Treasury recoups £230m in unspent traineeships cash in last two years

Just a third of the government’s traineeships budget was spent during the past two years – with education chiefs handing back nearly £230 million to the Treasury, shocking new figures reveal.

The Department for Education last month announced it was axing the flagship pre-employment programme, and instead said it would be “integrated” into existing 16 to 19 programmes and adult education provision from August 2023.

Years of low take-up were to blame for the decision, with starts reaching just half and two-thirds of their respective targets in 2020/21 and 2021/22 despite huge additional investment aimed at helping young people to enter the jobs market during the Covid-19 pandemic.

Fresh figures published in response to a parliamentary written question from Toby Perkins, Labour’s shadow skills minister, have now revealed the extent of the flop.

In total, just £119 million of the £348 million allocated for the past two years was spent – 34.1 per cent. Breaking this down by individual years, the data shows that £127 million of the allocated £189 million went unspent in 2021/22 and £102 million of £159 million was unused in 2020/21.

Last year the government reported that a £65 million underspend had been handed back to Treasury officials in 2020/21. FE Week asked the DfE to clarify the discrepancy between that number and the £102 million underspend figure it has now reported for the same year, but the department refused to comment.

The DfE did however confirm that all unspent money on traineeships was returned to the Treasury’s coffers, rather than reinvested in other programmes.

The Association of Employment and Learning Providers (AELP) criticised last month’s decision to scrap the scheme, dubbing it “disastrous” and “short-sighted”. It called on the government to tackle the reasons for the low uptake rather than stripping away a programme that offered a vital opportunity to disadvantaged learners.

AELP’s director of policy Simon Ashworth said the underspend “should have been used to offer trainees a training allowance, which would have made traineeships much more attractive to young people”.

Ashworth said it was fortunate the impact of the Covid-19 pandemic on youth unemployment was not as bad as anticipated, while the Kickstart scheme – the government’s paid job opportunities programme for 16 to 24-year-olds on Universal Credit – had been more appealing.

He added: “We are in discussion with the Department for Education on how we can mitigate the impact of this decision on learners, providers and communities. To retain expertise and capacity, we are clear that those providers with a standalone 16 to 18 traineeship contract should be able to access 16 to 19 funding and as a result some flexibility from government is required to allow that to happen.”

Traineeships were introduced in 2013 to deliver pre-employment training and unpaid work experience for eligible 16 to 24-year-olds. They can last between six weeks and one year, although most do not exceed six months.

The DfE said it had encouraged the growth of traineeships by introducing occupation-specific routes, employer incentives and promotion through its Get the Jump campaign, but starts still remained low.

Figures published in November revealed that just 15,500 traineeship starts were recorded in 2021/22, compared with a target of 43,000.

A high of 24,100 was recorded in 2015/16 while just 17,400 starts against a planned 36,700 were recorded for 2020/21.

Data published this week on traineeship starts between August and October 2022 – just weeks before the programme was axed – indicated just 4,600 enrolments – a fall of 17 per cent on the same period last year.

In May 2022, education chiefs gave the programme a final chance by pleading with employers to rapidly boost their starts. The Education and Skills Funding Agency reminded local authorities of their statutory duty to help 16 and 17-year-olds who were NEET (not in employment, education or training).

The ESFA also provided £1,000 cash sweeteners to employers for each learner they took on through the programme from 2020 up to July 2022.

From August 2023, traineeships can be incorporated into existing 16 to 19 programmes and non-devolved adult education budgets, while mayoral combined authorities, which oversee their own AEBs, can decide what is best in their areas.

During last month’s announcement about the ending of the flagship scheme, skills minister Robert Halfon said it was right to focus on mainstream provision and highlighted “great alternatives” such as T Levels and the T Level transition programme, skills bootcamps and apprenticeships.

Demand doubles for free courses for jobs

Data released this morning by the Department for Education gives us a first look at adult learner participation in further education and skills courses this academic year. 

Here’s what we learned from the first quarter (August 2022 – October 2022):

Level 2 decline

There were 1,056,530 learners recorded this quarter, up 4 per cent, on the same period last year. Most of the extra 43,380 learners so far this year are taking courses at level 4 and above (up 11 per cent) and below level 2 excluding basic skills (up 7 per cent). 

However, the number of learners on full level 2 and 3 programmes fell by 9 per cent and 5 per cent respectively, representing nearly 23,000 learners.

A quarterly comparison of ESOL learners show there were just over 20,000 more in 2022/23 so far than for the same period in 2020/21. Most of that growth came from entry level courses.

There was also a small overall rise in community learning participation, with a 4 per cent bump to 119,180 learners. Figures reported growth in all areas of community learning, but the largest increase in learner participation was in family English, maths and language programmes.

Free courses for jobs demand rises

The number of adults that have started a course under the free course for jobs offer is double what it was for the same period last year.

In-year statistics for the first quarter of this academic year show that 10,670 enrolments were funded under the scheme, which fully subsidises the course fees of certain level 3 courses. 

There were 5,080 enrolments for the same period last year. 

Figures also reveal that the decision to extend eligibility criteria last year boosted enrolments by nearly 2,000. 

A major criticism of the free courses for jobs scheme was that it would only subsidise courses for learners that didn’t already have any level 3 qualifications. A small change was made in April which allowed level 3 qualified learners to access the scheme but only if there earned below the national living wage.

In its first full year, the scheme achieved just under 25,000 enrolments.

Free courses for jobs enrolments

CORRECTION: An earlier version of this story incorrectly compared figures for participation of learners aged over 50 for quarter 1 of 2022/23 with full year figures for 2021/22. That section of the story has been removed.

Apprenticeship starts fall 6% in first quarter of 2022/23

Apprenticeship starts in England dropped by 6 per cent in the first quarter of 2022/23 while traineeship starts fell 17 per cent, new government figures show.

Provisional in-year Department for Education data states there were 122,290 apprenticeship starts recorded from August to October compared to 130,240 for the same period in 2021/22.

The apprenticeship starts recorded for the first quarter of 2022/23 are also 3 per cent down on the 125,800 reported for same period in 2019 before the pandemic struck.

While starts are down overall, take up of higher apprenticeships has continued to grow – rising by 10 per cent from 38,230 in 2021/22 to 42,060 in 2022/23.

Starts at level 6 and 7 increased by 14 per cent to 22,060, which now represents 18 per cent of all starts reported to date for 2022/23.

The biggest drop was seen at level 2 – falling 18 per cent from 35,740 to 29,150. Starts at level 3 dropped 9 per cent from 56,270 to 51,080.

Starts for young people aged 16 to 18 dropped by 4 per cent from 40,130 to 38,480, while starts for those aged 19 and above fell 7 per cent from 90,110 to 83,810.

Today’s data provides further evidence as to why the government has decided to scrap traineeships.

Despite investing hundreds of millions of pounds in additional funding to ramp up the pre-employment programme after the pandemic, starts were down by 17 per cent to 4,600 in the first quarter of 2022/23 compared to 5,600 reported for the same period in the previous year.

There were 5,700 traineeship starts in the same period in 2019.

DfE offers colleges ‘reassurance’ over at risk capital projects

The Department for Education has confirmed plans to “possibly” introduce its own loans scheme for colleges after restricting the sector from commercial borrowing, as officials seek to reassure leaders over their “at risk” capital projects.

Colleges have had to gain special and rare permission to borrow commercially since November 29, 2022, when the Office for National Statistics changed their classification from private to public sector.

The overnight ruling has put numerous capital projects in jeopardy, as previously reported by FE Week.

In an update today, the DfE said it “recognises” the challenges the new borrowing rules present and reminded the sector that £150 million additional capital grant funding will be shared among to colleges in April (individual allocations can be found here).

Officials admitted that for “some” projects this new additional funding “may not be sufficient” in addressing any funding gaps resulting from reduced access to private sector borrowing.

The DfE’s finance and provider market oversight (FPMO) team is working directly with affected colleges in “priority order” through the new borrowing consents process.

Today’s update revealed that officials are also working on other “options”, including a “possible DfE-backed loans scheme for colleges that were intending to borrow commercially in order to fund a capital project”.

The department added: “We want to reassure you that DfE continues to be committed to all its capital programmes (e.g., FE capital transformation, post-16 capacity fund, Institutes of Technology or T Level capital), including projects which had been planned with commercial borrowing.

“Our intention is that projects funded through these programmes should continue.

“We will provide a further update in the coming weeks.”

Skills minister Robert Halfon revealed earlier this month that, as of January 11, the DfE had already responded to six colleges which had urgent requests for commercial borrowing in December. It is not clear whether these requests were accepted or rejected.

The DfE has received 63 other consent requests, of which 36 have capital projects as part of the request, from 24 colleges.

Julian Gravatt, deputy chief executive of the Association of Colleges, previously told FE Week that a DfE-backed loans scheme for colleges was on the cards, but said it was “unclear what the terms are” and warned there is a “risk of delay while the two sides discuss the amount”.

How to ensure ESOL meets learners’ and employers’ needs

ESOL provision has been a long-standing feature of adult education and the metro mayors have taken advantage of their devolved powers to champion it as part of their social inclusion agendas.

More recently and evidently flying under the radar, local authorities have been commissioning pre-Entry ESOL, in some cases drawing from the UK Community Renewal Fund (CRF), the forerunner to the UK Shared Prosperity Fund. This type of provision is likely to grow, and in an increasingly output-driven environment, it is important that we take on board the lessons from the pilot initiatives so far.

Between June 2021 and September 2022, Twin Training delivered a pilot programme for Leicester City Council to address the lack of pre-entry ESOL provision in the city. The ESOL for Communities programme was designed to help those furthest from the job market and most at risk of exploitation to access pre-Entry ESOL and receive one-to-one information, advice and guidance (IAG) on employment, benefits and accessing statutory services. Learners were also supported to begin working towards paid employment.

The East Midlands has a lower English language proficiency than most regions. In Leicester specifically, 7 per cent of residents cannot speak English well and 2 per cent cannot speak English at all. The challenge was compounded by a belief that existing government programmes were not responding sufficiently to the needs of local people and new arrivals who spoke little or no English. For example, prior to the pilot, Twin Training received 75 referrals per month onto our accredited ESOL provision through an ESFA-funded Skills Support for the Unemployed (SSU) contract but had to refuse circa 30 people each month because their complete lack of English meant that they were ineligible for SSU.

The adult education budget does not fund any pre-entry ESOL in Leicester. Those without the skills to enter funded ESOL programmes are forced to self-fund, continue to struggle without work or support, or suffer exploitation in the black or grey economy without opportunity for progression.

Meeting demand

As an established local ESOL provider, Twin was acutely aware of the challenges likely to be faced in taking forward the new pre-entry programme. However, various hurdles were successfully overcome, resulting in a very significant improvement in hard outcomes between the start and end of the pilot. On soft targets, 85 per cent of female beneficiaries, for example, reported increased confidence in challenging cultural barriers to employment.

We anticipated correctly that 40 per cent of the 225 participants would be from the local Indian community and that 72 per cent would be female from cultures where female education is typically limited. With the exception of Ukrainian refugees, the spread of the remaining ethnicities was thinner than predicted and a first key lesson was that many organisations tried to refer asylum seekers to the programme, suggesting a great need for pre-entry ESOL provision among this group.

We would suggest that future pre-ESOL projects broaden their parameters to include asylum seekers so they can develop their ESOL skills and access other support to obtain legitimate employment.  

Matching supply

Linked to entering the workforce, participants must reach at least entry level 2 to engage in conversation. In addition, many employers require level 1 ESOL to apply. We recommend that future programmes expand to at least 12 months to achieve entry level 2, stretching to 18 months if possible to enable participants to progress to level 1 ESOL qualifications.

To adhere to CRF guidance, Twin had to report qualification and employment outcomes immediately after contract close on 30 September. However, not all could be for bona fides reasons. Allowing for a three-month tracking period following contract close should ensure all outcomes can be accurately recorded. Similarly we propose a three-month contract extension to support those who start the programme in its final three months to ensure they receive the IAG support they need.

With nearly 80 per cent of participants continuing their education afterwards, the Leicester pilot has shown that pre-Entry ESOL programmes can have a major impact for adult learners and the economy, especially if providers can incorporate measures to increase the number of economically inactive participants who benefit.

GCSE re-sits: ‘Wrong’ grades drain students and resources

The November 2022 GCSE English and maths results announced on 12 January reveal a huge problem at the heart of the re-sit policy.

The summer and autumn English cohort sizes are significantly different (697,827 and 41,529 respectively) but the difference in the grade distributions is stark. In November, 42.7 per cent of candidates received grade 3, and 23.1 per cent grade 4, as compared with 17.2 per cent and 16.0 per cent in the summer. This clustering of the November results around the 3/4 boundary is no surprise; these exams are taken largely by candidates obliged to re-sit because they were previously awarded grade 3.

The problem is a more fundamental one. What the autumn grade distribution hides is that many candidates are forced through the distressing experience of re-sitting, not because they didn’t work hard enough or had a bad day, but because their grade was wrong.

Don’t take my word for it. In September 2020, Dame Glenys Stacey, then Ofqual’s chief regulator, admitted to the education select committee that exam grades are “reliable to one grade either way”.

Should that grade 3 have been a 2? Or a 4? No one knows. But what the candidate knows is that there is a world of difference between a 3 and a 4; Only one represents many more months in the classroom and another trip into the exam hall.

Dame Glenys’s statement can be quantified. In November 2018, Ofqual published measures of just how (un)reliable grades are: their report showed that about 61 per cent of the grades awarded in England for GCSE English language correspond to the ‘definitive’ or ‘true’ grade that would have been awarded had a senior examiner marked all the scripts. Unfortunately, there aren’t enough senior examiners, so ‘ordinary’ examiners do the bulk of the job. As a consequence, around 39 per cent of grades aren’t ‘definitive’ or ‘true’. In other words, they could be just plain wrong.

It’s a tragic waste of time students could be investing elsewhere

Importantly, this difference in grades is not attributable to marking errors. Rather, it is a consequence of a reality we are all aware of: different examiners can legitimately give the same script different marks. If those legitimate-but-different marks are on different sides of a grade boundary, the resulting grades will be different –  but only one will be ‘definitive’.

We’re discussing English here, but let’s do some maths.

According to JCQ, for the summer 2022 GCSE English exams, 17.2 per cent of 697,827 candidates received grade 3: That’s 120,026 candidates who have to re-sit (not counting those with lower grades, who aren’t impacted by this argument).

Ofqual’s measure of the reliability of GCSE English grades implies that only about 61 per cent of those 120,026 candidates received a ‘definitive’ grade 3, while 39 per cent – that’s 46,810 students – were awarded a ‘non-definitive’/‘untrue’/‘wrong’ grade.

This means up to a huge 46,810 students were awarded grade 3 (a de facto ‘fail’) in error. The grade errors are about the same both ways, so around 23,405 students should have been awarded a grade 2, and some 23,405 grade 4, and would never have had to re-sit – if only their paper had been marked by a senior examiner.

Nevermind the shocking waste of FE resources being squandered on re-teaching more than 23,000 students who didn’t need it. But for those more than 23,000 students, it’s a tragic waste of time they could be investing in their chosen pursuits.

And this is just one example of the consequences of Ofqual’s failure to deliver reliable grades, one that happens every exam season.

Unreliable grades are a menace, and the easiest fix is for all certificates to declare, using Ofqual’s own words:

OFQUAL WARNING: THE GRADES ON THIS CERTIFICATE ARE RELIABLE ONLY TO ONE GRADE EITHER WAY

And if we accept that, then pursuing a policy to ensure all students study maths to 18 must surely be based on a better proposition than ensuring a high proportion attain a more acceptable – but also unreliable – grade.

How to relieve Reflective Achievement Deficit Syndrome

Since Rishi Sunak’s proposal to extend post-16 maths to all, it seems everyone is reflecting on their own journey (or lack of) to maths enlightenment. Those of us who teach post-16 GCSE re-sit courses are practiced in enduring tales of contextualisation and how maths in colleges should teach mortgages and basic finances. But after many thousands of hours delivering resit maths lessons, I find the challenges GCSE maths resit learners face simply don’t echo these concerns.

Resit learners are enrolled onto maths courses because they have not achieved the level of maths proficiency determined by government. Their experiences are unique to this situation. So while I agree with the prime minister’s policy, it’s unlikely to succeed if it remains shrouded with talk of low pass rates and disenfranchised learners. When existing narratives of contextualisation and pedagogy are applied to this group, we too often observe negative results.

Consider a population divided into two groups, A and B. Group A are literate in a particular discipline, and group B are not. Logically, it is members of group A who become experts and teachers and whose advice and opinions about what they learned, how they learned it and in what context become valued. But their experiences are rooted in their history of belonging in group A.

When group A members ‘tell’ group B members the reasons why group A are so great – including the contexts and methods involved in making group A great – they are often alarmed that group B do not respond positively. In fact, group B members often rebel against this, sometimes angrily.

I observe this frequently in maths teaching. Conferences and training events are run by those in group A and discuss at length contextualisation and methods that worked for other members of group A. Yet our mission is to unlock group B!

We should focus on the context, not mortgages or tax returns

It seems group A members are more comfortable considering group B membership as a problem to solve. To that end, I propose a diagnosis of Reflective Achievement Deficit Syndrome – RADS, with the following characteristics:

  • A lack of belief in one’s own ability, which prevents the individual from responding to conventional learning and reflection processes.
  • Conscious or unconscious ‘blocking’ of learning and reflection processes that are effective with those not exhibiting RADS, rendering them ineffective.
  • Development of symptoms that can be attributed to socio-economic status, (similarly to self-efficacy issues as observed by Mingming Zhou and others), but can also relate to poor relationships with previous teachers and professionals and previous trauma (including the trauma incurred from repeated perceived failures).

Often, a feeling of success or achievement can combat RADS, but this can be hard to achieve or sustain. To do that, teaching and guidance needs to occur in the context of a RAD environment, rather than using conventional contextual learning and pedagogy.

With regards to post-16 maths resit courses, we need to think very carefully about how we contextualise our subject. Repeating how useful maths will be to them in the future only disenfranchises them further because grade 4 appears out of reach.

Instead, we should explain to learners that society needs them rather than the other way round. We need our resit learners to succeed for us all to benefit, and making that explicit foregrounds that they have a worth in the world. This is much more likely to be conducive than telling them they will never progress in life if they do not pass.

Likewise, delivering maths in the context of their elective courses or real-world application reinforces the RADS. They want to succeed in their new exciting course, not feel tarnished by their perceived failure in maths.

For re-sit learners, we should ditch the idea of ‘relevance’ and focus on the context of the RAD environment, not mortgages or tax returns. Often, the only context that matters for learners with RADS is success in the exam; anything else we bring to bear is bound to be limited by our group A blinkers and risks reinforcing previous traumas or socio-economic conditions.

It feels as if we have a huge opportunity ahead of us, and I hope it is a time to reflect and consider alternative solutions.

Apprenticeships: A consultation to urgently accelerate uptake

The pandemic, Brexit and the urgent need to decarbonise and reach net zero by 2050 have all highlighted the UK’s skills and workforce shortages and shone a spotlight on our education and skills system – and apprenticeships in particular – raising questions about whether it is fit for purpose.

It’s clear that the UK’s success in key areas such as net zero, life science, transport, food sustainability and digital relies upon us having a thriving engineering and technology workforce. However, to make this a reality we urgently need to increase the number and diversity of young people taking technical routes into engineering, manufacturing and technology, such as apprenticeships. Doing so will not only be of great benefit to the young people who will develop valuable skills and knowledge required for a rewarding career, but will also enable employers to develop a talented workforce that is equipped with the future-ready skills the country needs.

While the latest apprenticeships data from the DfE suggest a move in the right direction, with a positive uptick in apprenticeship starts as we emerge from the pandemic, there is still a long way to go. Despite engineering-related apprenticeships faring better than other sectors, there has still been a decline of 9 per cent in the number of starts across engineering-related subjects since 2014/2015.

The change varies by subject, but the decline is particularly pronounced and concerning in engineering and manufacturing technologies, where we have seen a 34 per cent fall in apprenticeship starts since 2014/15. This coincides with a decline in lower-level apprenticeship starts – with level 2 apprenticeship starts in the sector falling from a high of around 67,000 in 2015/16 to around 31,000 last year.

Given our acute skills shortages and the pressing need for more engineers and technicians, we urgently need significant and sustained growth in apprenticeships uptake. However, if we want to see effective policy making in apprenticeships, we need to first unpack the pattern of decline over time in apprenticeship starts and understand the different factors at play.

It’s vital that FE providers’ voices are represented

An inquiry was launched this month – led by former Labour and Conservative ministers Lord Knight and Lord Willetts in partnership with EngineeringUK – aims to investigate this.

For the inquiry to be effective, we need the views of those involved in delivering apprenticeships at its heart. We’re urging FE training providers, employers and young people to respond to the inquiry’s call for evidence by submitting views, experiences or ideas on how to improve the availability and accessibility of apprenticeships for young people.

FE providers play a significant role in making apprenticeships a success, so it’s vital that their voices are represented in the inquiry. We’re particularly interested in hearing from FE providers about the factors that influence what apprenticeships they offer, including consideration about subjects and levels. We’re also keen to document their views on the barriers young people face in accessing apprenticeships, especially those with different protected characteristics (such as young women, young people with SEND, or those from minority ethnic backgrounds) as these groups are underrepresented in engineering and technology.

We hope the inquiry will open up conversations about how to break down these barriers, inform effective policy making and widen opportunities for young people in engineering and technology careers.

With National Apprenticeships Week fast approaching, now is an ideal opportunity for us to come together and take a holistic look at what drives demand for engineering and technology apprenticeships, and consider how we can make them more desirable for students, colleges and employers alike.

Addressing the challenges of apprenticeships uptake will require an open-mind and willingness to change collaborative working between schools, FE providers, employers and government. In particular, government will need to be open to making changes to how the system works.

Addressing the ever-growing skills and workforce shortages that threaten to hold us back is a matter of urgency. Everyone must take responsibility for their role in improving the offer and uptake of apprenticeships, and this consultation is a first opportunity to ensure they do.

The inquiry, Fit for the future: growing and sustaining engineering and technology apprenticeships for young people is open for evidence until 27 February 2023. To respond, visit: www.engineeringuk.com/fitforthefuture

Qualifications in apprenticeships require informed debate

So let me firstly declare my interest: I am a fan of the UKs qualification system for vocational education and training and as a CEO for an awarding organisation, it’s no surprise that I should be championing the cause for regulated occupational qualifications. FDQ is also an approved end-point assessment organisation, so we have even more skin in the game.

Against that backdrop, I was delighted when IfATE’s long-awaited consultation on mandating qualifications in apprenticeships launched in December included proposals for updating the policy and criteria for trailblazer groups when deciding whether qualifications should be included in the future.

I have completed many consultations in my 30 years in the sector, and with IfATE approaching its sixth year as the overseeing body for apprenticeships, I was hoping to see a detailed analysis of several hundred thousand apprentices who have started, left and/or completed their programmes and end-point assessments.

Disappointingly, the consultation provides no such information. Why not? EPAOs submit grade requests for completers to the DfE each week, and this data is reconciled with apprentices’ individual learning records (ILRs). The information on retention and relative success is available for each standard, and should be available for publication.

This is a significant omission in a consultation proposing to make it harder for employers to decide if qualifications will benefit apprentices on standards. These facts should have been presented to enable stakeholders to consider whether apprentices undertaking standards with mandated qualifications achieve at a higher or lower rate (I suspect higher) than those on standards with no such requirement.

Understandably, with 650 standards available across multiple occupations, the landscape is complicated. However, the consultation does confirm that around 60 per cent of apprenticeships do not mandate a qualification. Therefore, if 50 per cent of these apprentices leave without completion, it must mean thousands of leavers each year have no formal transcript of accreditation (Certificate of part-achievement) from an awarding organisation to show for their time on their programmes.

There is a significant omission in this consultation

The reason awarding organisations can award and training providers can claim part-achievement certificates is because they are protected to a large extent by regulatory centre assessment standards scrutiny (CASS). This system requires awarding organisations to have quality assurance controls in place with centres to ensure the consistency and reliability of assessment practice.

I am therefore incredulous at the suggestion from IfATE that qualifications will no longer be mandated on the basis of providing better structure for off-the-job training and/or adding breadth and depth to an apprenticeships. Structure, breadth and depth are precisely the bedrock of the current system.

The consultation is unlikely to attract universal consensus. The CASS, for example, is costly to implement. However, FDQ has seen many employers and providers continue with qualifications even where the trailblazer has withdrawn the mandating requirement. IfATE ought to investigate this type of scenario.

The updated criteria proposed in the consultation would allow for a qualification to be mandated only if it is required by a regulator or a professional body. The other option provided by the IfATE is based a ‘labour market requirement’, where it appears trailblazer groups will be subjected to a burdensome justification exercise, not to mention the work of aligning the qualification with the occupational standard, potentially resulting in adaptation of current qualifications or design of entirely new ones.

But trailblazer groups are mostly made up of busy employer representatives, all volunteering their time. New burdensome requirements will present a significant barrier to qualifications being included. Employers know what their businesses need, but they are not bureaucrats with the time or inclination to gather evidence to prove those needs.

The IfATE proposal states that it will only consider qualifications if the apprentice is heavily disadvantaged as a result of not obtaining one. Arguably, that England is the only nation in the UK where apprentices can leave with no accreditation heavily disadvantages them all.

So let’s have a balanced debate on the relative merits of qualifications in apprenticeships. But to do so, it needs to be an informed debate, and that means IfATE must supply trailblazer groups with labour market information underpinned with achievement data. Anything less undermines the consultation.