Ofsted wins battle to inspect ALL apprenticeships

Ofsted will soon be handed powers to inspect all universities that offer apprenticeships – including the likes of Cambridge, FE Week can reveal.

In a controversial move, the education watchdog is set to take on responsibility for overseeing all apprenticeships, including those at the degree levels of 6 and 7, for the first time.

Only the Office for Students can police higher apprenticeships under current policy, while Ofsted’s remit goes up to level 5 – a position that has frustrated the inspectorate for many years.

Plans have been drawn up to strip the OfS of this role amid concerns the higher education regulator is not up to the job. It is understood that the switch to Ofsted will be announced imminently.

A spokesperson for the Department for Education said they are working “closely with the Office for Students and Ofsted to consider carefully what the most appropriate quality assurance arrangements should be for level 6 and 7 apprenticeships” and will “provide further updates in due course”.

The Russell Group, which represents the 24 “leading” universities in the UK including Cambridge, did not pour cold water over the plan for Ofsted to inspect their members.

But a spokesperson said the group will continue to work with government on delivery and expansion of the apprenticeship route, including how to avoid “overburdensome or disproportionate regulation”.

The University Vocational Awards Council, which also represents a number of universities, has previously voiced its opposition to such a move and questioned Ofsted’s expertise to inspect degree-level fields such as registered nurses, social workers and architects.

FE Week analysis of the latest DfE data, which covers the first three quarters of the 2019/20 academic year, shows there were 231 providers offering level 6 and 7 apprenticeships – with over 26,000 starts between them.

Of those 231 providers, 47 (20 per cent) are currently completely out of Ofsted’s scope of inspection as they deliver no provision at level 5 or below.

Included in this 20 per cent are many prominent Russell Group universities such as the University of Manchester, University of Nottingham and the University of Warwick.

The most well-known redbrick university that delivers higher apprenticeships but has been out of scope for Ofsted visits to date is the University of Cambridge.

Cambridge currently delivers two level 7 apprenticeships that have a combined cohort of 120 apprentices: applied criminology and police management, which commenced in 2019; and architecture, which launched this month.

A University of Cambridge spokesperson said they would “welcome scrutiny from relevant bodies” and should Ofsted begin to oversee all levels of apprenticeship provision, “we will necessarily adjust to meet the requirements in the best interests of our student apprentices and their employers”.

Oversight of degree apprenticeships has sat with the OfS since their launch, but monitoring of the provision is not official inspections of the type Ofsted conducts.

A decision was made in June 2019 for the higher education regulator to oversee all level 6 and 7 apprenticeships, including those without a prescribed HE qualification delivered at providers not on the OfS’ register, which had gone years without any oversight.

This was against the recommendation of the post-18 education review conducted by Philip Augar, who had called for Ofsted to inspect all apprenticeships.

Frustration has been building over the pace of the OfS’ work in this area. The regulator has so far only completed “pilot reviews” to a small number of providers not on its register of HE providers in late 2019 and concluded an evaluation of the pilot before lockdown hit.

OfS previously said they would publish these reports, but has now gone back on that promise. A spokesperson explained that they have paused their oversight of level 6 and 7 apprenticeships until HE providers are able to return to “a more normal operating environment”, as is the case for its other regulatory activity.

Being handed oversight of all apprenticeships will mark a big win for Ofsted, which has been clamouring for the job for over four years.

Chief inspector Amanda Spielman has voiced concerns multiple times that some universities and training providers are getting away with offering level 6 and 7 apprenticeships which are simply “repackaged graduate schemes”.

In an interview with FE Week in March 2019, Spielman said the first FE inspection she observed found a large accountancy firm had “very clearly” turned its tax graduate trainees into level 4 and 7 apprentices.

But because the inspectorate’s remit only extends to level 5, Ofsted could only inspect the level 4 provision, while in another room level 7 apprentices were not being reviewed.

“It was very clearly a graduate training programme that existed for many years that had been reframed slightly to make sure it genuinely did meet the requirements, but nevertheless was the kind of training that firm would have always have been providing and paying for,” she told FE Week.

“We were there to look at only one piece of this graduate traineeship programme, which made for an extraordinarily artificial conversation.”

Last week, Ofsted’s deputy director for FE, Paul Joyce, said he would welcome the power to inspect all apprenticeships and it is something “that I think we could do, absolutely”.

PICTURE: Madingley Hall, built in 1543 by Sir John Hynde, part of Cambridge University and home to the Institute of Continuing Education where apprenticeships are delivered

Sending a hundred students home so soon was a reality check

One case of Covid-19 among the staff had an immediate impact on how we could run the college, writes Sam Parrett

With great anticipation and excitement, last week saw the re-opening of all our college campuses and schools. After months of forced closure, staff have worked tirelessly over the summer break to prepare sites for the safe return of staff and students.

The risks and concerns have been uppermost in all our minds, but so has the determination to get our students back into the classroom.

All our schools and college campuses are following every Covid-19 guideline; from staggered starts to having fewer people on site, mask-wearing in communal areas and encouraging hand hygiene. Yet the reality is that we will see cases of the virus across sites as we move into the autumn and winter months.

At the end of our induction week, we had notification that one of our college staff had tested positive for Covid-19. Seeing a case so early in the term was a real wake-up call as to the reality of the virus. As ever with these things, the call came on a Sunday. This meant our senior leadership team dropping afternoon plans and jumping on a Zoom call (with one of us dialling in from a kayaking trip, complete with life jacket!).

It’s been a stark reminder that Covid-19 is with us

It was vital to ascertain not only what the situation with the affected staff member was, but the impact it would have on the wider college. Getting hold of Public Health England and the DfE proved tricky (on a Sunday afternoon) and it took some time for us to establish exactly what action we needed to take.

After some initial confusion as to who would need to self-isolate, we were advised through the NHS Test and Trace system that up to 15 staff members would need to stay at home for 14 days. Fortunately, due to the Covid-safe measures we had taken at college (social distancing, compulsory masks in all communal areas etc) no student was affected on that front.

But with a number of tutors now unable to come into college, we had no choice but to contact around 100 students and move them to our online learning platform temporarily. This is not ideal so early in the academic year, when students and tutors have not yet formed relationships with one another. But in this case, it was sadly unavoidable to reduce any risk of Covid-19 transmission.

Having gone through this experience, we now better understand the crucial processes that must be in place, particularly in relation to test and trace; ensuring we know exactly which students and tutors have been where and when they have been there. Policies have been updated and clear procedures shared among all staff, so that everyone understands what is required.

We are focusing on ensuring everyone on site continues to familiarise themselves with the guidance and follow it. The “hands, face, space” message has to be crystal clear as this is the only way we can protect ourselves and our community.

In hindsight, it’s also clear we were lucky in terms of the number of staff who came into what is deemed “close contact” with the individual who tested positive. It could easily have been more, which would have had a severe impact on the college. Managing bubbles and contact between staff and students is extremely challenging. For example, a student or staff member may be in a particular ‘curriculum bubble’ but then go into the library or the common room and end up being part of another bubble, which makes contacting and tracing more difficult. It’s also tricky trying to balance staff cover.

In total, as a result of one staff member testing positive, around 100 students and 15 staff were directly affected – having to either go home or change their timetable.

It has been a stark reminder that Covid-19 is with us. Having thought we’d prepared for every eventuality, we’ve had a reality gap as well as a reality check – which thankfully we’ve now closed.

 

Without a clear plan for virus control, colleges have been left to guess

Lack of a blueprint for keeping colleges safe partly explains why one college even considered ‘alternate weeks’, writes Stuart Rimmer

My great friend Craig, who features in many of my stories, is a builder. I was chatting to him about restarting college life and how government kept issuing guidance after guidance through the summer. He asked, “Don’t you just get given a plan?”

I was stunned into silence. He went on to tell me that he never starts any (re)build without a clear and agreed plan. A blueprint of what it needs to look like – so everyone is happy, costs are controlled or fairly allocated and quality delivered.

Embarrassed, I fudged an answer that consisted of attempting to explain the freedoms of incorporation, representative bodies, nuances of governance and local context, of some colleges having more money than others (so could do more than others), the complexity of staff and union consultation, and so on. But in the end he was simply correct.

For every college there appears to be a different way of approaching re-opening in the context of Covid. We’ve all taken DFE “guidance” and attempted to apply it with sense and integrity. But without a clear and unchanging set of rules the problem is that some of us will undoubtedly get it wrong. What is considered “reasonable” by one college would be considered against the rules in another.

We are experts on pedagogy, not virus control

Some colleges set out their positions early in the summer to help with staff planning. Others waited. Should we use temperature testing? Who knows? Should we wipe down after each class? To mask or not to mask? How big can a bubble be? What proportion of provision should be online? Does anybody know?

College leaders can’t agree. Some are at 20 per cent online, some even chancing their arms at 50 per cent flip week timetables – as we saw with a college last week.

The college announced plans to alternate students between on-site provision and working from home each week, and then U-turned after an outcry from parents.

The ESFA has also started phoning around checking onsite attendance – prompting the question, does it have a view of what is right or wrong? We were told to use our judgement, and so we used our (totally unqualified epidemiological) judgement as best we could.

Other colleges have taken a pragmatic or generous view of “social distance where possible”. In my own college, we are trying to deliver a full onsite timetable to provide some normality and opportunities for learners (before Boris Johnson almost inevitably shuts us down again).

But among students and frontline staff and leaders, there is a huge spectrum of views. In the same day, it was suggested to me we shouldn’t bother with any mitigation as Covid was a “conspiracy”, while other staff told me they feared leaving the house.

This polarised difference of opinion, which mirrors the wider public, is playing out in every college in the country. What’s important is that they are all valid views, but it makes effective delivery almost impossible.

We all carry personal bias into this scenario. Leaders try to navigate this logistical nightmare by implementing best-fit plans. This is far from a criticism of colleagues, in whom I have witnessed a stoicism and can-do attitude of which we should be fiercely proud.

But we are fighting the Covid battle from a position of inherent weakness. We are experts on pedagogy, not virus control.

We are likely to experience local lockdowns over the coming weeks and months, which will disrupt and damage learning, but if the government had provided a clear, unambiguous and mandated blueprint then at least we would have begun the term with some consistency.

Without a plan, have we built the start of the academic year on shaky foundations and will the walls come tumbling down?

It remains to be seen, but I can tell you now that Craig wouldn’t have started this without his signed-off blueprint. Should we?

How can we be in financial intervention yet ineligible for Covid relief?

Being turned down twice for relief funding feels like we are losing out partly because of our hard work, writes Chris Malish

As lockdown began to really bite in April, the announcement of the ESFA’s post-16 provider relief scheme was welcome. The aim of the extra cash was “to continue to retain capacity within the apprenticeships and adult education sector to deliver the skills needed to support economic recovery post-pandemic”.

But as always, the devil was in the detail. Our college has been turned down twice, and I’m going to explain what that was like.

The requirements for applications included proof of eligibility for the scheme, “proof of financial need” and proof of eligible costs which make up the financial need.

Among other requirements, a transitional plan also had to be in place that demonstrated the ability to operate without any further relief on or before October 2020.

To its credit, the guidance on the scheme was clear and gave a template on how to provide the information, including cash flow information.

The impact of this was demoralising for the college

But there were other issues. The application timescales were tight and originally set at around five working days for the April submission.

That’s before you consider the wider context of Covid-19, which was causing us and other colleges to struggle to deliver courses to our students.

Many of our staff had home schooling commitments for their own children, while at the same time adjusting to working from home. Most colleges would also have been deep into business planning for the next academic year.

We were unsuccessful with the first application as we were not classed as “at risk”, mainly, I feel, because of our cash position and were perceived to be able to cope without the funding in the short term for the activity that was required. It was frustrating, but we persevered.

By the second round of applications, gathering the data became much smoother and the original plan was still relevant; the finances just needed updating.

But what wasn’t clear at the outset was exactly what the threshold was for receiving these funds. Again, the applicant’s cash position seemed to be the biggest factor. If you had cash in the bank, you weren’t deemed in need, and if you didn’t have cash in the bank, you were.

But the money we had in the bank was already earmarked for other activities and ensuring bank covenant compliance. We needed the funds for additional activities as yet unfunded. Nevertheless, we were turned down a second time because of our cash position.

This suggests to me that there was a fixed amount of money available for the Covid relief scheme (although a fixed figure was certainly never announced for it); the ESFA was unsure about how many applications would be received and the level of funding that would be requested; and the criteria might even have been formulated after applications had been received.

This is very different to other initiatives such as the Job Retention Scheme and Eat Out To Help Out. It makes me question where education funding ranks in the government’s priorities, especially as education will be central to rebuilding the economy.

It’s especially confusing not to receive the funds since we are under financial intervention and our finances, under the ESFA’s own health score metric, are judged to “require improvement”.

The impact of this was demoralising for the college, as over the last three years we have been working hard on improving finances. To have funding for much-needed activities declined, to the detriment of our financial position, has left us feeling let down. It feels as though we have lost out partly because of our hard work.

However, it was not unexpected and enforces the feeling in the sector that we are undervalued and underappreciated.

So now, all the plans put forward in the application have been continued, but unfunded. Bradford College is not driven simply by finances, but by a vision  ̶  of creating a better future for all through education and training.

Why route reviews are so critical for the future of technical education

The resumption of route reviews is a wonderful opportunity for us to consider together how technical education can play a more important role than ever in supporting the nation’s economic recovery, writes Ana Osbourne

It has now been nearly six months since the Institute announced that all route reviews would be postponed due to the COVID-19 lockdown.

I am delighted to announce that we are releasing the handbrake as of today (18 September), albeit cautiously and with a careful eye on the ongoing situation.

Employers, providers, awarding organisations, and the Institute have developed more resilient ways of doing business, so despite the future uncertainties we feel we can restart this important work and see it through to completion for the benefit of employers and learners. 

To recap, the route review process is a statutory requirement resulting from the Apprenticeships, Skills, Children and Learning Act way back in 2009.

The reviews play a crucial role in updating and maintaining the quality of current apprenticeships. They also take a more strategic look at how apprenticeships and T Levels are serving different employment sectors.

We speak to hundreds of employers and the process gives everyone the opportunity to reflect on what is serving the economy well or needs improving.

Our first ever route review, which was for the digital sector, launched in September 2018 and recommendations were published in May 2019.

An innovative feature to emerge from that, which I was particularly proud of as a woman keen to see gender barriers broken down wherever possible, was around the use of language.

We started off by introducing gender-neutral language checks, which identify phrases that could put women off applying, for digital apprenticeships. They have since been rolled out across all new apprenticeships.

All route reviews that were paused for lockdown will now pick up from where they left off.

This means the spotlight is about to fall again on the hair and beauty; creative and design; agriculture, environmental and animal care; and engineering and manufacturing occupational routes.

Hair and beauty had progressed furthest before the pause. We will now be hosting an event in November to announce our recommendations for improvements to the hair professional apprenticeship.

We had also arranged for a workshop to take place for the engineering and manufacturing review prior to postponement. This event, which will be run by our partner organisation, Enginuity, has been rescheduled for 8 October.

We have also rearranged workshops for the agriculture, environmental and animal care routes. These events, run by fellow partner Landex, will now take place on 2, 12, 23 and 26 October.

We would welcome as many participants as possible. If you would like to take part visit the route review section of our website where you can find more details.

Once route reviews restart we will need to keep progress under review in light of the changing situation with COVID-19. 

The purpose of the relaunch is not to send out the message that COVID-19 is behind us and everything should return to the same as it was before.

Valuable lessons have been learned and the delivery of technical education will inevitably evolve as a result.

We want to hear from businesses about their experiences during and post lockdown and the impact that COVID-19 has had on them and their apprentices, as well as understanding the range of learning incentives available to them and other stakeholders.

This feedback will be collected as part of the route reviews. The changing nature of technical education training – including recent moves towards more remote learning for example – will be reflected in our thinking.

I would also like to urge as many people as possible to take part in the second of our series of employer surveys on the impact of COVID-19 before it closes on 22 September.

Input from employers and the wider sector is always hugely appreciated. The resumption of route reviews is a wonderful opportunity for us to consider together how technical education can play a more important role than ever in supporting the nation’s economic recovery.

DEBATE: Should FE colleges lose autonomy to make course choices?

On 17 January 2020, FE Week was first to report that the government was working on new legislation in the form of an FE Bill, which “could mean colleges lose ultimate power over deciding which courses are run”.

Four days later, on the 21 January,  Amanda Spielman, Ofsted’s chief inspector, gave a speech in which she repeated criticisms she’d first made in November 2018. Her argument is that some colleges choose to run courses for financial gain, such as in performing arts, despite the lack of opportunity for progression. This, she said, is giving students “false hope” by putting them on courses where there are slim job prospects.

David Hughes, chief executive of the Association of Colleges, responded directly to the concern and said on the same day at his annual conference: “It does happen and we just need to face up to it.”

But the government still refuse to comment on what will be in the FE Bill or related White Paper (which we understand publication of keeps being put back), beyond saying it will be “revolutionary”.

In September, Tom Richmond, a former adviser to the skills minister and founder of the think tank EDSK, proposed a solution in a report funded by FETL.

Colleges should be stripped of autonomy to choose course offer, in favour of new regional FE directors arranging provision “in line with local social and economic needs, as well as eliminating duplication of courses and promoting specialisation among nearby colleges.

“While day-to-day operations would remain the responsibility of college principals, the FE director will have the final say on important strategic decisions such as the courses and specialisms that each college offers”, says Richmond.

Could new regional FE directors dictating college specialisms and the courses they run be an improvement on the current system? Richmond, writing for FE Week, believes this “the loss of some autonomy for individual colleges is a step in the right direction”.

Join this important debate online at 12pm on Wednesday 7 October , chaired by FETL president Dame Ruth Silver. Tom Richmond will be arguing in favour of the motion for the loss of some college autonomy and Nick Linford, editor of FE Week, will be arguing against.

Register here to watch live and be sent a recording of the session.

MOVERS AND SHAKERS: EDITION 326

Your weekly guide to who’s new and who’s leaving.

Joel Charles, Director of policy, communications and public affairs, Seetec

Start date: August 2020

Previous job: Director of government relations and impact, Future Care Capital

Interesting fact: He is a trustee of a foundation that supports underprivileged children to pursue their educational ambitions

Laura Leong, High-performance skills coach, WorldSkills UK Centre of Excellence

Start date: August 2020

Concurrent job: WorldSkills UK training manager in floristry

Interesting fact: She has won RHS Chelsea Florist of the Year twice

Frazer Minskip, High-performance skills coach, WorldSkills UK Centre of Excellence

Start date: August 2020

Concurrent job: WorldSkills UK training manager in autobody repair

Interesting fact: Despite working with Bentley Motors for five years as its global trainer, he never got to drive a Bentley on the road

No mandatory face masks, and 7 other things you need to know about autumn exams

The government has released further guidance on how schools and colleges must prepare for autumn exams to best protect public health. 

This is what you need to know: 

 

1. Keep students apart in safe spaces before exams …

Schools and colleges are being told to “identify a location where candidates will wait before the exam that can support social distancing between group ‘bubbles’”. 

In addition all candidates must be kept separate from other learners arriving at school or college. 

The guidance tells schools and colleges it must make sure there “is a plan to manage candidates leaving the room and site” – taking into account different exam finishing times and extra time for some students. 

These considerations also apply in private exam centres or “wherever the exams are taking place” and schools and colleges must ensure candidates maintain social distancing from other members of the public if necessary.  

 

2. … and maintain 2 metres between ‘bubbles’ in exam rooms

For students within the same group ‘bubble’, the minimum distance between candidate chairs “must” be 1.25 metres. 

However, “all other candidates, whether in different group bubbles, private candidates or those returning to school or college to take exams, should be seated 2 metres apart from each other.”

Invigilators are allowed to walk up and down aisles between desks, but “there must also be points in the room where an invigilator can stand at least 2 metres from the nearest desks and see all the candidates in the room”.

 

3. No limit on candidate numbers – but keep windows open

While there is no overall limit on the number of candidates who can sit in a room, “as long as desks are correctly spaced”, the guidance advises the opening of windows and doors for ventilation. 

It states: “Good ventilation is important and you should maximise this wherever possible”

 

4. Schools and colleegs must keep contact info for NHS Test and Trace

The guidance advises school and college leaders will need to “collect and keep” contact information for candidates and invigilators “so that you can share it with NHS Test and Trace if needed”. 

The government warns this is “particularly important for any external visitors” such as invigilators and candidates not enrolled at the school or college, with providers advised to cross reference contact details with a prepared seating plan.

 

5. Exam rooms must be cleaned after each exam

Frequently touched surfaces, including the backs of chairs where candidates pull chairs out to sit, should be cleaned after every exam. 

The guidance adds: “Rooms do not need to be left empty between exams, provided they are cleaned properly each time.”

 

6. No face coverings requirement …

According to the guidance, candidates and invigilators do not need to wear face coverings – unless they want to. 

However, they “should wear face coverings in communal areas if the exam centre is in an area of local intervention”.

 

7. … but invigilators must minimise contact with others

Invigilators are allowed to move between different schools and colleges, so should therefore “minimise contact and maintain as much distance as possible from other staff”.

Before exams are under way schools must tell invigilators what they need to do to minimise contact and maintain as much distance as possible from other staff.

In addition the guidance states “invigilators do not need to wear gloves when collecting exam scripts”. 

 

8. Stand alongside candidates rather than face to face

The government says schools and colleges “should advise invigilators and other staff to stand alongside candidates when interacting with them, rather than face to face”.

For encounters “over 15 minutes”, such as providing individual support, staff are advised to maintain a two metre distance or consider using a separate room from other candidates.

If a two metre distance cannot be maintained “they should avoid close face to face contact and minimise time spent within one metre of others.”

However, the guidance includes the caveat that “these arrangements may not be possible when working with some candidates who have complex needs, in which case these candidates’ educational support should be provided as normal during exams”.

Apprentice quality assurance charges to end from October

Controversial £40 charges for the external quality assurance of apprenticeship endpoint-assessment will start being phased out as soon as October, it has been confirmed.

The fees will end as the Institute for Apprenticeships and Technical Education hands over EQA responsibility for over 300 apprenticeship standards to Ofqual.

Federation of Awarding Bodies chief executive Tom Bewick has welcomed the news, but said the IfATE “must get better” at communicating how the transition will work so that “we avoid any further unnecessary complexity and confusion”.

Tom Bewick

In two Ofqual letters to EPA organisations seen by FE Week, 69 standards overseen by IfATE will transition “by November”, with a further 54 from January 2021 and the remaining standards by next summer.

Currently, Ofqual splits EQA duties with the IfATE and around 20 other employer bodies.

But under a new system confirmed last month, all quality assurance of apprenticeships without an intergraded degree will transfer to Ofqual and all EPA organisations will need to be “recognised” with them. The Office for Students is taking over EQA for integrated degree apprenticeships only.

The existing complex EQA system has come under heavy criticism for the variability in approaches. FE Week analysis last year found other EQA organisations were charging up to £179 per apprentice for the service, leading Bewick to liken the quality assurance market to “the Wild West”.

A spokesperson for IfATE, which runs EQA through contractor Open Awards and charges £40 for the job per apprentice, has confirmed Ofqual “will not charge for external quality assurance, so as standards transition the existing charge will be turned off”.

They added that the charge will cease for each apprenticeship standard on the day that they are transferred over to Ofqual.

The institute’s own delivery of EQA, originally conceived as a back-stop in the event of failure to secure a different organisation, is currently in use across around half of the nearly 600 standards.

The Institute must get better at communicating with the sector about how the EQA transition will be handled

The full transitioning of standards to Ofqual is planned to take two years, and those EPAOs starting with Ofqual from November have been given until the end of this month to apply to carry on doing EPA for their existing standards.

An awarding organisation being recognised by Ofqual means their qualifications can be considered for public funding to be taught in schools, colleges and other FE providers, and its certificates can carry the Ofqual logo.

Bewick, the boss of the Federation of Awarding Bodies which has many members as EPAOs, said: “I welcome the clarification about Ofqual not charging from as soon as October for the standards now in the process of migrating to them.

“However, the Institute must get better at communicating with the sector about how the EQA transition will be handled, so that we avoid any further unnecessary complexity and confusion.”

This, he added, should include the Treasury, which issues the charge, agreeing to end it all together by the end of March 2021.

Standards which are not assured by IfATE will be transferred over in the second transition year.

Ofqual has said it is “starting to engage with EPAOs who want to apply for Ofqual recognition” but, faced with a wave of applications, the watchdog has put up an advertisement for an “immediately available” financial and markets analyst to scrutinise the “financial suitability” of EPAOs.

The job, which will run on a fixed-term contract until March with a salary of up to £44,660 per year, involves analysing financial records and business proposals to “reach judgements about the overall financial suitability of applications”.

Candidates should be an “experienced analyst with a strong financial or accounting background who can review company business plans and finances from day one”.

Organisations applying to be recognised by Ofqual have to be able to prove they have “adequate financial reserves which will support the organisation through the lifecycle of a qualification” as well as accounting and financial monitoring systems either in place, or in development if it is a new awarding organisation.