QUA0067

Written evidence submitted by MiddletonMurray

Introduction

1. MiddletonMurray is a leading independent training provider, providing bespoke apprenticeships and a vocational alternative to traditional further education pathways. We help bridge the gap between education and employment for young people through the provision of traineeships and apprenticeships, which lead to rewarding jobs and careers. Since entering the training sector in 2008, we have worked with nearly 11,000 individuals on our apprenticeships and traineeships, and we have now expanded to 14 offices across England, and a branch in the USA.

2. MiddletonMurray welcomes the opportunity to provide evidence to the Education Select Committee, and would be pleased to provide further evidence in any way the Committee sees fit. 

Executive Summary

3. The quality of apprenticeship provision has been on an upward trajectory in recent years. However, recent changes to the system, for example the introduction of Standards, threatens to disrupt this.

4. Ofsted inspections are fair, useful and thorough, however there is an issue with capacity that can result in a lack of regular inspections. This can result in a delay identifying problems that lead to quality suffering.

5. The funding streams for apprenticeship contracts are confusing, faceless and bureaucratic. This causes uncertainty for providers and is poor value for the taxpayer. There is also no appreciation for commercial pressures and the difficulties that delays to funding etc. can cause. It is essential that this is reformed.  

6. There should be stricter regulations on subcontracting, which is often substandard. Contract holders and subcontractors should both have to take responsibility if quality is found to be lacking, and Ofsted should also inspect subcontractors in their own right.

7. There are serious barriers to those from a disadvantaged background to access good quality training, and they are harder to retain on courses. Providers should be encouraged to widen participation by changing how success rates are calculated, and all levy payers should have to fill a quota of new apprentice hires for young people aged 16-24 to open up new opportunities, ideally from a disadvantaged background.  

The Quality of Current Provision

8. The quality of apprenticeships vary across level, sector and region, but the general direction is positive.

9. Outcomes have stayed relatively constant since 2011 against a backdrop of a much stricter set of rules and regulations.[i] The introduction of the minimum duration of a year for the completion of apprenticeships, the 20% mandated learning time and issuing success rates in a much more transparent manner with a stricter methodology has been positive. This has immediately increased quality without having a negative impact on success rates, and learners’ satisfaction rates have stayed steady.[ii]

10. However there is still room for improvement and quality does still vary by provider and sector; this is clear from the National Achievement Rate tables which reveal that 9 FE colleges and 47 private providers had achievement rates of less than 50%.[iii] However, poor quality is often reflected in inadequate Ofsted ratings.

11. Despite criticism of Level 2 apprenticeships, it is essential that they are retained as a way to widen access to higher level apprenticeships. Criticism is often unfounded if the apprenticeships are delivered properly, with significant levels of classroom teaching. This provides a good outcome for the learner and the employer.

12. The introduction of standards has caused confusion within the sector and threatens outcome rates for example, the end point assessment process hasn’t been clarified yet. This uncertainty makes it difficult for those delivering contracts to plan ahead. This should be rectified as soon as possible.

13. In order to ensure that progress does not stagnate, providers should be rewarded financially for getting above average achievement rates via a value added system (similar to that used by schools) which rewards quality apprenticeships and good achievement rates.

The Effectiveness of the quality monitoring system

14. MiddletonMurray’s own experience of Ofsted inspections are positive, having been inspected three times in three years and achieving a ‘good’ grade for both apprenticeships and traineeships in every inspection.

15. We have found the inspectors to be very thorough. The inspectors spend a lot of time to hear the training provider’s perspective, and then test all the evidence by talking to staff, learners, employers etc. We have found it to be a very useful tool, leaving each time with clear recommendations for improvements.

16. The length of Ofsted visits (4 days) and the short notice (48 hours) means that they get a true picture of the provider. We believe that this system works.

17. Similarly, the complaints system for both Ofsted and audits is transparent.

18. However, Ofsted’s capacity is an issue. It is likely that Ofsted will struggle to inspect all of the providers on the RoATP. Ofsted therefore needs to sensibly prioritise the organisations that they inspect – there are some organisations with a large number of learners who are only inspected every 7 years, whereas some organisations with very few learners are inspected more regularly. Ofsted should ensure all providers are inspected regularly, and prioritise those who are delivering a large number of apprenticeships.

19. Our experience of Ofqual when designing standards has been positive. We believe that they are experts and should be used as end point assessors for all standards, therefore guaranteeing quality.

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

20. The funding system for apprenticeships is complex, bureaucratic and lacks professionalism. It urgently needs reforming.

21. As a training provider, we have found the system difficult to navigate, inflexible and at times unprofessional. For example, in the recent non-levy tender, ESFA asked providers to tender, then abandoned the process, then asked providers to retender again, before missing their own deadline to announce funding allocations. Furthermore, there can be large delays in receiving funding for apprenticeships that have already been delivered. This puts the ability of providers to deliver apprenticeships for SMEs at risk, and there is little appreciation of the commercial pressures that commercial providers face – despite them delivering 75% of apprenticeships.

22. As well as difficult for providers to access, ESFA are often failing to deliver value for money. The processes that were used to award non-levy contracts resulted in some grade 1 and 2 providers being unable to deliver contracts, yet a contractor who went bust months before was given a contract.[iv] In order to deliver value for money, ESFA should ensure that they prioritise those organisations who have a proven track record of delivering quality apprenticeships for contracts during tender processes.

23. The difficulty faced by organisations applying for funding through ESFA is often exacerbated as although individual members of staff are often helpful, there is a high turnover of staff and little consistency with who providers deal with.

24. Funding guidance is long and often variable. There are regularly grey areas in the guidance, and it is difficult to obtain any clear answers. Typically, this can involve an individual having to view several different lengthy documents to find an answer, and it is not uncommon for much of this guidance to be contradictory. Additionally, these documents are regularly pulled from the ESFA website, causing confusion and misunderstanding for providers and those trying to audit their work. We have unfortunately experienced this, and not only did it result in the loss of a significant amount of time, it also put our funding in jeopardy to deliver a specific contract. The situation was only rectified as we had saved a copy of the particular guidance (which was no longer available online) that we could then show to the auditors. Situations such as these are common and means that providers have to be resilient and persistent with the ESFA in order to get the funding they are entitled to.

25. Similarly, it has recently become clear that some organisations are now deemed too big to fail, yet smaller ones are penalised and judged more harshly than those organisations. A clear example of this was Learn Direct being able to continue to deliver apprenticeships until the end of their contract, rather than being immediately terminated which would be expected for smaller providers.[v] This is delivering poor value for taxpayers and is short-changing the young people affected. This situation should be urgently addressed.

26. Additionally, we have concerns that there is sometimes not a good understanding of the needs of an organisation when delivering the new standards. This is clear from the funding allocations that are being awarded, which seem arbitrary and without adequate funding, quality apprenticeships cannot be delivered. There are now significant delays in the IFA signing off standards due to disagreements over funding with the trailblazers who have designed them. This is something that we have experienced directly as a trailblazer for the recruitment standard. This is something that we have experienced directly as a trailblazer for the recruitment standard, which had to be revised upwards from the initial funding of £4,000 for a Level 2 apprenticeship and £3,000 for a Level 3 apprenticeship. Both levels are now paid at £5,000.

27. More widely, there are concerns in the sector about the future of commercial providers who deliver apprenticeships. The Sainsbury Report stated that “Ideally, all publicly-subsidised technical education – notably college-based courses and the off-the-job component of apprenticeships – should be delivered under not-for-profit arrangements”.[vi] This is clearly in contrast to the reality of apprenticeship delivery where commercial providers deliver 75% of apprenticeships.[vii] Yet, when tendering for contracts, independent training providers have to put in financial details and get more budget if they are in a stronger financial position, whereas colleges do not have to do this. Colleges should have to compete on a level playing field with independent training providers to ensure that courses are sustainable and therefore taxpayers are getting the best value for money. 

Quality and oversight of training provided by subcontractors

28. The quality of training provided by subcontractors is variable and is often not good enough. This is why MiddletonMurray does not do subcontracting. We do however accept that in some cases there is a need for subcontracting, although would argue that this should only be used in small, specialist industries rather than for apprenticeships that are widespread and easily delivered, e.g. Business Administration.

29. There are no restrictions on how much a provider can subcontract. For example, a provider can subcontract 100% of their delivery of a contract whilst charging a significant overhead. This is poor value for the taxpayer and as there is little quality control, it can be detrimental for the learner.

30. Often, colleges will subcontract towards the end of their contract if they are unlikely to fully fulfil it, in order to receive full funding. This can result in a serious drop in quality as courses have to be delivered quickly, and there should be safeguards against this. 

31. We welcome the change in rules that says every contract holder has to display their percentage management charge on their website if they subcontract. This is a significant step forward, but more could be done to ensure value for money, e.g. a maximum management charge. 

32. Oversight is lacking although poor quality subcontracting can be picked up when Ofsted inspects the contract holder which often picks up that quality is lacking. However, to ensure that this is more effective, Ofsted should also be routinely inspecting major subcontractors, and holding the subcontractors and the contract holders to account for any inadequate standards.

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

33. The quality of training received by the socially disadvantaged is often of a good quality, although we do have concerns that in some industries there will not be good career prospects. However, the barriers to socially disadvantaged young people accessing such training is significant.

34. We note with concern that there has been some criticism of the minimum duration of apprenticeships, and the 20% learning target. For apprenticeships to have a parity of esteem with degrees, and to demonstrate that they are rigorous, it is essential that this is retained. Employers should be willing to give this time to boost their employee’s skills and productivity. We therefore believe that 20% is about right.

35. However, we would support Maths and English keyskills being taught in this 20%. Burdening employers further by taking those who do not have English and Maths into the classroom for even longer periods will unfortunately result in employers being biased towards high achievers who have already achieved the required grades in English and Maths. Furthermore, maths and English are paid at just £471 each, despite the volume of work which has to be put in to deliver quality courses, e.g. one-to-one teaching, which means that they are lossmaking. This discourages some training providers from taking on young people who require this support. This is harmful to social mobility, and makes it more difficult for those without the grades to access good apprenticeships.

36. It is essential that level 2 apprenticeships are retained to widen access to training. Often, a level 3 is initially too hard for individuals and this is more likely to be the case for the socially disadvantaged. Therefore, a robust level 2 qualification should be encouraged and seen as a stepping stone to a higher qualification for individuals who would initially struggle at this level.

37. Socially disadvantaged individuals are harder to reach, and are harder to work with, and harder to retain. Approximately 18% of MM learners are classed as socially disadvantaged (based on learners eligible for bursaries). Our experience shows that it is often a lack of confidence and aspiration amongst individuals that creates a reluctance to initially engage with providers. 

38. A lack of good careers advice is also a significant barrier for the socially disadvantaged.[viii] The current system of careers advice is inconsistent and ‘patchy’, geared towards higher education and more academic pathways, and is simply not suited to meet the demands of Britain’s contemporary economy. Careers advice should be made more easily accessible and look at traditional and non-traditional ways of accessing careers. For example, advice should be easily accessible on the internet or through a podcast (which Angela Middleton, CEO of MiddletonMurray, has created to provide careers advice for people whenever and wherever they want to access it).

39. There is currently a significant move towards ‘elite’ apprenticeships which threatens to further hinder those who are socially disadvantaged. For example, there are many providers who will not take young people who do not have good A level’s. There is a danger that if this becomes the norm then we will move away from the founding ethos of apprenticeships.

40. In order to ensure that those from disadvantaged background can access elite apprenticeships, levy payers should have to fulfil a specific quota of their apprenticeship hires with young people aged 16-24, and ideally from a disadvantaged background. This will open up new opportunities for young people and ensure that the levy is in-keeping with the ethos behind apprenticeships.

41. It is easier for providers to work with already high-achieving individuals and achieve good results, yet there is no recognition for providers who work with socially disadvantaged individuals, with all providers being compared merely on their success rates.

42. Success rates could be changed to factor this in and encouraged training providers to work with more socially disadvantaged individuals. For example, success rates could use a value added system similar to those in schools where the progress of an individual is assessed from their starting point.

January 2018