ESFA failing to curb apprentice assessment ‘bundling’

Awarding bodies call for clarity after rules watered down and culprits 'hide in plain sight'

Awarding bodies call for clarity after rules watered down and culprits 'hide in plain sight'


Awarding bodies are demanding clarity over the government’s position on “bundling” of apprenticeship end-point assessments (EPA), after officials watered down the rules on the banned tactic.

It comes after years of allegations that professional bodies are unfairly offering extra perks or inducements to their EPA offer despite being ineligible costs, with no decisive action from officials to curb the behaviour.

The additional services can include, for example, membership, chartered status, or additional materials free of charge to apprentices who have their EPA carried out by the professional body.

Other end-point assessment organisations (EPAOs) have long complained this practice disadvantages apprentices who undertake their EPA with a different EPAO and has created an uneven playing field.

Education and Skills Funding Agency policy was previously clear that EPAOs “must not” bundle in any extra products or services into their EPA offer. Officials have also issued multiple warnings to the sector, including in March 2023 when an update revealed “we have had several instances of ‘bundling’ brought to our attention in recent weeks” with a vow to identify and clamp down on individual culprits.

But in September 2023, the ESFA launched the new apprenticeship provider and assessment register (APAR) and weakened the wording of its rules to state that officials now only “do not expect you to promote or offer any additional financial reward, service or membership to improve your likelihood of being chosen by a provider”.

Smaller EPAOs allege that “bundling” is still rife and providers are being strongarmed into doing their EPA with professional bodies. They are calling on the government to enforce their rule or be clear that the behaviour is now allowed.

David Pearson, chief executive of DSW Learning, said: “The bundling of products and services alongside end-point assessment violates ESFA conditions and it does so for good reason; the practice disadvantages apprentices, brings EPA into disrepute, launders the levy, and restricts competition. 

“DSW are one of several end-point assessment organisations that have repeatedly reported the issue. We would like the ESFA to take decisive action against this practice, or to confirm that the bundling of additional services is now tolerated, and in doing so enable those organisations that play by the rules to do so on a level playing field.”

Jacqui Molkenthin, an independent EPAO consultant, told FE Week the ESFA has failed to take any enforcement action despite bundling “hiding in plain sight on some EPAO websites”.

She said the ESFA has caused “disillusionment” that officials will ever act on an issue that is “directly negatively impacting the marketplace”, adding that the agency “need to make a choice, do they, or do they not permit bundling, and if they do not then they must enforce their condition”.

The Department for Education refused to clarify its position when approached by FE Week, and instead repeated that the ESFA “do not expect EPAOs to promote or offer any additional financial reward, service, or membership to improve the likelihood of their being chosen by a provider”.

Websites altered as bodies deny bundling

Every apprentice takes an end-point assessment at the end of their training to confirm the person meets the required occupational standard. Each EPA must be conducted by an independent organisation, and it is up to training providers and employers to choose the EPAO at the beginning of the apprenticeship.

Competition in the EPAO space is fierce and has allegedly led to the deployment of extra incentives by some professional bodies. The practice can include explicit bundling, such as including membership to a professional body, or implicit bundling such as exempting some apprentices from examinations and fees to gain professional status based on their choice of EPAO.

Professional bodies have also been accused of offering discounts on their non-EPA products or services if they are used for EPA, such as discounted qualifications; or threatening that discounts will no longer apply on the non-EPA products if they are not used for the EPA.

FE Week approached multiple professional bodies who had been accused of such behaviour, but all denied any wrongdoing.

Several have however changed their websites since FE Week’s approach.

The Chartered Management Institute’s website has for years stated that “CMI is the only professional body who can award chartered manager status and has it embedded in the EPA”. 

Another section said: “If you’re completing EPA only through CMI then on confirmation of your apprenticeship result you are eligible for: foundation/full chartered manager status (depending on your apprenticeship standard); three months free CMI membership”.

A CMI spokesperson denied that it includes any additional services in its EPA offer and insisted that “any” apprentice who has successfully passed the relevant EPA can apply for chartered status at their own cost, no matter which organisation they do EPA with.

The institute then altered the wording on its website to state that CMI “is the only professional body who can award chartered manager status which apprentices can apply for, following their EPA”.

Another section now reads: “If you have completed your EPA only with CMI or have completed your EPA with another end point assessment organisation, you will have met the knowledge criteria for becoming a chartered manager.”

While not permitting bundling is an ESFA condition, EPAOs must also comply with Ofqual’s conditions, one of which says: “An awarding organisation must not advertise or promote its qualifications in a manner that is likely to be misleading to users of qualifications.”

Molkenthin pointed out that if an EPAO does not bundle then it must not market in such as way as to mislead users to think it does.

The Institute of Sales Professionals (ISP) was also alleged to offer free membership to training provider staff and apprentices that only use the institute for EPA. Its website said: “Every training provider and learner studying towards an ISP-assessed apprenticeship standard will get the added benefit of a free associate membership.”

But an ISP spokesperson claimed the institute did not “bundle” and insisted this offer was open to all provider staff and apprentices on sales-based apprenticeships, regardless of which EPAO they did their assessment with. 

The institute’s website was changed after its response to FE Week to say: “Every training provider and learner studying towards a sales-related apprenticeship standard will get the added benefit of an optional, complimentary student membership.”

Competitor EPAOs and providers also alleged the ISP mandates an additional qualification be taken in the sales executive level 4 apprenticeship, which is not included in the assessment plan and is being bundled with EPA.

ISP’s spokesperson admitted the institute does make an additional qualification available as an option, which comes with additional charges if providers choose to include it, but denied the offer was mandatory.

“It is a however requirement that any training provider or educational organisation offering any ISP-Ofqual regulated qualifications must be approved by the ISP as the awarding body, for which additional charges are applied outside the eligible costs of end point assessment,” the spokesperson said.

They added that the ISP has been “aware for some time” about the concerns of bundling, but said the institute has not been approached by the ESFA or any other regulatory body in connection with this issue. 

It has however sought assurances that the way it makes student membership and ISP certification available to apprentices is appropriate twice over the past 12 months.

On both occasions the ESFA said they “did not regard our approach as bundling”, the spokesperson said.

‘We have been fully transparent on our approach’

Elsewhere, apprentices who successfully complete their senior people professional apprenticeship EPA with the Chartered Institute of Personnel and Development (CIPD) are automatically entitled to apply for chartered membership, subject to standard membership and joining and fees.

But if an apprentice completes the same apprenticeship EPA with a different EPAO they are asked to undertake an upgrading assessment, with a cost of £120 for a telephone assessment and £60 for a form-based assessment, to determine whether they can apply for chartered membership.

A CIPD spokesperson denied this was bundling additional services within its EPA provision, adding the institute has been “fully transparent on our approach with both ESFA and the relevant regulatory bodies”.

The Chartered Institute of Housing (CIH) has meanwhile allegedly told providers that apprentices who use the professional body as their EPAO are eligible for free student membership, but apprentices with other EPAOs would have to pay a fee.

CIH refuted this and claimed it has always offered free membership to all apprentices studying housing, no matter which organisation does their EPA.

It has however decided to start charging £78 for membership to all learners from April 1, 2024.

Active IQ is another EPAO accused of “bundling”, specifically that it offers free qualification registration with a range of EPAs, including sports coach, team leader and early years.

A section on its website, which has been removed since FE Week’s contact, said: “Our EPA fee includes comprehensive apprentice and teaching resources, as well as free additional, supplementary qualifications where available.”

Jenny Patrickson, Active IQ managing director, said: “Where an apprenticeship provider wishes to purchase further services in addition to our EPA delivery for them, they are required to go through Active IQ’s centre approval process.

“This incurs additional costs and process for them, which we administer completely separately, to ensure that any supplementary qualification delivery, assessment, or quality assurance activity is distinct from the EPA services being provided. We are currently reviewing our marketing materials and web pages to ensure clarity for all providers on our offering.”

Prior to the launch of APAR, the DfE told the sector on multiple occasions it would remove EPAOs from the apprenticeship market if they breach its conditions including by “bundling”. 

The department refused to say whether it has taken any direct action against a bundling culprit to date.

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