QUA0048

 

Written evidence submitted by the Association of Colleges

 

Background

 

  1. The Association of Colleges (AoC) represents nearly 95% of the 279 colleges in England incorporated under the Further and Higher Education Act 1992.

 

  1. Colleges are drivers of social mobility, economic growth and community development. They provide high-quality technical and professional education, particularly at advanced level and covering a broad range of disciplines ranging from science, engineering and IT to construction, hospitality and the creative arts. Colleges educate and train three million young people and adults, including 300,000 apprentices. In doing this, they support people into careers as well as strengthen the economy.

 

  1. The Committee has invited views on whether employers, learners and tax payers are getting value for the time and money invested in training, and whether more needs to be done to detect poor-quality provision. Our response is organised so that it addresses the questions posed by the Committee.

 

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

 

  1. Government action has brought change in every part of the apprenticeship system. The bigger changes include:

 

 

  1. There are good reasons for each individual change though negative consequences from some. Our response will explore some of the details, but we should stress the disruptive impact of implementing all these changes at the same time.

 

  1. One issue of immediate concern is the reduction in the number of apprentices. New systems often bring reductions in activity, but the fall this time seems very large. Data collected by AoC from 91 colleges in November 2017 suggested a 39% fall in the numbers of apprentices compared to the same point last year. There are a number of factors which may be contributing to this situation and which may be worth investigation:

 

 

  1. We believe that the Committee should consider some of these issues but also suggest that there will be consequences for the quality of current provision and the variations between sector, region and level of study. There are several points that we would like to make:

 

 

 

 

 

 

 

 

The effectiveness of the quality monitoring system, in particular the role and capacity of Ofsted

 

  1. The systems for monitoring quality in apprenticeships are complicated, but it is worth stating up front that the key to quality of teaching and training is the quality of the teacher or trainer. The success of the UK’s apprenticeship ambitions depend mainly on the people engaged in supervising and training apprentices.

 

  1. Ofsted has the main responsibility for monitoring quality in government regulated and funded organisations, but will struggle to inspect and oversee a growing number of providers with direct funding contracts. The number of providers has recently increased by over 30% and there are more applicants for the RoATP at every opening. Leaving the inspection of new market entrants for three years is a risk. Ofsted works collaboratively, is adapting its focus and is asking many of the right questions, but its grades are over-used as an indicator of quality. Some multi-disciplinary colleges have inspection judgements that they require improvement. The use of these grades by Government and large employers means that the strength of their apprenticeship training may be under-used. The ‘one size fits all’ grade can also mask strengths and weaknesses in individual curriculum areas.

 

  1. There is also a potential overlap between Ofsted and other agencies with responsibilities in this area. The Institute for Apprenticeships (IfA) has oversight of apprenticeship standards, whereas Ofsted inspects their actual delivery. Where apprenticeship standards include qualifications, Ofqual will be involved. Degree apprenticeships involve universities, the Quality Assurance Agency (QAA) and the Office for Students (OfS). There are quite complicated partnership arrangements between agencies to oversee higher and degree apprenticeships. Meanwhile, the new rules about end point assessment and the requirements to commission separate apprenticeship awarding organisations create further complexity and also the likelihood that published completion rates will decline in the next few years.

 

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

 

  1. The Education and Skills Funding Agency (ESFA) has a very wide remit covering 23,000 schools and several other sectors as well as apprenticeships. The skills part of ESFA has an administrative budget which is about 50% smaller than it was in 2010. ESFA work on apprenticeships and in the last 18 months has focused on implementing the new digital service (DAS), the new register (RoATP) and the new funding rules. There have been some successes – for example, the IT for the digital service was delivered on time and appears to be robust. However, ESFA have had a large number of tasks to deliver at speed and this will have problems. There was little proper testing or research for the new funding rates. There has also been a transactional approach taken towards deciding which organisations can be on the training register. ESFA’s role has been more as an enforcer of policy rather than developers of it. Ensuring value for money ultimately sits with Government and its Departments – DfE in this instance.

 

  1. DfE has published a benefits realisation plan, but we would like to see more reporting against that plan and honest and realistic assessments of the potential tensions in the system. For instance, some standards look more like job descriptions than occupational descriptions, suggesting that whilst they may help deliver people who can do a job today, they may fail the test of social mobility and progression into a career. The tension between what an employer needs now and the skills, experience and knowledge which will support an apprentice over a fifty year career need to be spelt out more fully in the assessment of value for money.

 

  1. The apprenticeship training register is a particular concern. Ministers have strongly encouraged colleges to focus on apprenticeships. In response, colleges have risen to the challenge. Colleges have explained the benefits to employers and worked hard to develop a new offer for apprentices. They have integrated their apprenticeship within the wider offer to students and employers. In future, this offer will include T Levels. For colleges, apprenticeships are not simply a ‘side-contract’ or sideshow to the main core business. Losing non-levy apprenticeship funding through a tendering process weighted towards new market entrants is a significant problem with wide implications. Colleges have longstanding and strong relationships with employers which are highly valued by both parties. The colleges affected include some of the most successful in the country.

 

  1. Unlike the approach taken by DfE elsewhere in education (for example in the new Office for Students register of universities and higher education providers), ESFA's commissioning approach is based on a single written application, takes no account of track record, allows no discussion on details and put at risk all the funding in one process. This is in danger of preventing colleges with decades of experience from training young people for local employers while bringing in new companies with no track record based on an untested and speculative plan. All weight has been given to writing a good bid, with no consideration for evidenced and sustained track record of delivery. Asking everyone the same questions does not equate to treating everyone equally. ESFA's funding rules involve no provision for staff transfers from unsuccessful to successful bidders and make sub-contracting incredibly difficult. This means that the rational economic choice for the rejected colleges would be to close their apprenticeship training facilities and redeploy or make redundant their experienced staff. Colleges are also key strategic players within local skills planning and the cost of extricating them from this infrastructure will far outweigh the funding allocations that were being sought.

 

Quality and oversight of training subcontractors

 

  1. Good subcontracting is a crucial part of the apprenticeship programme, to support employers to have a complete coverage of all of the standards in their organisations. Good subcontracting allows colleges and others to pull together partnerships of providers that can provide a comprehensive, high quality offer to employers through one point of contact. The quality and oversight of subcontractors is the direct responsibility of the prime (or lead) contractor. It is critical that the Government through its agencies, effectively manage the primes and ensure that they retain full control of the quality of delivery that they have sub-contracted. This is achieved through the ESFA funding rules which cover subcontracting within apprenticeships. Most weak sub-contracting has been removed from the funded apprenticeship offer in England due to the changes in funding flow. Providers no longer have an annual allocation to underspend, so there is no need to find subcontractors at the eleventh hour to ensure the full allocation is committed. ESFA rules are also designed to remove ‘managing agent’ style relationships from the apprenticeship market, meaning only bona fide apprenticeship delivery organisations can work together to meet employer needs.

 

  1. Subcontracting within colleges has dropped significantly over the past few years and been replaced with direct delivery. Where sub-contracting still exists in colleges, the models are generally strong and reflective of local demand from both employers and the subcontractors themselves. The alterations to subcontracting rules should provide ESFA with sufficient control over subcontracting. They should be encouraged to use these rules sooner rather than later to challenge those who are not displaying appropriate behaviours in subcontracting.

 

  1. Subcontracting rules also need to evolve to deal with new circumstances, such as the role of universities in apprenticeships. College/university partnerships are well placed to meet the needs of employers across a wide range of need, and subcontracting provides an effect way to give employers access to a complex support offer through a single, simple relationship. Such relationships are also good for individuals seeking to progress through apprenticeship levels. This type of subcontracting could provide a comparable route within apprenticeships to those existing between colleges and universities for more traditional learning such as Higher National Diploma/Certificate programmes that allow learners to enter the second or final year of a full degree.

 

Quality of training received by the socially disadvantaged, and barriers to them undertaking this training

 

  1. There are a range of barriers to quality apprenticeship and skills training for the socially disadvantaged ranging from an intangible belief that training is not intended for them, to practical transport problems. This coupled with the fact that there are insufficient incentives within the new funding system to encourage training providers and employers from working with socially disadvantaged individuals means that the socially disadvantaged are perhaps further away from opportunities than in recent history. Employer choice could mean priority will be given to using apprenticeship funding for mid-career adults with recent work experience and a settled lifestyle, against unproven young people who will need much more support and guidance both within the job and in off-the-job training. Many employers will inevitably focus on their core business unless there are sufficient incentives and rewards to do something different. The role that colleges have had in the past in persuading employers to take more difficult apprentices will fall away if the relationship is solely one of client and contractor.

 

  1. The new system also transfers control over a large part of the training budget to large employers headquartered in the South East. Putting employers in control of spending has many benefits, but the economy and jobs are changing. Today’s employers are getting a larger share of training funds but may be in sectors that will get smaller in future. They may perpetuate English training patterns which are currently biased towards Level 2 skills in low value service roles where there is substantial gender and ethnic segregation.

 

  1. The Government recently published the Maynard Review with recommendations for apprenticeships with disabilities and learning difficulties. The new flexibility on English and maths is helpful, but only apply to those with Education Health and Care Plans (EHCPs). Young people with EHCPs are a small minority of those with disabilities and learning difficulties who might require this flexibility. More also needs to be done to make employers aware of the specific support on offer, for example through the Access to Work scheme.

 

  1. There are also financial obstacles for apprentices from low income backgrounds. Recent fiscal measures to encourage employers to recruit young apprentices have not been matched by incentives for parents of the apprentice themselves.

 

  1. Incentives to employers include the lower apprenticeship minimum wage, the apprenticeship ‘bonus’ of £1,000 for various categories of apprentice and abolition of employer’s National Insurance for apprentices under the age of 25.

 

  1. Penalties for parents include the removal of child benefit if a young person takes an apprenticeship rather than a full time academic or vocational course which has knock-on effects for housing benefit and other similar proxies.

 

  1. A decision to extend child benefit to the families of apprentices would be relatively straightforward to enact in law and administratively because it would apply to parents and young people already known to DWP. AoC estimates that the annual child benefit cost would be £100 million on the assumption that the parents of 120,000 apprentices across the four parts of the UK became eligible for the full payment. This is less than the £300 million currently spent to incentivise employers via grants and national insurance waivers.

 

 

January 2018