The Future of Apprenticeships in England: Next Steps from the Richard Review Consultation

The Future of Apprenticeships in England: Next steps from the Richard Review–Consultation questions

We set out below areas for your comments/contribution on the Government’s response to issues raised by Doug Richard’s wide-ranging report on apprenticeships, including some quite strong proposals.All responses to the consultation document we have put on the TSSA website will be considered when compiling our formal submission".

If you are interested in reading the full Richard Review you will be able to find it here:

Please use this as an opportunity to talk to your colleagues – remember that TSSA is a collective voice to raise issues with the Government! If you would like to make a general comment or respond to one or more of the specific questions set out below please either amend the document and send back, or just send an email/letter with your points for inclusion in the TSSA response, to Sal Morawetz, TSSA National Learning Organiser by email - or to Walkden House, 10 Melton Street, London, NW1 2EJ. All comments from TSSA members must be sent to Sal by 9am Monday 13th May.

Guidance Note

Please be aware that the Government explanatory points are set out in blue, their questions in blue bold and TSSA’s additional questions in black.

Q1.The government agrees that Apprenticeships should be designed for and targeted at those at the outset of a new job role or occupation, to train them in the skills needed for that job and to provide a springboard for their future careers. This includes helping people to advance within their existing employment, where the Apprenticeship is firmly focused on training for a job at a higher skilled level. Most important is that substantial learning takes place, with the application and practice of new knowledge and skills in a real workplace. For those already experienced and competent in their roles, Apprenticeships will not be the right approach – unless they are advancing to a substantially higher skilled role.

Q 1: How can we ensure that every Apprenticeship delivers substantial new skills?

Do you agree that apprenticeships:
Should not be available for people in “low skilled jobs”?
Should be to fit people with the skills for new jobs and not for their existing job?
May not be the best starting point for all 16-24 year olds and that some young unemployed people would be better served by undergoing a traineeship first [with English & maths, work placements, “work skills training etc” in order to develop employability / work experience before getting on to an apprenticeship]
Are there any dangers in setting up such a parallel “traineeship” scheme for some young people and particularly for some groups of, historically more disadvantaged/discriminated against, young people?

Q2. The Richard Review recommends that every Apprenticeship should be based on employer-designed industry standards. It recommends that these new standards should focus on outcomes and mastery of the occupation or major job role, and should replace Apprenticeship frameworks, the current qualifications which comprise them and the national occupational standards which underpin them. The new standards would set out simply and clearly what employee in that occupation or major job role will need to be able to do. The government agrees, and believes that employers should take responsibility for designing these new standards. The government seeks views on the best way to bring employers together to do this – for example through a competition, or a facilitated or collaborative approach.

Question 2: How should we invite and enable employers to come together to design new standards for Apprenticeships?

Do you have any comments on why your, or other, employer(s), should or should not be responsible for designing such standards?

Do you have any views about the introduction of employers competing against each other to develop the apprenticeship standard in our sectors?
Do you see that as a good use of their time?
Do you think that this might lead to self-selection by only some of the employers who have the resources/commitment, but not necessarily the right approach?

Do you agree that apprenticeships should also involve trade unions in setting the overall standards?
And if so, how would you like to see trade unions in the travel or transport sectors input to those standards?

How would you ensure that no gender stereotypes affect the design of any standard?

Question 3: What are your views on the proposed criteria for Apprenticeship standards as set out below?

Do you agree that apprenticeships criteria should:

•be stretching;

•deliver transferable skills;

•have significant buy in across the sector, including from Small or Medium

Enterprises [companies with 25-250 employees], and bedeliverable by small

employers;

•require substantial training and take more than a matter of months to become competent at – involving training significantly beyond thatoffered to all new staff;

•include skills which are relevant and valuable beyond just the current job, supporting progression within the sector; and

•reflect a real job, not generic skill.

Is there anything missing or that you would argue about?

How should resources from an employer, and/or the Government size up against resources for the needs of current staff who may have had no formal structured [and/or accredited] training for their existing job or career paths?

Q4.The Richard Review recommends that there should be just one Apprenticeship standard and qualification for each occupation or major job role. He proposes that these should set out what an Apprentice should be able to do and know at the end of their Apprenticeship, in a way that is relevant and meaningful for employers.The government recognises the strong arguments set out in the Review that there should be only one standard. Government also recognises that for some sectors the nature of individual jobs may vary significantly between employers, even for job roles that are nominally the same. Government needs to find a solution to take account of this – for example through a “core and options” approach for each standard and qualification, increasing their flexibility to different settings and contexts whilst ensuring a rigorous core of essential knowledge and skills.

Q 4:Should there be only one standard per Apprentice occupation/job role?

Yes No Don’t know

Any comments as to why you selected yes, no or don’t know?

5. The Richard Review recommends that these one Apprenticeship standard / qualification for each occupation or job role and that these should set out what an Apprentice should be able to do and know at the end of their Apprenticeship, in a way that is relevant and meaningful for employers.

Question 5: Should there be only one qualification per standard?

Yes No Don’t know

Any comments as to why you selected yes, no or don’t know?

6. The Government’s proposals to replace the current Apprenticeship Frameworks with new employer-designed standards and qualifications would be a significant reform, and will need careful planning and collaboration.
Q 6: How should the Government manage the transition from the current system of Apprenticeship frameworks to a new system of employer-designed Apprenticeship standards and qualifications?

Are there any current best practice apprenticeships in your company, or that you know about outside your own workplace, which you think should be protected in the transition period and beyond – if so, what and why?

Q7. Once the new Apprenticeship standards are agreed it will to be important that they remain rigorous, stretching and relevant to employers.

Q 7: The Government wants to know how they can make sure that the new standards stay relevant to employers, and are not compromised over time.

Do you:

Agree thatit is only about [existing] employers’ views of the relevance
Believe that the trade unions should play a role in this?
and if so,
doing what ?
and with what support from employers and government?

Q8. Whilst some employers already contribute to the design and development of assessment, government agrees with the Review on the benefits of employers playing an increased role in this area. This relates both to the design of the final test for the occupation or major job role and to the ongoing arrangements for assessing the competence of apprentices who take this, working with awarding organisations. Increased employer involvement will help to build trust in the credibility and rigour of the assessment process. In pursuing this, government will need to ensure that it does not ask more from employers than they have the capacity to do, which will vary between sectors and occupations.

Q 8: How can government ensure that employers are better engaged with the development and oversight of the assessment in Apprenticeships?

Should trade unions also be involved in this, and if so, how?

Should any other groups of people or interest groups be involved?
How would you ensure that no gender or other stereotypes affect any assessment?

Q9. The Review proposes that employers also have a more direct role in being part of the final assessment of individual Apprenticeships. Government is keen to explore how this might be achieved in practice, without placing undue burden on employers and recognising the expertise required of professional assessors. The role of such professionals will continue to be important. Government proposes therefore to include assessment as a further area to be considered by those developing Apprenticeship standards. Employers would be invited to set out what an effective test of competency against the standards they wish to set would be, and how the arrangements for its delivery might work.

Q9: How could employers best be involved in the practical delivery of assessment?

Is there a danger of assessment being designed by the very people who might best benefit from apprentices reaching the standard – i.e. under the new proposals for funding apprentices, employers will only get the direct funding, and hence only then pay the provider, if their apprentices are judged to have achieved the required standard
Given that many employers are still unaware of the impact of neurodiversity, and their responsibilities towards people with neurodiverse conditions, how might this and other issues of discrimination and diversity be explicitly factored in to any assessment?
How should trade unions be involved in designing the delivery of and inputting to assessment?
and if so,
doing what ?
and with what support from employers and government?

Q 10: The key principles of assessment in any education or training system are independence, consistency and the maintenance of standards over time. Independent assessment should be demonstrably objective, separated from any individual or organisation with an incentive for whether the individual passes or fails. This might be achieved, for example, by ensuring that assessment is fully independent of training delivery. Or, where this is not possible, through robust arrangements for independent verification to ensure objectivity is maintained. By consistency we mean that the outcome of the assessment should not vary between different settings, workplaces or areas.

Question 10: How can the independence and consistency of assessment in Apprenticeships be further improved?

Is there a specific role for trade unions here?
If yes, what would unions need from Government or the employer to carry out that role?
Do you have any concerns as to how independence, consistency & maintenance of standards might be affected in your own workplace setting?
Do you think there might need to be additional safeguards to ensure that institutional discrimination does not affect the assessment of individuals from groups who have been historically discriminated against and if so, what?

Q11. Apprenticeships today, as a result of the qualifications they contain, often focus heavily on continuous assessment. This can be at the expense of new teaching and learning. Indeed, some Apprentices tell us that their Apprenticeship experience has been dominated by assessment alone. Re-focusing on assessment at the end will allow trainers to spend more time teaching, not testing.

Q 11: How should we implement end point assessment for Apprenticeships? Are there any particular issues which would be best assessed through continuous assessment rather than just one final assessment at theend?

In our sectors there are a range of qualitative standard issues which might best be looked at over time [for instance if there was an apprentice responsible for dealing with customers, particularly with long running and intricate complaints or other issues, or making a report to a court or large meeting] rather than just one assessment at the end which might not be able to cover a range of evidence of standards criteria met. Are there particular things which you would like to see assessed in other ways than a one off final assessment – if so, what, and how?

Q12:Current occupational qualifications use a wide variety of grading approaches. Most assess purely on a pass or fail basis but some distinguish between different levels of achievement. We will welcome views in particular from employers on the appropriateness of grading for their sector, and how this might work as part of standard setting and assessment.

Q12: How should we implement grading for Apprenticeship qualifications?

Is setting a range of grading levels simply introducing competition for the sake of competition?
Will the introduction of a range of grades mean that apprentices who have successfully overcome neurodiversity or other equality barriers in order to reach the required standard for a good apprentice, but may not have got the top grade, still be at danger of being treated as 2nd class apprentices?

Q13. From August 2014, government will require all Apprentices who begin their Apprenticeship with only level 1 qualifications in English and/or maths to work towards level 2 attainment in these subjects during their Apprenticeship. At this interim stage Apprentices will not need to have achieved level 2 English and maths in order to successfully complete their Apprenticeship. In future years government aims to go further, so that all Apprentices (including those starting without a level 1 in English or maths) must achieve level 2 English and maths as part of their Apprenticeship.

Question 13:What are the specific obstacles to all Apprentices achieving level 2 English and maths as part of their Apprenticeship, and how could these be overcome?

What consideration needs to be taken for apprentices with neurodiverse conditions [such as dyslexia or dyscalculia etc] who might particularly struggle to reach such grade levels at the same time as other apprentices who are not neurodiverse?

Is there a role for union learning reps to be involved in supporting apprentices to reach absolute academic grade levels?
and if so, with what support from employers and government?

Question 14:How would a requirement to have all Apprentices achieve level 2 in English and maths impact on employers, providers and potential learners? What are the risks and potential solutions?

Do we agree that all apprentices should achieve the equivalent of GCSE “O” Levels grades A-C in English andmaths - and are there any dangers this might bring?

How might the trade unions practically support apprentices struggling to achieve this in a standard apprenticeship timescale?
and if so, with what support from employers and government?

15. The Government’s proposed reforms, focusing on final competency and removing the detailed prescription and incremental assessment that many Apprenticeships involve today, will give greater scope to train in more flexible ways. Government wants more empowered employers, working with training providers and learners, to shape each individual Apprenticeship. Government reforms will incentivise greater responsiveness, innovation and dynamism in training delivery, with more new entrants to the market bringing fresh ideas and approaches. Government wants to encourage this, and also spread good practices and take full advantage of the opportunities offered by new technologies.

Question 15: What further steps, by government or others, could encourage greater diversity and innovation in training delivery to help Apprentices reach the standards that employers have set?

Are there any concerns about a move away from colleges to new private providers delivering apprentices in different / non-traditional ways?
The government seems keen to make use of new technology, are there areas of concern whereby off the job training might be solely/primarily e-learning or through other non-collective training methods in terms of your own work area?
What might be concerns about training being individualised and solely dependent on the employer’s view of the job role & requirement?

16. Government recognises the benefits for Apprentices of having sufficient time to learn and reflect well away from their “day job”, and shares Doug Richard’s concerns that many Apprentices today lack sufficient time away from their workplace and off-site. This brings the opportunity for additional training, and gives the time and space to gain fresh perspectives and consolidate learning. Further benefits can come from shared learning with other Apprentices. Government wants to ensure this is a core component of every Apprenticeship, without undermining employers’ ability to shape each Apprenticeship as they see fit.

Question 16: What approach would work best to ensure Apprentices benefit from time to train and reflect away from their day to day workplace?

How should trade unions be [automatically?] involved to ensure that Apprentices do actually get time away from the workplace for learning?
How might trade unions/Union Learning Reps be involved in supporting, mentoring or coaching apprentices in order to add to the on-going development of apprentices?
Are there are other barriers to their development which apprentices also face other than no time away from work?

Q 17: The review set out that “there should be no unnecessary process and prescription for how an Apprentice reaches the desired outcome, but rather many paths and approaches.
The3 Government suggests that some off-site learning and a minimum duration for Apprenticeships [at least 12 months] should be mandatory.

Q 17: Should off-site learning be made mandatory?