Don’t blame providers for the levy’s unintended consequences

24 Oct 2019, 9:58

Apprenticeships may have cleared one storm, but new clouds are already gathering on the horizon. Simon Ashworth charts the troubled seas that could sway ESFA apprenticeships director Keith Smith’s appearance at the AELP autumn conference on Tuesday

I can see the headlines now: “Apprentices let down by poorly performing providers”, providing meat and drink for concerned MPs in any subsequent Commons committee inquiry.

True, the introduction of the apprenticeship levy suffered from a serious misfire with the establishment of a new register of apprenticeship training providers (RoATP) which, in its first phase, saw the government allow some entirely inappropriate players to enter the market.

Ofsted’s correctly applied risk-based approach to inspecting the new entrants and the subsequent RoATP ‘refresh’ have done much to rectify matters and we are now seeing reconfirmation that at least three of four apprentices are being supported by good or outstanding training.

Yet a cloud on the horizon threatens to revive questions about the quality of apprenticeships and could see training providers unfairly blamed. The pending publication of apprenticeship success rates for 2018-19 is expected to show an overall decline on previous years’ results which have hovered around the 66 per cent benchmark.

Some good quality providers are informing AELP that their success rates will show a fall by anything up to 10 per cent, varying across programmes and sectors.

The truth is that in the vast majority of cases, the falls will have absolutely nothing to do with a decline in the quality of the training apprentices are receiving. Instead, they relate to how the official data system records changes in employer or apprentice behaviour.

What we are now seeing are unintended consequences of the levy reforms that have made apprenticeships more employer-driven. Failures are being flagged that are anything but.

Failures are being flagged that are anything but

Under the old system, for example, apprentices who changed employers would carry on the apprenticeship with the new employer with no break. Shifting funding so that it now goes through employers instead of following apprentices means that now they are automatically counted as a non-achieving leaver.

Providers report that a significant number of SME employers have stopped paying the co-investment, resulting in the apprenticeship being terminated. Generally, as soon as an employee says that they are leaving a job, they are taken off the apprenticeship scheme.

These cases will count as failures on an individual provider’s published qualification achievement rates (QAR).

Other ‘failures’ counting against providers include apprentices unable to pass their functional skills tests – even if the employer wanted them to go ahead despite an initial assessment suggesting it was unwise – and employers removing apprentices from programmes they are finding too challenging.

It is important to recognise that, along with being harder and more challenging, apprenticeship standards are now longer in duration, which brings natural employee churn more into play.

One large provider recently ran an exercise on apprenticeship non-completion reasons comparing 2016-17 (mostly pre-reform) to 2018-19. They counted employer changes of circumstances and changes which were not the fault of the employer or provider as negative outcomes. The net outcome over the 12-month period was an 8 per cent reduction in the overall completion rate.

When standards were introduced, AELP argued that using the ESFA’s legacy success rate measures on frameworks needed to be rethought.

With standards, providers are contracted to specifically deliver the on-programme training and are paid the completion payment when the apprentices undertake rather than pass the end-point assessment (EPA).

The provider facilitates the end-point process on behalf of the employer, although the ESFA want to give employers yet more control of this process. Whether they actually need to is another question. Whether employers want it is yet another.

Let’s rewind the clock to consider other important changes that should not be forgotten.

Firstly, Ofsted have been clear that data will be less important than before when it comes to inspection under the new Education Inspection Framework. This is important because the inspectorate recognises that success rates on frameworks and standards are not directly comparable.

Instead, Ofsted is judging quality of provision and will focus on the starting point of each apprentice and their development of new skills, knowledge and behaviours. Providers need to know the rationale behind their performance in terms of progression and destination data.

Secondly, the ESFA has recognised the shifting landscape. Its suspension of the timely success measure was the first sign that they acknowledged the impact from the shift from frameworks to standards, with providers no longer having 100 per cent control of the end-to-end process. The employer and EPA have not only added new complexity to the system, but critically employers now decide when the apprentice is ready for assessment.

More recently, the ESFA announced they were removing their minimum standards of success as an automatic trigger for provider intervention as part of their new approach to provider oversight and risk management.

The agency is aware of the success rate issue and is apparently willing to consider possible changes to the QAR system. For its part, AELP is clear that providers should not be the punch bag for a potentially negative story about the quality of apprenticeships.

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