QUA0063
Written evidence submitted by NHS Employers
1.1 NHS Employers is an organisation which acts on behalf of NHS trusts in the National Health Service in England and Wales. It is a part of the NHS Confederation, and negotiates contracts with healthcare staff on behalf of the government. NHS Employers represents NHS trusts in discussions with national bodies on the development of workforce policy, and has a remit to share NHS employer views on the implementation of apprenticeship policy and programmes.
2.1 NHS Employers welcomes this inquiry into the quality of apprenticeships and skills training, in particular exploration of the role of the Education and Skills Funding Agency in ensuring value for money, and the impact of different funding models. From our findings and engagement with members, we have established it is crucial for the conditions to be put in place to enable the NHS, as the largest employer in the country, to scale-up its offer of high-quality apprenticeships in all areas of the service. This ambition is dependent on the way the apprenticeship levy is administered being suitable to support the health service and the specific challenges it faces.
2.2 The introduction of the apprenticeship levy in April 2017 has provided an opportunity for the health service to significantly scale-up it’s approach to embedding apprenticeships into the way we recruit and develop talent in the NHS. In the last 12 months, we have seen a marked increase in the range of apprenticeship standards available for healthcare specific courses, and we’re hearing from employers who are taking novel approaches to recoup their levy costs.
2.3 Employers across the NHS are expanding their apprenticeship programmes, but are facing some specific challenges which are unique to the health sector. In this submission, we outline these healthcare-specific challenges and make some suggestions for how flexibility in the funding models for the apprenticeship levy, provided by the ESFA, might have a dramatic impact on the NHS’ ability to make use of the apprenticeship levy and therefore increase the apprenticeship offer in health.
2.4 The three flexibilities we would ask to see applied to NHS organisations are as follows:
2.5 Employers in the NHS recognise the need to redesign the way care services are delivered to better meet the needs of patients. These organisations are committed to using apprenticeships as a way of enhancing and delivering the new skills required to help meet the changes, as set out in the NHS Workforce Strategy commissioned by the Secretary of State for Health, but require some further support through these flexibilities to realise these ambitions.
3.1 As one of the largest contributors to the levy (contributing £200 million per year) and a sector already under considerable financial strain, NHS organisations need to be given the best possible opportunity to use the levy to fill skills gaps in the workforce. Therefore, we strongly recommended that the deadline for the use of the levy should be extended from 24 months to 36 months during this establishment period.
3.2 Employers in the NHS at a local level, despite their ambitions to scale up the apprenticeship offer, are now faced with the challenge of setting up a large number of new, high-quality apprenticeship programmes. This growth in required programme establishment is due to a recent increase in the development and availability of apprenticeship standards suitable for the NHS, and a previous lack of standards available.
3.3 Of the 1.2 million staff employed in the NHS more than 481,000 were in roles that did not have a relevant apprenticeship standard available when the levy was introduced in April 2017. Since the introduction of the levy, the number of apprenticeship standards available for the NHS to offer has more than doubled to a current total of 37, which provides a sizeable opportunity for employers, but will require time and resource to establish and embed them.
3.4 Currently any unspent funds should expire 24 months after they enter a digital account. Delaying removal of levy funds from the digital account for a further 12 months, in addition to the already agreed 24 months, would have a significant impact on the NHS’ ability to increase its apprenticeship offer using newly developed healthcare apprenticeship standards.
4.1 As a result of scaling-up the NHS’ approach to embedding apprenticeships throughout the workforce, organisations are coming under increasing pressure to provide more placements and learning support in the workplace. This pressure is further compounded by emphasis from government to expand traditional nurse training places and introduce the nursing associate training programme into their workforce. A combination of these activities will strengthen the supply of skills into the NHS, but has a significant impact on training and supervisory requirement.
4.2 Practice supervision and assessments are offered by registered healthcare professionals who are based in practice and carry this out on top of their other daily duties. If employers are to increase the number of apprenticeships offered in the NHS they need to scale up their capacity to offer work based learning but be able to do this in a way that is both affordable and cost effective, and supported by a funding system that allows for flexibility.
4.3 Better value could be gained from the levy if employers in the NHS were able to use some this funding to support a wider range of training activities to help deliver successful apprenticeships. This could include training those required to undertake the supervision, assessment and mentoring of apprentices and enable them to carry this out in a consistent way. Allowing the levy to backfill and provide protected time to undertake these tasks would bring them in line with other professions, and would provide a long-term return on investment in the future as these skills will be used for supporting apprenticeships and work-based learning delivered in the coming years.
5.1 Employers in the NHS recognise the value of, and support the 20 per cent ‘off the job’ training that forms a key component of an apprenticeship. However, for healthcare specific standards such as the Nursing Degree Apprenticeship, there is a much larger ‘off the job’ requirement (this may be up to 60 per cent). This time is considered supernumerary. The Nursing and Midwifery Council (2010) defines this as: ‘Supernumerary means that students will not, as part of their programme preparation, be contracted by any person or anybody to provide nursing care.”
5.2 This means that, although the apprentice will be in the workplace, undertaking tasks within their competency and scope of practice, they are not able to be considered a part of the workforce, and cannot be included in any staffing figures or calculations. In order to support this level of ‘off the job’ training, employers will need to provide back-fill for these individuals, usually at a rate of £7.88-£10.15 per hour.
5.3 This additional cost is a significant financial burden for NHS organisations wishing to offer the Nursing Degree Apprenticeship, and is proving to be a disincentive for establishing Nursing Degree Apprenticeship programmes. We recommend that, for apprenticeships where there is a supernumerary or ‘off the job’ requirement of over 20 per cent, NHS organisations are able to access their apprenticeship levy funds to contribute towards this additional, unexpected cost.
5.4 It is important to note that the challenges employers face relating to the supernumerary status (and associated back-fill costs) of the Nursing Degree Apprenticeship, are unique to the health service. The decision for Nursing Degree Apprentices to be supernumerary is beyond employer control, as it is a stipulation of an external professional regulator.
6.1 This submission has clearly articulated the enthusiasm and motivation the NHS has to use the apprenticeship levy to maximum effect to support development of new skills in the NHS, and has outlined the three flexibilities in that would enable the health service to have a stronger approach to increasing apprenticeships across the sector.
January 2018