IfA funding band review: Aviation standard set to have rate doubled

An apprenticeship standard is set to have its funding band doubled following the Institute for Apprenticeships’ recent review.

The maximum cash on offer for the level three aviation ground specialist will increase from £3,000 to £6,000, according to Annette Allmark, director of strategic policy at People 1st, who worked with the employer group that developed the standard.

It’s one of the least popular of the 31 standards included in the IfA’s review, with just 30 starts in the first nine months of 2017/18.

A number of major employers, led by the Ministry of Defence, were involved in the development of the standard, which was approved for delivery in April 2016.

It’s designed to train an apprentice to work on the ground in a range of different aviation environments, including a commercial airport or military base.

A number of specialist functions are covered in the standard, including aircraft handling and movement, flight operations, passenger operations and fire-fighting.

These are all focussed around the “arrival, turnaround and departure of aircraft and maintaining an aviation operation” and also include “knowledge, skills and behaviours to complete complex aviation tasks”.

The IfA’s funding band review, launched in May, was intended to “help make sure that employers can access high quality apprenticeships and that funding bands represent good value for money for employers and government”.

It covers 31 standards – including some of the most popular.

Analysis at the time the review was launched found that the 31 represented 64 per cent of all starts on standards for the first half of 2017/18 (45,900 out of 71,720).

This is just the second standard that FE Week is aware of to have had its funding band increased as a result of the review.

The level three senior healthcare worker will have its maximum funding cap increased from £3,000 to £5,000 – a rise of 67 per cent.

Funding for the level five healthcare assistant practitioner standard will remain the same, at £12,000.

A further six standards are set to have their funding bands cut, including three popular management apprenticeships (see table above).

Each of these proposals is subject to potential appeal by the employer groups behind them, and final approval by the education secretary, Damian Hinds.

Writing for FE Week, the IfA’s chief executive Sir Gerry Berragan insisted that the “collaborative approach” it had taken with the reviews was working.

Some of the reviews had resulted in recommendation that the bands “stay the same, some increase, and some decrease”, he said.

The IfA has also refused FE Week’s request for a full list of its recommendations, insisting it would be “premature” to do so.

 

ESFA hiring team to focus on audit and intervention at private training providers

The Education and Skills Funding Agency is to focus on intervention and prevention in independent training providers following a number of high profile failures, as it continues to beef up its audit team.

Its latest recruitment drive for its “market oversight” unit includes six advertised roles, who will try to identify financial problems at ITPs before they occur and “respond swiftly to provider failure to ensure learner and employer interests are protected and new, high quality provision is identified”.

The new jobs include an assurance manager, senior assurance officer, assistance assurance officer, and a graduate assistance assurance officer.

“We welcome these steps as part of a two-way dialogue in terms of understanding how policy changes can possibly destabilise the ITP market

Also being recruited is a post-16 senior interventions support officer and a post-16 financial intervention support manager.

All adverts, posted on the civil service jobs website, state that they will have a specific focus on independent training providers.

The extra agency resource comes after a series of significant failures, requiring the transfer of thousands of apprentices to new employers and providers.

In March 2017, First4Skills, one of the largest apprenticeship providers in England, called in the administrators after the ESFA terminated their contract following an Ofsted grade four inspection report. As many as 6,500 apprentices were affected.

Then in August later that year the nation’s largest FE provider Learndirect was also suddenly hit with an Ofsted grade four. It had around 80,000 learners at the time of inspection and the ESFA delayed cancelling its skills contracts in an effort to avoid transferring many of the students before finishing their courses.

Mark Dawe, chief executive of the Association of Employment and Learning Providers, welcomed the new assurance and intervention teams.

“While AELP believes that the current ESFA audit process has generally worked well for a sector that has over 1,000 providers, we have been saying to the agency for some time that the intervention process should be reviewed and improved,” he told FE Week.

“We therefore welcome these steps as part of a two-way dialogue in terms of understanding how policy changes can possibly destabilise the ITP market and at the same time achieve a positive impact from any interventions that the agency feels necessary to make.”

FE Week reported in May that the rapid increase in the number of training providers has forced an expansion of the ESFA’s audit team.

Mark Dawe

All personnel in the new assurance and intervention teams will operate directly under the leadership of Matt Atkinson, the ESFA’s director of provider market oversight – a unit which now has around 120 employees.

A key responsibility of the manager who will lead the assurance team will be to “oversee, develop and manage a programme of assurance monitoring visits that targets specific risk issues and complement existing assurance activities”.

“The programme will be suitably flexible to target emerging issues and respond on a timely basis, with an emphasis on Independent Training Providers,” the job advert adds.

The successful candidate will be “responsible for ensuring appropriate quality assurance and continuous improvement procedures are in place to enable the assurance work to be delivered to the high quality standards expected”.

They must also carry out “horizon-scanning, anticipating the impact of emerging policy and sector changes, as well as technological opportunities, acting as a champion for associated business transformation”.

The post-16 financial intervention support manager must act as a “national link” between the provider market oversight unit and the ESFA intervention team “on all things relating to intervention with ITPs”.

They must “attend meetings at ITPs, providing challenge and advice on the financial position of institutions as required”.

College and Co-op lead way with paid day release on two year course – but it’s not an apprenticeship

A sixth-form college in Manchester is set to offer paid work experience for some of its learners, in what is believed to be the first programme of its kind.

The course, run by Connell Sixth Form College from September 2019, is not an apprenticeship programme, despite being promoted as such by the Co-op Academies Trust which the SFC will join in November.

Instead, learners on the college’s new BTEC extended diploma in business course will spend one day a week doing paid work at the Co-op Group’s headquarters in Manchester.

The learners’ £7.71 an hour wages will be paid by the group, which sponsors the trust, in the form of a grant.

Jane Hopcroft, Connell SFC principal, told FE Week that the group was “keen to work with local young people in order to develop their opportunities” and paying them for the work experience was “the right thing to do”.

“Their view is that industry should be investing in our young people, and this was a good way to do it,” she said.

The two-year BTEC course was chosen because it “links up with aspects of the Co-op Group’s business” including marketing, accounting, economics, HR and ethics.

Ms Hopcraft described the Co-op cash as a “kind of bursary” for the college’s learners, many of whom “have to do paid part-time work in order to fund their time through college”.

“We felt that this would really help us to project who we are and what we’re trying to achieve. A lot of the young people that come here are local, and the area is quite deprived,” she said.

James Kewin, deputy chief executive of the Sixth Form Colleges Association, said he wasn’t aware of a similar programme being run by another SFC.

“This is a really interesting and innovative example of how to incorporate work experience into the sixth form curriculum,” he said.

“Students can earn while they learn and a major local employer is able to shape the workforce of the future.”

Frank Norris, director of the Co-op Academies Trust, told FE Week the new programme built on the trust’s existing work placements with the Co-op for pupils in year 10, .

“The Co-op has got value out of that, and those young people are adding value to the business,” he said.

Paying post-16 students would be a recognition that “it’ll be a work placement, but you’re going to work,” Mr Norris said.

“This isn’t just about sitting next to me and finding out what’s going on, you’re going to get actively involved in the business.”

Helen Webb, the Co-op Group’s chief people officer, said: “This new initiative shows how business and education can come even closer together to create a win-win for pupils and employers alike.”

Connell SFC, rated ‘good’ by Ofsted in January, was set up in September 2013 as a 16-to-19 free school.

It’s currently sponsored by Bright Futures Educational Trust, but will transfer to the Co-op Academies Trust in November.

The first Co-op backed school was opened in 2010. The trust had 12 academies across the north of England under its umbrella in April, when it announced plans to expand that number to 40 over the next three years.

EuroSkills 2018: Team UK given send-off at Parliament

“Endurance, fortitude and determination” are the qualities that each member of Team UK will need to beat Europe’s best, Anne Milton told competitors heading to EuroSkills Budapest at a special send-off event today.

The skills minister was full of enthusiasm when addressing the 22 gifted young tradespeople who are flying out to Hungary in less than three weeks’ time to compete in a broad spectrum of disciplines including mechanical engineering, beauty therapy, web design and cooking.

She told them that they “are the future” as life today is “no longer about what you know it is about what skills you have got as well”.

“You will be going out to Budapest representing your country and doing us proud.”

The minister said that going to the WorldSkills Abu Dhabi competition last year was “probably the most mind-blowing experience of my life” and offered this new round of competitors some advice.

“Don’t let anything get in your way,” she said.

“Never forget what you have already achieved, you are the best but you now have to compete against the rest.

“Don’t feel you are under any kind of pressure because of Brexit, don’t like thoughts like these get in your head that will stop you from doing your very best.

“If you believe you can do and believe you deserve it then you will achieve what you set out to achieve.”

Speaking to FE Week after she added: “It is going to take endurance, fortitude and determination to show the rest of Europe what they can do. Good luck to them all.”

Twenty-seven other countries will compete in EuroSkills Budapest in over 30 different disciplines. Around 80,000 spectators, including European policy-makers, educators and industry experts are expected to attend.

Ms Milton was one of a number of high-profile government officials attending today’s Team UK send-off on the Terrace Pavilion in Parliament. Sir Gerry Berragan, the boss of the Institute for Apprenticeships, was in attendance along with the ESFA’s director of apprenticeships, Keith Smith.

Shadow skills minister Gordon Marsden hosted the event.

“You just by being here today as competitors have already done a great deal and are already winners,” he told Team UK.

“Whatever happens in EuroSkills remember you are ambassadors for the UK. The stories you have and the sacrifices you’ve made to be here highlight the importance of skills and further education.”

Neil Bentley, chief executive of WorldSkills UK, which organises the country’s skills competitions, added: “In three weeks’ time we will be in Budapest competing against the best of the rest of Europe.

“Today we are here to celebrate the achievements of 22 young women and men, Team UK, who are going to be showing the best of what they can do. They’ve worked so hard to earn their seat on that plane to Hungary.

“You will be facing a new level of competition. Yes you are already the best at what you do in the UK but the challenge now is to up your game as you’ll be competing against 27 other countries.

“You might be feeling nervous but I want to reassure you that we are feeling confident in you and your ability.”

Following the speeches each competitor was issued with a special enamel pin.

Kieran Leyland, Team UK’s heavy truck maintenance competitor, told FE Week that he is “immensely proud” to get to this stage.

“It’s a great opportunity and hopefully I’ll do my best in Budapest,” said the 21-year-old.

“I’m going for gold but obviously I just want to do my best. This is everything for me.”

Holly-Mae Cotterell, Team UK’s beauty therapist competitor, said her training has been “up and down” as she’s had to learn a lot of new treatments in a short period of time but now she’s confident of success.

“Training has been intense but I’ve got my performance together now,” the 19-year-old told FE Week.

“My goals are to do the best I can and beat the previous score that I did at the nationals and if I come back with a medallion of excellence that will be amazing.”

Team UK will fly to Hungary on September 23 in preparation for competitions which will run between September 26 and 28.

FE Week is media partner and will be joining them for the whole week, producing an on location supplement following the closing ceremony.

Keep up with all the action before and during the competition on feweek.co.uk or on Twitter with the handle @FEWeek and the #TeamUK hashtag.

AoC proposes introduction of HE levy to pay for developing new suite of higher level qualifications

The government should fund the development of new higher level qualifications, paid for by a “higher technical levy” or top-slice from the apprenticeship levy, the Association of Colleges has said in a wide-ranging set of recommendations.

In a new policy paper called ‘2030 and beyond: An upgraded Post-18 education system, the association calls for a major redesign of England’s higher technical route.

It says that by “common consent”, the country has “low numbers of students taking courses at levels four and five when compared to our OECD counterparts”.

In the first 10 years, a teaching grant should be introduced to reduce the loan required by the student

There is an “executive lift” taking 18 and 19-year-olds directly from level three courses to level six degrees and “very few taking courses at the levels in between”.

To combat this, a new suite of level four and five qualifications should be developed which include the introduction of “teaching grants” – where government would pay towards that level of education.

DfE would need to reform current “grant, fee and loan rules to incentivise and support new one and two-year courses at levels four and five”, the AoC said.

“The same fee cap and loan/maintenance arrangements should be made available for this route for students of all age – whether they are part or full time.

“In the first 10 years, a teaching grant should be introduced to reduce the loan required by the student.

“This might be in the region of, say, 25 to 50 per cent of the fee coming from teaching grant, with the loan available for the remainder. In addition, students should be able to access financial support for living costs, travel and childcare.”

Funding for both the development of the qualifications and the teaching grants “could come from charging a short-term higher technical levy (say 0.2 per cent),” the AoC proposed.

“Other options would be to top-slice the apprenticeship levy (using the funds currently spent on apprenticeships for those over the age of 25) or to redirect some of the higher education teaching funding currently spent on high costs subjects and student opportunities.”

It added: “We assume that the current accounting rules for student loans will not last and therefore that the annual costs of the new teaching grants we propose will partly be offset by lower student loan outlays.”

AoC chief executive David Hughes told FE Week that the 0.2 per cent levy “could be on the same basis as the apprenticeship levy, in which case it would raise around £1 billion”.

The association believes that some level four and five qualifications, such as Higher Nationals and Foundation Degrees, are “well developed in some sectors (e.g. engineering and construction and hospitality) but are too often seen only as a route to a degree level course in a university rather than an end point in themselves, leading into employment”.

“They are also less well known, understood and respected than degrees by parents, schools and employers in many sectors of the economy,” it said.

The AoC’s policy paper also calls on the government to scrap the 24 age limit on free first level two and three courses.

It should introduce a “statutory entitlement – with appropriate funding – to at least level three for all adults who have not previously attained that level”, which Mr Hughes estimates  “if it increases numbers by 200,000 a year (restoring them to the pre-FE loan position), this would cost £1 billion a year”.

Today’s review paper from the AoC further highlights the urgent need for post-18 reform.

“This would involve the Department for Education reversing the 17.5 per cent cut to funding at age 18 and increasing the adult education budget to replace learner loans,” the AoC said.

“As with access courses, the government could write off any level three fee on completion of a higher education course.”

There would be considerable costs to implement the report’s recommendations but Mr Hughes insisted “the aim is a long-term investment in the UK population”.

“The costs need to be set against the possibility of long-term savings if there is a shift away from full-time residential higher education,” he said, adding: “These are substantial sums but no higher than proposals to restore HE maintenance grants to their pre-2016 position.”

The government has set up a panel, led by Philip Augar, to review post-18 education.

Nick Hillman, the director of the Higher Education Policy Institute, “welcomed” today’s “imaginative” report from the AoC but predicts there is “zero chance” of all the proposals being introduced.

“Demand for level four and five qualifications has withered yet employers say they need far more people trained to these levels,” he told FE Week.

“There is zero chance that all the AoC’s proposals will be implemented but the overall approach of better level four and five provision, a more flexible apprenticeship levy and a fresh look at the old teaching grant make a lot of sense.

“I hope the Post-18 Review looks at these proposals very carefully alongside all the others it is receiving.”

Shadow skills minister Gordon Marsden added: “Today’s review paper from the AoC further highlights the urgent need for post-18 reform and contains a series of practical proposals to assist students with much-needed support including for travel and maintenance grants – issues we’ve consistently challenged Government over but they have consistently ignored.”

Ofsted watch: Loans-funded provider branded ‘inadequate’

A loans-funded independent provider has received the lowest possible rating in its first ever inspection this week.

And two apprenticeship providers have been found to be making ‘reasonable progress’ in all themes under review in early monitoring visits, in the only other reports published in the last seven days.

Darlington-based Elms Associates Limited was rated grade four overall and in three out of four headline fields in a report published August 30 and based on an inspection in early July.

Leaders, managers and staff were found to lack “high enough expectations of learners”, with the result that “too many” made slow progress or dropped out altogether and “only a minority” passed their courses.

“Too many” learners failed to fulfil their potential – in part because of teaching, learning and assessment that relied “too heavily on undirected online searches to find information” or “on assessors providing answers for learners to rewrite in their own words”.

Elms Associates’ “very small” senior management team “also acts in a governance role,” the report said.

However, “the team has not had sufficient capacity to plan new strategic direction effectively or to offer sufficient challenge and support to improve outcomes for learners and address longstanding poor practice in teaching, learning and assessment”.

The provider had 27 adult learners on loans-funded courses at the time of inspection, of which 20 were on level three courses.

However, this provision only makes up “a small part” of its overall offer, with the majority made up of delivering apprenticeships on a subcontracting basis – provision that was “out of scope for this inspection”.

The provider has been approached for a comment.

KnowledgeBrief Limited was found to be making reasonable progress in all three themes under review in a report published August 29 and based on a monitoring visit in late July.

The London-based independent provider offers management training to levy-paying employers, and was new to apprenticeships when it secured a place on the register of apprenticeship training providers in May 2017.

Directors “aspire to be an outstanding provider of leadership and management training” and have “successfully adapted their commercial training offer to meet the requirements of the apprenticeship standards”.

Apprentices were found to be “highly motivated” and to “enjoy their learning and development”.

“Staff plan the apprenticeship programmes skilfully, taking careful account of apprentices’ job roles, employment circumstances and entitlement to off-the-job training,” the report.

Manchester University NHS Foundation Trust was also found to be making reasonable progress in all areas in a report published August 31 and based on a monitoring visit in late July.

The employer provider, which began directly training its own apprentices in 2016/17 before making it onto RoATP in May 2017, had 308 apprentices from across the eight hospitals that make up the trust at the time of the visit.

Directors and senior managers were “committed to ensuring that learners receive high-quality education and training”, according to inspectors.

Their planning of the apprenticeship programmes was found to be “good”, and a 12-week pre-apprenticeship programme “very helpful” in preparing apprentices “for their job role and the demands of the apprenticeship programme”.

 

Independent Learning Providers Inspected Published Grade Previous grade
Elms Associates Limited 10/07/2018 30/08/2018 4
KnowledgeBrief Limited 25/07/2018 29/08/2018 M M

 

Employer providers Inspected Published Grade Previous grade
Manchester University NHS Foundation Trust 25/07/2018 31/08/2018 M M

Ofqual U-turns on T-level plans that would have forced students to wait a year for a retake

Ofqual will allow T-level exams to be taken more than once throughout the assessment year – meaning students will not have to wait a whole year for retakes, after FE Week exposed sector leader fears.

The exams regulator has also binned the idea of introducing a “working towards” grade for learners who narrowly fail the new technical qualifications.

Ofqual made the U-turns known today when launching its further technical consultation for how it will regulate T-levels, the deadline of which is October 28.

The regulator had originally consulted on the idea to only allow assessments to be taken in the summer, thus forcing students who need to re-sit their exams to wait a whole year to do so.

FE Week reported last month that awarding organisations across the country were majorly alarmed by this and urged Ofqual to reconsider.

“Following feedback, we will amend our approach as set out in the consultation to require an awarding organisation to provide a minimum of one assessment series for the Core and the Occupational Specialisms; with the option for an additional assessment series, if appropriate,” Ofqual said today.

It added that it will allow “each assessment series to be used both for students sitting assessments for the first time and those retaking assessments”.

The regulator will “not specify when in the year these should take place”, it will be “for an awarding organisation to determine based on the requirements of the particular Technical Qualification and to explain its approach to assessment scheduling as part of its assessment strategy”.

There was also concern when the regulator proposed setting a requirement for occupational specialisms in T-levels to have a “working Towards” grade below pass.

“As there is felt to be limited value in this grade, we will not proceed with this proposal,” Ofqual has now said.

Other areas that have been changed include results and certification.

“Taking account of responses received, we will dis-apply our Conditions, meaning awarding organisations will not be required to issue certificates for the Technical Qualifications,” Ofqual said.

“Instead, certification will be for the overall T-level. However, a statement of achievement will be implemented for students who do not successfully pass all elements of the T-level, to ensure students are not disadvantaged and that their achievements are recognised.”

With regards to setting and marking assessments, the regulator will “require that the core knowledge and understanding elements are assessed by an examination and marked by the awarding organisation”.

“We would also expect these to be marked by the respective awarding organisation,” it added. “However, in exceptional circumstances, our rules will allow for centre marking of core skills assessments and Occupational Specialism assessments.”

Other proposals, including Ofqual’s approach on grading, reviews of marking and accreditation, will be “adopted largely as outlined in the consultation”.

Chief regulator Sally Collier said: “Our decisions, along with the government’s Invitation to Tender, mark a significant milestone in the delivery of T-levels.

“We look forward to continuing our collaboration with the Institute for Apprenticeships and Department for Education on this important initiative.”

“The responses we received to our policy consultation will help ensure these qualifications, and the T-levels of which they are part, are valid and robust, and meet the demands of the work place.”

Ofqual’s new T-levels consultation, which gives interested parties the chance to have their say on the detail of Ofqual’s rules, including drafts of the Conditions and Guidance,  has been published alongside the DfE’s tender process for awarding organisations.

The first three T-level pathways set to start teaching in 2020 will be in digital (production, design and development), childcare and education, and construction (design, surveying and planning).

T-levels tender launched by Department for Education

The highly anticipated and controversial T-levels tender process has now been launched by the Department for Education.

Awarding organisations can bid for an “exclusive license” to develop and deliver the new qualifications, in a contract worth £17.5 million.

Three separate tenders have been launched – one for each of the first pathways to be delivered from 2020, in digital (digital production, design and development); childcare and education; and construction (design, surveying and planning).

“We will make sure that our changes to technical education enable young people to have the very best choices about how to build their career,” said skills minister Anne Milton.

“It is really important that we select the organisations with the right vision, to get the best for the young people taking new T Levels. They will be key to upholding the quality of our reforms and making T Levels a success.

“Since we started developing T Levels we have taken an open and collaborative approach, including sharing the draft procurement documents with the sector to give potential bidders a genuine opportunity to influence how this procurement works.  

“We want to continue working closely with them every step of the way so we get this once in a lifetime opportunity right.”

The closing date for bids is October 26, and the contract start date is March 4 2019.

Click here to view the contract notice.

Read more about the contentious background to today’s tender notice.

Colleges in uproar as CITB tries to protect management fees with ‘reverse subcontracting’ deal

The Construction Industry Training Board is trying to force colleges to enter “reverse subcontracting” arrangements where it charges “unfair” top-slices of at least 28 per cent even though it won’t be the prime.

The bizarre deal, which the Association of Colleges believes would break government funding rules, has been thought up by the CITB after it failed to win a non-levy apprenticeships contract.

Whereas before the levy it would use its apprenticeships contract as a prime and subcontract the training out to colleges, the CITB now wants colleges to agree to a “reversal of our contracts”.

Colleges would be the prime but have to pay a huge management fee believed to range from 28 to 36 per cent, like a subcontractor, for which the CITB will give access to construction employers and provide other services such as inductions and health and safety training, according to a contract seen by FE Week.

CITB ‘reverse subcontract’ proposal

It means that for apprenticeships on the carpentry and joinery level two standard, for example, the training provider would receive £12,000 government funding but have to give £3,360 of it to the CITB.

One college which did not want to be named told FE Week the deal was “unfair”.

“We would question the regulatory compliance of the current reverse contract proposal and it does appear to be ill-conceived and almost unworkable,” it said.

“It is unfair and not in the best interests of the sector, students and employers.”

The Association of Colleges, who the CITB deceptively said had endorsed the deal along with the ESFA, is “deeply concerned” about the proposed arrangement.

It is suggesting colleges do not enter into such deals without consulting the association first.

“We remain deeply concerned that the current deal is not compliant with the current funding rules and does not represent a fair and transparent deal,” said AoC boss David Hughes in an email sent to his members today.

“To try to work through this, we have a meeting with CITB next week to which we are inviting ESFA, because an urgent way forward is needed.

“It would be helpful to hear from every college involved in this so that we can communicate directly with you.”

Teresa Frith, senior policy manager at the AoC, added: “We need to ensure that the way of working is fully compliant with ESFA funding rules and that it is fair to all involved.

“It is unfortunate that miscommunication at CITB has led to their staff telling colleges incorrectly that AoC and ESFA support the current proposal, but at least this has led us to the opportunity to jointly consider a way forward.”

Part of the reason why this “reverse subcontract” will be deemed as uncompliant by the ESFA is that a number of activities the CITB contract proposes they will do are listed in the rules as ineligible for funding, such as recruitment.

A Department for Education spokesperson said: “The ESFA funding rules make clear that we expect a direct relationship between apprenticeship training providers and the employers and apprentices they are working with.

“We would not support or endorse any funding arrangements that are inconsistent with these rules.”

She added that the DfE will “take action” with training providers found to be operating outside of the funding rules.

Steve Hearty, CITB’s director of apprenticeships and standards, told FE Week that all arrangements “will be in accordance with the ESFA’s subcontracting guidelines” when agreed.

“Like a number of providers, CITB was not awarded a contract to provide apprenticeship support to non-apprenticeship levy employers from April 2018 to March 2019,” he explained.

“In response to this, we have agreed a reversal of our contracts with our partner colleges. This means CITB will be a subcontractor to colleges providing training for non-apprenticeship levy construction employers where they wish to do so, although colleges may choose to deliver services without CITB as a subcontractor.”