QUA0036

 

Written evidence submitted by UVAC

 

UVAC - UVAC is the representative organisation for Higher Education Institutions (HEIs) committed to higher level vocational learning.  UVAC has over sixty institutions in membership drawn from all university mission groups, including the Russell Group.  We have an extensive track record in researching approaches to Apprenticeship, higher education and skills. Our peer reviewed journal Higher Education, Skills and Work-based Learning published by Emerald has an international editorial board, had over 16,000 downloads in the last year and has featured special editions focused on Higher and Degree Apprenticeship.  UVAC has a track record advising on how Apprenticeship can be used to support social mobility and has undertaken several studies on this topic for ministers and Government agencies. UVAC provides a support programme for HEIs engaging in the Apprenticeship agenda.  We also work in partnership with the Education and Skills Funding Agency (ESFA), the Higher Education Funding Council for England (HEFCE) and the Institute for Apprenticeships (IfA) to support HEIs provide the Higher and Degree Apprenticeships employers and individuals are demanding.   

 

  1. UVAC welcomes the Committee's inquiry - it comes at a pivotal moment for the implementation of the Apprenticeship Reforms. We are, however, surprised that the call for written evidence:

 

 

 

 

 

  1. In summary the call for evidence suggests a focus on past approaches to Apprenticeship and skills provision.  Apprenticeship is changing rapidly and we would suggest consideration is given to the new Apprenticeship system and its impact on productivity and social mobility, rather than a focus on historic patterns of provision and problems with the old delivery system. To compete internationally England needs to develop a skills system encompassing all levels focused on the needs of the national, regional and local economy.  Too often, in the past, skills and apprenticeship programmes have been seen as synonymous with further education – they are not.  Further education has a critical role, but the historic exclusion of higher education has resulted in an over concentration on lower level skills provision, rather than the skills provision the Country needs to compete internationally.  Such an approach has also impeded the development of new work-based progression routes through Apprenticeship which open up access to under-represented cohorts of individuals to technical, professional and managerial occupations. 

 

The quality of current provision, how this varies by sector, level and region and the impact of this on learner outcomes

 

  1. Apprenticeship is frequently identified as the Government's flagship productivity programme.  If this is so, historic patterns of provision illustrate how much Apprenticeship has to change. Put simply, under the stewardship of the ESFA and its predecessor the SFA, Apprenticeship has been a low level programme, with little focus on STEM occupations and with a negligible relationship to the skills gaps and shortages evident in the UK economy.  In 2015/16 58% of Apprenticeship provision was at Intermediate level (level 2) and only 5% provision at level 4 – 7.  Apprenticeship frameworks with the highest take up were low level programmes in health and social care, business administration, hospitality and catering and customer service.  Such a pattern of provision represents poor value for employers, Government and tax payers.

 

  1. Apprenticeship provision is dominated by low level programmes many of which are of dubious value and offer few opportunities for learners to progress to technical and higher level occupations.  Indeed, in their recent report Better Apprenticeships for the Sutton Trust, Lorna Unwin, Chiara Cavaglia, Guglielmo Ventura, Alison Fuller and Sandra McNally concluded that the majority of apprentices under the age of 25, given the level 2 focus of Apprenticeships, start their training below their current level of educational attainment and as such are 'treading water'.  From a social mobility perspective the focus of Apprenticeship needs to change.

 

  1. The current Apprenticeship reforms are helping to ensure that Apprenticeship is a proper skills programme focused on real occupations.  Through the Trailblazer process employers have rejected the old agency, intermediary and provider focus of SASE Apprenticeship frameworks.  Employers have focused the development of Apprenticeship standards on real occupations needed by the economy, registered nurse, police constable, social worker, teacher, engineer, digital occupations and manager.  Apprenticeship has also moved upwards in level to reflect the skills needed by the UK economy – approximately 35% of Apprenticeship standards have/are being developed at higher education level.  This change reflects the skills needed by the UK economy.  For example in The Right Combination – CBI/Pearson Education Skills Survey 2016:

 

 

  1. Regrettably, the ESFA is behind the curve in terms of the changing occupational focus of Apprenticeship and its movement upwards in levels.  ESFA is still a further education organisation with a further education ethos and focus. It has limited understanding of higher education and many of its systems are incompatible with higher education and act as substantial barriers to the engagement of HEIs and the delivery of the Higher and Degree Apprenticeships employers have developed through the Trailblazer process.  As outlined in later sections of our response the ESFA approach to procurement of Apprenticeship provision for non-levy paying employers has had a massive detrimental impact on the availability of Degree Apprenticeship in different parts of the Country.

 

The Effectiveness of the Quality Monitoring System, in Particular the Role and Capacity of Ofsted

 

  1. We are surprised specific attention is directed at Ofsted, when other agencies/organisations have a role; HEFCE/OfS, Ofqual and the Institute for Apprenticeships.  Ofsted has responsibility for the 'inspection' of Intermediate (level 2) and Advanced Apprenticeship (level 3).  HEFCE/OfS leads on quality assurance for Higher and Degree Apprenticeship at level 6 and 7. Joint approaches are being developed by Ofsted and HEFCE to quality assurance for Higher Apprenticeship at levels 4 and 5. The IfA also has a lead role in the Quality Alliance and for EQA of Apprenticeship end point assessment, HEFCE, Ofqual, professional bodies, IfA and employers themselves. Under the Apprenticeship Reforms Apprenticeship is moving upwards in level. This means more Apprenticeships will move out of the scope of Ofsted and quality oversight will be the responsibility of HEFCE/OfS.

 

  1. We cannot comment on Ofsted's role at level 2 and 3. England has, however, a widely acknowledged 'world-class' higher education sector. HEIs have an established reputation in working with Professional, Statutory and Regulatory Bodies and employers to develop and deliver programmes that develop and accredit occupational competence, nursing and social work being good examples. Robust and proven approaches to quality assurance exist. 

 

The role of the Education and Skills Funding Agency in ensuring value for money, and the impact of different funding models

 

  1. The ESFA as currently structured is not fit for purpose to oversee the Skills and Apprenticeship system. In terms of knowledge and expertise the ESFA is focused on low level and intermediate skills and certainly not the higher technical, professional and managerial skills needed by the UK economy.  The ESFA has continually adopted a further education first approach to the detriment of the Apprenticeship reforms, employers and individual learners. Data returns are based on the FE based ILR (individualised learner record), providers with data issues are asked to use feconnect and quality measures focus on Ofsted not NSS results.  The very terminology used by ESFA hinders an inclusive approach to all types of providers. 

 

  1. Apprenticeship is not and should not be seen as a further education programme. If Apprenticeship is to deliver the Government's productivity and social mobility objectives, the Apprenticeship system must support the engagement of further education colleges, independent training providers and higher education institutions. ESFA under its new chief executive needs to turn the page and ensure appropriate systems are in place. No better example of the ESFA's lack of responsiveness to the changing focus of Apprenticeship is its approach to the procurement of Apprenticeship provision for non-levy paying employers.  The first failed procurement exercise resulted in ESFA simply rolling over contracts to existing providers based on historic patterns of delivery, effectively prioritising lower level framework provision.  As Higher and Degree Apprenticeship were new programmes and HEIs new providers the ESFA approach was devastating.  HE regulator HEFCE reported, following a survey of higher education providers that:

 

 

In one case study the report outlines how a higher education provider ‘had conducted a survey of demand for Apprenticeship provision among (its local) SME population which showed around 50 SMEs had an immediate or future interest in Degree Apprenticeship and a further 60 SMEs requested further information.’ Following the pause in procurement the provider had been unable to follow-up ‘such clearly evidence local demand’.

 

  1. The failure of the first ESFA procurement has resulted in a loss of confidence in ESFA.  Higher Education providers had developed partnerships not just with SMEs, but also with LEPs and further education providers, many of which have been delayed or abandoned. Momentum has been lost and some HEIs with a skills focus took the decision to solely focus on levy paying employer business and not to respond to the second ESFA procurement to the detriment of the productivity and social mobility agenda.   

 

  1. The second procurement for non-levy paying employers, the results of which announced on 7 December 2017, yet again raises serious concerns as to the ability of the ESFA to effectively manage the Apprenticeship system.   Large HEIs based in urban areas with multiple Degree Apprenticeship programmes were reasonably successful – this is positive. There is, however, a significant problem with universities that bid for relatively small amounts of Degree Apprenticeship provision, typically smaller institutions away from metropolitan areas.  However well evidenced on the basis of employer demand, LEP priorities or skills needs the scaling back of bids has resulted in some universities being pushed below the £200,000 threshold and denied a contract for provision vital to local economic, business and individual need.      

 

  1. It seems we may well be facing the creation of localised Degree Apprenticeship cold spots which have little or no Degree Apprenticeship provision which will severely disadvantage not just local employers and learners, but also undermine LEP skills plans.  We are also aware of universities who have received DfE/HEFCE Degree Apprenticeship Development Funding but that have not received ESFA funding for delivery.  Public funding has been provided to develop provision – but ESFA has not provided funding to deliver such Apprenticeship provision to non-levy paying employers. ESFA could have easily avoided such a situation.

 

  1. One issue that has been raised by Independent Training Providers is the 10% co-investment non-levy paying employers are required to make when using Apprenticeship. The 10% co-investment is claimed to be unaffordable and will prevent many individuals from undertaking Apprenticeships. Our view supported by our members is that the 10% co-investment is regarded as an excellent proposition by employers and will not prevent non-levy paying employers utilise Apprenticeship if the Apprenticeship is of high quality and needed by the employer. The 10% co-investment will, however, ensure Apprenticeship is appropriately used and that bad practices and misuse of the skills system under programmes such as Train to Gain are not repeated. Any move to fully fund Apprenticeship for non-levy payers would wholly undermine the ability of the ESFA to prevent misuse of Apprenticeship funding and efforts to safeguard the public purse.

 

Quality and Oversight of Training Provided by Subcontractors

 

  1. Subcontracting is frequently regarded as a 'negative' in the Apprenticeship system. While this may be the case with Intermediate Apprenticeship it is certainly not the case with Degree Apprenticeship. Indeed QAA, the organisation appointed to safeguard standards and improve the quality of UK higher education described in Quality Assuring Higher Education in Apprenticeships sub-contracting and partnership in the following terms:

 

  1. ‘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.’

 

  1. Innovative partnership and subcontracting models are being developed that will open up new opportunities for under-representative cohorts of learners and provide cost effective and flexible approaches for employers to use Apprenticeship to develop the productivity of their workforce. Too often sub-contacting is associated with past poor practice where providers with an ESFA 'allocation' top sliced funding and sub-contacted provision to third parties who delivered poor quality provision. Such poor practice has more to do with the historic ESFA provider base and weaknesses in the ESFA allocations system rather than any inherent problems with sub-contracting as such. In the longer term as all employers move over to use the Apprenticeship Service to purchase provision the majority of the problems and poor practice associated with sub-contracting will we would suggest be far less of an issue.

 

  1. UVAC has been working with the ESFA and Association of Colleges to identify different sub-contacting models that enable Apprenticeship to better meet the needs of employers and individual learners.  Examples include HEI/college/employer sub-contracting models to deliver the Nuclear Engineering Degree Apprenticeship, HE/ITP partnerships to deliver the Digital Technology Solutions Professional Degree Apprenticeship and a variety of HE/FE/ITP models focused on the Chartered Manager Degree Apprenticeship.

 

Quality of Training Received by the Socially Disadvantaged and Barriers to them undertaking this Training

 

  1. Debate on the role of Apprenticeship in enhancing social mobility and social justice is usually too narrowly focused. Too often the debate focuses on the importance of Intermediate Apprenticeship in supporting individuals into low level and low paid employment.  As outlined earlier in our response, the recent Sutton Trust report, Better Apprenticeships concluded that the majority of apprentices under the age of 25, given the level 2 focus of Apprenticeships, start their Apprenticeship training below their current level of educational attainment and as such are 'treading water' with no prospect of stepping-up on completion. 

 

  1. We would suggest that even for individuals who have yet to attain level 2 qualifications Intermediate Apprenticeships are not, in most cases, the best solution to supporting the 'socially disadvantaged' have a successful long-term career.  An Intermediate Apprenticeship for a 16 - 19 year-old will only involve a 20% off the job learning component.  For individuals without 5 GCSEs at A to C we would question why an Intermediate Apprenticeship is often seen as the best or most appropriate learning opportunity.  We would suggest that Traineeships and college-based education options are more appropriate and will be of greater value to an individual in terms of supporting long-term career progression.

 

  1. What is not usually acknowledged is the potential role of Apprenticeship encompassing levels 3 (A level equivalent) to 7 (master’s degree level) in providing an 'earn while you learn' and 'debt free option' (your employer pays your tuition fees) through higher education to technical, professional and managerial occupations.  Apprenticeship offers a new opportunity to develop work-based progression routes to compliment the historic A level and full-time university route.  It is still early days, but UVAC's work with over 60 HEIs (including Russell Group universities) suggests Degree Apprenticeship is opening up new opportunities to under-represented cohorts of learners. Degree Apprenticeship is also showing the potential to tackle the gender imbalance in some key occupation areas - the digital sector being a particularly good example. These are the areas where Apprenticeships has the greatest potential to make an impact on social mobility and social justice.  In recent discussions with ESFA/DfE UVAC has outlined proposals to incentivise employers to develop and utilise work-based progression routes from level 3 to higher level skills in technical, associate professional, managerial and professional occupations. We would welcome the opportunity to develop these proposals further.

 

  1. It is also critically important that Apprenticeship is seen as a programme to support social mobility/social justice for individuals in employment rather than just 16 - 19 year-olds. An individual aged 20 or 25 may have 50 years of work ahead. It is important that Apprenticeship provides a basis for career progression and enhancement for individuals of all ages. Our own work demonstrates how several new Degree Apprenticeships, social work being a particularly good example, will be used by employers to support existing employees with the ability and aspiration to progress from level 3 roles to professional occupations. As such Degree Apprenticeship will open-up and support progression to professional and managerial occupations to employees who simply haven't had such opportunities in the past.

 

  1. One of the key barriers to the engagement of employers particularly SMEs in Apprenticeship and its use by learners is the minimum 20% 'off the job' rule. While the 20% of the job rule is entirely appropriate for 16- 19 year-olds, following Intermediate Apprenticeships, many of whom will have been poorly served by the schools system, and need a sound educational base, the requirement is inappropriate for older learners following Advanced, Higher and Degree Apprenticeships. Older learners and those following Higher and Degree Apprenticeships will in many cases adopt a blended learning approach where the divide between on and off the job learning is intentionally blurred to deliver a higher quality learning experience and output. A loosening of the 20% off the job requirement (and adoption of other measures e.g. credit and guided/notional learning hours), would support more SMEs engage in Apprenticeship and open up opportunities for new cohorts of learners.

 

  1. The new approach to the development of Apprenticeship standards, while rightly driven by employers to ensure focus on real occupations and areas of skill need does not give enough attention to the needs of the learner. The Apprenticeship is designed and funded to ensure an individual develops the knowledge, skills and behaviours to be competent in a defined occupation. In some cases this has meant that insufficient attention has been given to how the Apprenticeship provides a basis for or 'qualifies' an individual for further learning.  How for example will Advanced Apprenticeship certificates awarded by the Institute for Apprenticeships be regarded by higher education admissions tutors? How do Apprenticeship standards at level 3 relate to and support progression to Higher and Degree Apprenticeship? While we recognise Apprenticeship is primarily focused on occupational competence, Apprenticeship should allow and indeed open-up access to further learning opportunities if it is to support Apprenticeship enhance opportunities for social mobility.

 

  1. Finally one of the practices that will undermine social mobility is the Institute for Apprenticeships (IfA) attitude to qualifications and their specification in Apprenticeship standards and assessment plans. Qualifications provide transferability and currency for individuals who will decide to undertake further study and move on to multiple jobs throughout their working lives. Employers, in our experience, also value qualifications. Rather than encouraging employers to include qualifications in Apprenticeship standards and assessment plans the Institute for Apprenticeships actively discourages their inclusion unless they are a requirement to practice or used in hard sifting for job interviews.  For the reasons specified, this approach will act as a barrier for individuals wanting to progress at some stage of their Apprenticeship to further learning or a different or higher level occupation. Whether Apprenticeship certificates issued by the Institute for Apprenticeships will have currency with employers and equally importantly educational organisations that offer opportunities for further learning is as yet to be determined. The current Institute for Apprenticeships (IfA) statement that ‘ Recruiting employers and apprentices use (Apprenticeship Certificates) as a licence for the occupation and to access related professional status’ is an aspiration rather than a statement of fact.

 

 

January 2018