprenticeship develops as a high-quality learning programme it is essential that Apprenticeship is also considered as a basis for further study and learning. This is not sufficiently reflected in the Quality Statement. Individuals completing Apprenticeship at the age of 19 or 20 will have a working life of 45 – 50 years. The Apprenticeship needs to form the base that allows an individual to move between different occupations and undertake new learning programmes. As such the statement 'additional transferable skills which allow an apprentice to deal with new employers, situations, problems and equipment’is too weak and needs to also emphasise the Apprenticeship as a platform or basis for further study and potential progression and promotion.

End-point Assessment and Certification - The analysis presented suggests the IfA has a limited understanding of quality assurance in higher education and crucially for higher level occupations. England has an acknowledged world class higher education sector. We would hope the IfA would want to learn from the HE external examiner system (no reference is made to this in the statement andits role in ensuringquality/independence). IfAcould also benefit from understanding how Higher Education works with PSRBs to ensure high quality and consistent assessment of occupational competence. Proven systems exist to ensure HE programmes accredit the competence of some of the key occupations in England, nursing and social work being particularly good examples.

We would question how the IfA can justify the following statement ‘Certification by the Institute on completion of the whole apprenticeship. Recruiting employers and apprentices use this trusted record of employability as a licence for the occupation and to access related professional status.’ Should this not be stated as an aspiration rather than a fact? What evidence is there for this statement? We would also note that Apprenticeship is only one route for a licence to practise and to access professional status. We are also concerned as to how Apprenticeship certificates at level 3 will support progression to vocational higher education programmes and professional level job roles – we would suggest the IfA needs urgent dialogue with the HE sector, UVAC and UCAS.

Quality Indicators

Our understanding is that the two core policy objectives of the Apprenticeship Reforms are to increase productivity and to enhance opportunities for social mobility. We cannot see how the indicators proposed directly relate to, or will measure the impact of Apprenticeship on either objective. Apprenticeship is also a programme that is supposed to be employer-led. Employers develop Apprenticeship standards and then decide where best to spend on Apprenticeship to enhance the performance of new and existing employees. Employer leadership and choice was seen as a key way of ensuring Apprenticeship met employer needs and raised productivity and moved Apprenticeship on from the provider, intermediary and agency led Apprenticeship system of the past rejected by the Richard review, the recommendations of which were accepted by Government.

We would suggest the IfA needs to rethink quality indicators for the Apprenticeship systemwith reference to productivity and social mobility. For example:

-Measuring through appropriate long-term tracking studies how Apprenticeship opens up progression routes to under-represented cohorts to technical, managerial and professional occupations

-Developing a model that seeks to establish how employers/economists believe Apprenticeship has increased the performance and productivity of their workforce. This will be challenging – but it is crucial the impact of Apprenticeship on productivity is measured.

The following statement in the quality statement is weak and open to a variety of interpretations:

‘Apprenticeships will meet the skills needs of employers and apprentices by reflecting the range of occupations and skill levels in our diverse economy.’

We will measure this by:

-Cumulative entry to and achievement of apprenticeships by occupation, level and age group

-The number of employers recruiting and training apprentices by size and sector.’

Surely the IfA will want employers to use Apprenticeship to combat skills shortages and gaps and ensure that the fullpotential of Apprenticeship is realised by employers to raise the productivity of their workforce? If employers choose not to use Apprenticeships for 16 – 19 year-olds, but decide Apprenticeship can be better used to raise productivity by focusing on their existing workforce should the IfA not defend such a decision? Again, if employers decide to focus on Higher and Degree Apprenticeship rather than the level 2 business administration and customer service apprenticeships of the past should not IfA welcome such behaviour? And if NHS Trusts want to prioritise levy spend on Apprenticeships for registered nursingand professional level skills rather than level 2 Apprenticeships in business administration and customer service, again is this not the best use of the levy?

From a productivity and social mobility perspective the figures for Apprenticeship delivery prior to the Apprenticeship Reforms are not impressive. In the academic year 2013/14, 65% of apprenticeship starts were at level 2 (GCSE equivalent) and only 2% at level 4 and above (HE equivalent). In terms of occupational focus, Apprenticeship frameworks with the highest take-up in 2013/14 were health and social care, business administration, management (below level 4), hospitality and catering and customer service. In 2013/14 construction skills and engineering frameworks each amounted to approximately 3.5% of total apprenticeship starts. This is hardly a pattern of provision that would boost UK productivity or enable the UK to compete with OECD and BRIC competitors in a post Brexit economy. Neither is it a pattern of provision that supported social mobility and progression to technical, professional and managerial occupations.

Does the quality statement need to emphasise that Apprenticeship is focused on employers’skills needs and that Apprenticeship has moved on from the agency/intermediary/provider led LSC/SFA system of the past?

‘Days of off-the-job training delivered by apprentices’ – This is a poor and potentially misleading measure, as outlined in our earlier comments on ‘blended’ approaches to learning delivery. A crude measure of days off the job does not reflect best practice in the delivery of training programmes that develop occupational competence.

‘Wage gain after the apprenticeship’ - The obvious question here is how soon and over what period this will be measured. A medium/long-term measure would be appropriate. A short-term measure would not. An Apprentice completing their Apprenticeship may want to undertake further study which could well restrict their opportunity for initial salary increases. The term ‘wage’ also links apprenticeship to craft and trade occupations – could the term ‘salary’ also be used?

All the above suggests that the IfA may want to commit to some long-term tracking work focused on the benefits (or otherwise) of Apprenticeship over a period of 5 to 10 years.

We welcome plans for the IfA to gain feedback from employers and individuals. We would suggest that specific focus, in respect of employers involved:

-The speed and efficiency of the Apprenticeship Trailblazer, Standards and Assessment Plan system – measured through an annual survey of employers engaged in Trailblazers

-The availability of the Apprenticeships employers need to develop the performance of their new and existing employers – again measured by an annual survey of employers.

UVAC

October 2017

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