DfE should be concerned about rip-off subcontracting fees

Just when you think the government is finally going to act to stop the practice of rip-off subcontracting fees, they provide a statement expressing “no concern”.

I’d be lost for words, if it wasn’t for the fact this editorial demands I write them.

FE Week has been reporting on the huge topslices ever since we launched in 2011.

And we are regularly contacted by subcontractees, complaining of the impact on quality when funds are withheld, but fearful of going on the record to bite the hand that feeds them.

It did seem the government recognised the poor value for money, introducing a series of measures over the years to limit subcontracting, and to make the management fees more transparent.

In April, the Education and Skills Funding Agency announced they were reviewing “subcontracting fees and charges; so that we can be assured that our funding is being used for recognised costs”.

At the time they also said they “believe it is important that government funds are not diverted away from training and assessment in the form of fees and other charges, and so the intent of the rules is to make sure that the main and subcontracted providers both add value to the employer’s apprenticeship programme”.

Skip forward a few months and the DfE tell FE Week they’ve looked at the latest figures and found that the total sector topslice was 20 per cent last year.

So, according to the DfE, everything is tickety-boo, nothing to see here, fine and dandy.

No problem with Learndirect keeping close to £19 million in fees (34 per cent), including a single deal with a £4.7 million (40 per cent) fee.

No problem with 28 per cent of prime providers charging more than 20 per cent, and 12 charging more than 30 per cent.

The DfE argument seems to be that if the average is 20 per cent, then the outliers don’t matter.

What an appalling conclusion – that if the majority are acting responsibly, then there is no need to stop those that fail to.

It is clear that the education select committee, led by former skills minister Robert Halfon, will heavily criticise subcontracting fees in its forthcoming report.

The National Audit Office will also be taking a look as part of an apprenticeship reform review, as will the Mayoral Combined Authorities during the transition to devolution of the Adult Education Budget.

And FE Week will challenge both Anne Milton and Damian Hinds on their “no concern” conclusion at the earliest opportunity.

My hunch, as well as hope, is that the DfE defending the indefensible won’t hold forever.

But so far I’ve been proven wrong, so I won’t be holding my breath.

Read the story: Ex-minister calls subcontracting fees ‘scandalous’ but DfE has ‘no concerns’

Ofsted watch: Bad week for providers – especially UTCs

It was a poor week for providers who received full inspections, as one failed to improve its grade three and two university technical colleges were hit with damning grade four reports.

People and Business Development Ltd, an independent provider based in Suffolk, was rated ‘requires improvement’ across the board – which was worse than its inspection in October 2016 when it achieved ‘good’ in one headline field.

“Leaders have not effectively dealt with the weaknesses identified at the previous inspection because they have not taken effective action or directed staff well enough,” inspectors said.

“Leaders do not effectively assess the quality of teaching, learning and assessment. Consequently, they have not ensured that assessors improve their practice, to enable learners to make rapid progress.”

Ofsted found that the proportion of apprentices who achieve their qualifications was “too low”, and “too few” achieve their apprenticeships within planned timescales.

To improve, inspectors said PBD must ensure that employers are “routinely involved in the planning of learning programmes and in the reviews of progress with apprentices”.

Meanwhile, hugely critical ‘inadequate’ reports were handed to UTC@Harbourside and Health Futures UTC.

Bullying – some of it racial – was rife at Harbourside, which announced closure last week.

Some pupils in year 10 have a “miserable time” at the UTC “due to bullying, some of a persistent nature and which results in a few pupils being isolated”.

It was also accused of “too often” breaking “too many promises”.

Leaders and governors at Health Futures UTC, based in West Bromwich, were deemed “ineffective”, having missed “significant” teaching weaknesses, according to inspectors.

“Teaching has been weak and consequently, students have made very poor progress,” the report said, adding that the top team had failed to recognise these failings until exam results were released in August 2017.

There was one monitoring visit of a “new” apprenticeship provider published this week, which produced a positive report.

Impact Futures Training Limited is based in Berkshire and delivers training to over 150 apprentices in industries including health and social care, management and customer service.

“Senior leaders and managers are very committed to providing a high and improving standard of training for all apprentices,” inspectors said.

They’ve also “set and communicated a clear strategy to address training skills gaps in the business, and health and social care sectors”.

Inspectors added that tutors ensure that apprentices “develop new skills, knowledge and behaviours that allow them to carry out their work roles more effectively”.

As a result, “apprentices are able to show how their learning has improved the quality of service that they offer their clients”.

Lastly, three short inspections were published this week, in which Wiltshire College, Cheyne’s (Management) Limited in London, and Stockton-on-Tees Borough Council maintained their ‘good’ ratings.

Independent Learning Providers Inspected Published Grade Previous grade
People and Business Development Ltd 05/06/2018 04/07/2018 3 3
Impact Futures Training Limited 05/06/2018 06/07/2018 M M

 

Other (including UTCs) Inspected Published Grade Previous grade
Health Futures UTC 22/05/2018 03/07/2018 4 NA
UTC@harbourside 22/05/2018 04/07/2018 4 NA

 

Short inspections (remains grade 2) Inspected Published
Wiltshire College 23/05/2018 04/07/2018
Cheyne’s (Management) Limited 05/06/2018 05/07/2018
Stockton-on-Tees Borough Council 05/06/2018 06/07/2018

Why we are planning to use a single licensing approach for T-Levels

Choosing awarding organisations in open competition will not only give the new technical qualifications the greatest chance of success, but clarify the landscape for students, promises Anne Milton

I was recently interviewed by Nick at FE Week, who wanted to know why we are planning to use a single licensing approach for T-levels. I thought I’d put my thoughts down here to explain more fully why we have decided to do this.

T-levels are a once in a lifetime opportunity to change the way technical education works in this country, putting it on a par with the very best available in other countries. In the past, technical education courses were of variable quality and not always valued by employers. And that’s exactly what we want to change. Single licensing has an important role to play in doing that.

The Sainsbury Report, which was published in 2016, recommended that for each occupation or cluster of occupations, there should be one high-quality qualification for 16-19 year olds that meets employer-set standards. The report also recommended that a single body or consortium should deliver each qualification under an exclusive licence. This would be awarded for a fixed time period following an open competition.

So why did the report recommend this approach and why have we followed the advice? Well, the key reason is that we want to protect the standard of T-levels. T-levels must be high quality and those taking them must know that they represent the gold standard — that’s what introducing T-levels is all about. Making sure all T-levels are of the same exemplary standard also means that they will be valued and easily recognisable by employers.

Of course, procurements are never easy

Awarding organisations (AOs) play a vital role in our education system, and for me there are two key benefits that stand out when it comes to single licensing. By selecting one AO to work on each T-level, it means they will have been successful against other competitors in demonstrating their vision to us, making it a shared vision to give our T-levels the greatest chance of success. Another reason is that we want to make the options as clear as possible for students wanting to do T-levels. With thousands of qualifications at level 3 and below, the current landscape can be confusing for students. We have a chance to change this and a single-licence approach will make choices much easier.

Of course, procurements are never easy – there are always losers and disappointments, and the process can be challenging. But they are often necessary if we want to make sure we are getting the best. So we are being completely open and transparent with the market about how we intend to run this procurement. We held events in June to meet with awarding organisations to talk about our procurement plans, with further activities to come, and we are reflecting on the feedback we have heard from the Federation of Awarding Bodies, the Joint Council for Qualifications and others. We are working hard to think about how we can make the procurement more attractive, create lively competition and make sure we get value for money for the public purse. This approach means we should retain the best elements of the competitive market and still get the stability we need to make sure standards are properly understood and kept up.

We’ll also be putting in place rigorous monitoring arrangements to minimise the risk of failure – and we will make sure there are effective exit arrangements at the end of each licence to enable smooth transfer from one awarding organisation to another.

The Sainsbury Report’s recommendations are now in law – in the form of the Technical and Further Education Act 2017 – and we are proud to have followed them.

The single licensing model for T-levels means learners, employers and parents know exactly what they will be getting, and have a clear choice between excellent technical and academic routes. T-levels are a fantastic opportunity for everyone – providers, employers and young people – to get the technical education that they deserve, and the country needs.

Ex-minister calls subcontracting fees ‘scandalous’, but DfE has ‘no concerns’

The government has for the first time concluded they have “no concerns” about subcontracting fees, despite more than 10 providers charging an average of over 30 per cent last year, FE Week can reveal.

This is completely at odds with the view of the last skills minister Robert Halfon, who now chairs the education select committee, and who called the latest figures “absolutely scandalous”.

Last week the Education and Skills Funding Agency published, also for the first time, the result of a subcontracting data collection completed by all prime contractors in receipt of funding last year.

But it looks like a recently announced review of charges will not lead to any tightening of policy, as the Department for Education thinks there’s nothing to worry about.

“We have no concerns on the level of subcontracting fees being paid by providers.

“Our recent data shows that approximately 80 per cent of funding goes straight to the front line, supporting learners, apprentices and employers to get the training and skills that they need,” a DfE spokesperson said.

FE Week’s analysis of the 2016-17 figures showed that the total level of charges by 407 prime contractors on subcontractors was £110.6 million (see tables below).

Just under a third of primes were charging above the 20 per cent best-practice threshold agreed by key sector bodies in March, with Learndirect and John Ruskin College among those taking the biggest cut.

The level of these subcontracting fees is absolutely scandalous

“The level of these subcontracting fees is absolutely scandalous,” said Mr Halfon. “Money should be going to deliver high-quality front-line training, not paying off middlemen.

“When government funding ends up the lining the pockets of companies taking a hefty cut and delivering little value, then both apprentices and the taxpayer are being let down.”

His successor as skills minister, Anne Milton, also agreed with education committee MPs in May that huge top-slices in subcontracting concerned her and that it amounted to “wasted money” in some cases.

However, she claimed it was “too soon” for the government to take action in specific cases.

The Association of Employment and Learning Providers took to Twitter to criticise “unacceptable fees” soon after the subcontracting charges were finally published on June 29.

FE Week analysis also showed that 12 providers charged an average top-slice – which is the common term used for subcontracting fees – in excess of 30 per cent.

At 39 per cent, John Ruskin College – which disputed the accuracy of the figure – appeared to have the highest average top-slice percentage.

The biggest single deal was a £4.7 million (40 per cent) Learndirect top-slice taken from the £11.9 million of the adult education budget that went to training delivered by Go Train Limited. The provider declined to comment.

Top-slicing describes the amount that prime providers charge subcontractors in so-called management fees when they run training on prime providers’ behalf.

Concern has mounted in recent years that certain lead providers were charging excessive rates as an easy way of supplementing their incomes.

The ESFA had revealed in April that subcontracting fees and charges would be reviewed to ensure government funding is being used for “recognised costs”.

“In the coming months, we will be reviewing aspects of the subcontracting funding rules,” it said.

This will include looking at “subcontracting fees and charges, so that we can be assured that our funding is being used for recognised costs”.

Any subsequent changes to subcontracting rules are expected to come into force from August.

Individual lead providers used to have to publish their annual figures on their websites by the end of November every year.

This changed starting in 2016-17, when new rules dictated that providers had to inform the ESFA of their figures, which would henceforth be published centrally.

But the agency came in for heavy criticism as November passed without any indication of when the full figures would be revealed for the past academic year.

The sector finally got its answer in April, after Gordon Marsden, the shadow skills minister, lodged a written parliamentary question asking when the government planned to publish the fees data.

The education minister Nadhim Zahawi confirmed that they would be available by the end of June.

See FE Week editor NIck Linford’s editorial on subcontracting fees here.

‘Comprehensive’ new guidance coming soon

“Comprehensive” new subcontracting guidance agreed between key government education agencies and FE bodies will be published within weeks, FE Week can reveal.

But the Association of Colleges has indicated it will not come with tougher limits on top-slicing fees. 

A 20 per cent recommended limit was agreed in March by the Association of Employment and Learning Providers, Holex and the Collab provider group.

This was conspicuously missing a sign-off from the AoC, which insisted at the time it was developing other guidance “properly” with the Education and Skills Funding Agency and the University Vocational Awards Council.

FE Week asked them how this was progressing, considering that latest figures have showed how many primes are still charging a level considered by many to be excessive.

A spokesperson said it is still developing a “comprehensive guidance document” with the ESFA and UVAC, as well as other organisations including Ofsted, the Institute for Apprenticeships and AELP that “considers subcontracting from all angles relevant to a provider”.

This should be out within “the next few weeks”.

Teresa Frith

Teresa Frith, senior AOC policy manager, indicated they want primes to retain control of setting their own charges.

“We are not condoning overcharging in subcontracting, quite the opposite, but want providers to be free to determine how much it costs them to support subcontractors effectively within the new apprenticeship market and within the new rules.”

“We advocate for complete transparency in the process of determining the fees imposed by a lead provider,” she added.

“The relationship should be a partnership where both sides can see value. It is the quality of the offer in general that should be the focus of concern, not the price attached to that quality.”

AELP boss Mark Dawe reiterated his defence of the 20 per cent recommended limit.

“In signing up to our joint guidance, the members of AELP and Holex and Collab’s college members are by implication struggling to identify where fees in excess of 20 per cent might be justified whatever services are being offered,” he said.

“We would argue that by denying so much money to frontline provision, it is very much the quality of provision received by the learner which is being endangered.

“The ESFA data suggests that there are too many institutions where the funding is actually being used to prop up the general accounts.”

3aaa inspection ‘incomplete’ as whistleblowing sparks review

An investigation is being carried out by government officials into apprenticeship giant Aspire Achieve Advance, after claims made by a whistleblower.

FE Week revealed last week that Ofsted’s latest inspection of 3aaa – which holds the largest ESFA apprenticeship allocation – had been declared “incomplete” following intervention from the Education and Skills Funding Agency.

We can now reveal that 3aaa had been expecting a grade 1 outcome and the inspection has been classed as incomplete owing to an ongoing investigation led by the ESFA.

FE Week also understands that the provider is facing an employment tribunal claim from a former employee who does not wish to be named.

The employee raised concerns that now form part of the ESFA investigation after they were set out in a letter to 3aaa bosses, seen by FE Week, dated February 28, 2018.

A response from Di McEvoy-Robinson, co-founder and director of 3aaa, also seen by FE Week, stated that this had sparked an “internal review”, and that the allegations had been referred to the ESFA.

Neither 3aaa nor the ESFA would confirm to FE Week whether the allegations were shared.

Ofsted originally confirmed on June 20 that it had inspected the provider in May and nothing was amiss.

“The report is currently going through our normal processes and will be published in due course,” a spokesperson said at the time.

And FE Week can reveal that 3aaa held a staff conference at Derbyshire County Cricket Club where it is believed they celebrated the expected outstanding grade (see picture).

And co-founder and chief executive Peter Marples took to social media to describe an “amazing week – challenging but back to back 1 it could be”.

But there was a change of position shortly before the report was published and the inspectorate released a second statement to FE Week mentioning “new information”.

“Given new information that has come to light, we have decided to declare our inspection of Aspire Achieve Advance Limited incomplete,” a spokesperson said.

“In due course, pending further information from the EFSA, we will decide whether we need to return to the provider to gather further evidence.”

The provider has seen significant growth under the leadership of Marples and McEvoy-Robinson, its chief executive and director respectively. In 2015 the provider was awarded an “outstanding” grade by Ofsted.

Its allocation for non-levy apprenticeships now stands at nearly £22 million, which is up from £5.5 million at the start of the academic year.

Direct ESFA funding increased from just £390,000 in 2012-13 to £3.6 million the following year. It rose again to £12.5 million in 2014-15 and to £21.7 million a year later.

Its apprenticeships include IT, software, digital marketing, accountancy, financial services, business administration, customer service and management.

3aaa, at the time of going to press, has not provided a comment on Ofsted’s decision, the ESFA investigation, or accusations made by the whistleblower.

The ESFA would say only that it never comments on whether investigations are taking place.

Three ‘inadequate’ UTCs in a week as Lord Baker blames Ofsted

Ofsted has dealt a series of devastating blows to university technical colleges this week, with three of the 14-to-19 technical and vocational institutions rated “inadequate” in a week.

Inspectors were damning in their criticism of UTC@Harbourside, Derby Manufacturing UTC and Health Futures UTC in grade 4 reports published between June 28 and July 4.

The latest verdicts mean that over a quarter of the UTCs inspected to date have been given the lowest possible overall grade.

This is sure to be an embarrassment to the Conservative party, which pledged to have a UTC “within reach of every city” in its 2015 manifesto.

Nonetheless, Charles Parker, boss of the Baker Dearing Trust, which backs UTCs, insisted it was “absolutely not” time to admit the experiment had failed.

“We are disappointed at our current Ofsted records, which we are working hard to improve,” he acknowledged.

“However, the excellent destinations of our students and the satisfaction of parents and employers mean it is much too early to say that standards are bad.”

UTCs’ destination data is “the best of all schools in the country”, yet this is not taken into consideration by the education watchdog, he said.

Lord Baker, the trust’s co-founder and architect of UTCs, also told FE Week that he believed the current inspection regime was unfair for this reason.

“A UTC is not a school or a college, it is a hybrid animal,” he said in an interview in May.

“Ofsted takes no account of employability in inspections and that is a big test for us.”

However, a spokesperson for the watchdog rejected these claims.

“Inspectors take into account the destinations of UTC pupils, but as we set out in our handbook, no single measure determines the outcome of an inspection,” he said.

Ofsted inspects UTCs as schools “because that is the legal status they have”, and all schools are inspected against the same criteria.

“Clearly some UTCs manage to meet these requirements,” he added.

In the same FE Week interview, Lord Baker hit out at schools that refused to comply with their legal requirement to open their doors to technical and vocational education providers, including UTCs – as set out in the Baker clause amendment to the Technical and FE Act.

And in an interview with The Times newspaper in 2017, he blamed “poor governance and mistakes made” where UTCs had failed.

Thus far, 10 of the 36 UTCs inspected by Ofsted, or 28 per cent, have received a grade 4 verdict.

A further 13 have been rated “requires improvement”, meaning a massive 64 per cent are rated less than good.

And to date eight UTCs have closed after failing to attract enough pupils, owing in large part to the difficulty in persuading them to change schools at 14.

David Russell, the chief executive of the Education and Training Foundation who formerly led on vocational education reform at the Department for Education, took to Twitter to vent his anger at the latest reports.

“This was the 100 per cent inevitable outcome of UTCs’ policy, as many inside DfE said at the time,” he tweeted.

“This hideous experiment in ‘technical education’ policy must stop.”

The most critical of the three reports was for UTC@Harbourside, published on July 4 just two days after the school announced it would close in 2019 after failing to recruit enough pupils to make it financially viable.

According to 2018 school census figures, it has 130 pupils on register in 2017-18, down from 141 in 2016-17.

Bullying – some of it racial in nature – was found to be “frequent”, which led to some pupils having a “miserable time” at the school.

“Adults do not act decisively enough to stop it and prevent repetition.”

Pupils and learners at the school, which opened in 2015, are “hugely disappointed” with its “failure to live up to their expectations”, the report said.

The school’s governors said they “fully accept the findings of the inspectors and are committed to implementing the recommendations” for its remaining pupils.

The UTC@Harbourside report came just a day after Health Futures UTC in West Bromwich was branded “inadequate” across the board.

Leaders and governors at the school, which also opened in 2015, were deemed “ineffective”, having missed “significant” teaching weaknesses, according to inspectors.

“Teaching has been weak and consequently, students have made very poor progress,” the report said, adding that the top team had failed to recognise these failings until exam results were released in August 2017.

However, Ofsted acknowledged that the school’s new interim principal, Ruth Umerah, was starting to turn things around.

Leaders and governors at Derby Manufacturing UTC drew criticism for their “over-generous” view of quality, which “prevented leaders and governors from taking appropriate action to secure the required improvements”, according to the June 28 Ofsted report.

‘Incredible’ that DfE unsure which of its apprentices were already civil servants

The Department for Education has drawn criticism for not knowing whether more than a third of its apprentices were new or existing civil servants.

As of May 10, the department had 186 employed apprentices.

Through a freedom of information response, the DfE revealed that 76 of these were existing civil servants and 36 were new entrants to the government.

However, for 74 of them the department admitted it did not know whether they were new civil service employees or not.

It said this was because the department gathers data on apprentices via a voluntary questionnaire and not all questionnaires are returned.

Lord Watson of Invergowrie (pictured), who has a keen interest in apprenticeships and often brings the topic to debate in parliament, expressed his shock.

He called the situation “ridiculous” and said it did not “inspire confidence” for employers dealing with the complexities of the apprenticeship levy.

“I find it incredible that any employer would not know how many apprentices are new appointments or existing members of staff,” Lord Watson, Labour’s education spokesperson in the House of Lords, told FE Week.

“That is particularly so when the employer in question is the department overseeing the whole expansion of apprenticeships and the apprenticeships levy.”

He promised to table a parliamentary question to “probe this matter further”.

“To have this left hand right hand situation does not exactly inspire confidence in other employers, many of whom are struggling with the levy system, as they find it bureaucratic and impenetrable,” added Lord Watson

“What this doesn’t do is give the DfE any firm footing on which to question other employers that they are not satisfied with how they are proceeding with the levy.

“It is a question of getting their own house in order first. They don’t just need to do that, but need to be seen to have done that, to inspire confidence.”

If colleges are not careful, HE will muscle in on their territory

The FE sector is already beleaguered, but market forces will soon see universities trying to carve themselves out a bigger slice of the pie, writes Ewart Keep

A research project about to be published by the FE Trust for Leadership on the marketisation of further education points to the growing competition that colleges face from both schools and universities. There is a danger that the FE sector may be about to be caught in a pincer movement.

With the current demographic downturn in older pupils, English secondary education is currently suffering from local overcapacity, a situation exacerbated by the government’s school choice agenda and its sponsorship of new market entrants such as UTCs, studio schools and free schools.

Moreover, between 2011/12 and 2014/15, about 260 school sixth-forms entered the 16-to-18 arena, and the number of approved apprenticeship providers or with an AEB allocation registered as in scope for Ofsted inspections rose from 1,043 in 2011/12 to 2,543 in April 2018. The 14-to-18/19 marketplace that has been created as a result of these developments is a brutal one, with FE colleges, UTCs and other new forms of school, apprenticeship providers, sixth-form colleges and traditional school sixth-forms all fighting for “market share”.

On the other side of the fence, HE has been seen by all mainstream parties as the chief means to deliver higher technical and vocational skill and promote social mobility. It has many political allies and has attracted increased resources through fees.

However, at present there is overcapacity in HE. This is partly driven by the current decline in the volume of 18-year-olds (which is set to last until 2020), and partly by increased competition for students between the Russell Group universities which are expanding their student numbers, and lower-tier institutions which have seen applications fall.

Some universities are already searching for new markets and customers in order to sustain themselves

Empty places are not an easy option to live with, because since fees went up, universities have spent £28 billion, much of it borrowed from banks, on new teaching infrastructure, halls of residence, cafes, social spaces and refurbishment programmes aimed at attracting students. A fall in cashflow from fees is dangerous as the financial performance in many institutions is weakening. Some universities are already searching for new markets and customers in order to sustain themselves.

One route is to expand foundation years, and put tight limits on the validation of degrees in FE, particularly where the university is seeking to build its own degree-apprenticeship provision. The other is to move directly into what have hitherto been seen as part of the FE marketplace, such as access courses and level three vocational qualifications, as some universities already have. This suggests that battles will loom over who fills the gap in technician level or sub-degree courses.

These are not new problems. Back in 2005, the Foster Review noted that “FE colleges are more and more drawn and squeezed into roles that are defined by demography and policy changes and the emerging roles of HE and schools”. The issues have simply been heightened by a funding squeeze, increased marketisation of the different areas of FE provision, and the increased pace and scale of the marketisation of schools and, more latterly, HE.

What should FE’s response be? One clear message is that colleges need to stake their claim, as publicly as possible, to a large slice of the new sub-degree technician action. The virtues of HE delivered through FE also need to be publicised (not least to local MPs) – colleges, not universities, are the main provider of lower-cost degree courses, and they are the ideal provider if policymakers want to try to revive part-time and adult participation.

Finally, as a medium-term goal, it is surely not beyond the wit and imagination of a powerful mayor and combined authority to seek to bring together local FE and HE providers in some kind of more integrated local tertiary partnership or alliance, particularly in areas where colleges have themselves learned to operate more cooperatively.

If the 10% apprenticeship co-investment is removed, it should be done selectively

The 10 per cent apprenticeship contribution rule for non-levied employers remains a lively issue. It is frequently cited by training providers as a barrier to engagement, and the calls for its removal by leading sector bodies such as the Association of Employment and Learning Providers and others remain strident.

An air of suppressed anticipation awaited Anne Milton’s address to AELP’s national conference last week, since it had been informally trailed that she might make just such an announcement. However, the apprenticeships and skills minister said that while the calls for removal had been “noted”, the policy would not change “any time soon”. Subsequent speakers with insider experience of the Department for Education wryly suggested that “noted” is established civil service speak for sidelining an issue until it can be comfortably forgotten about.

A new approach is clearly needed. There are, in any event, some issues with the call for a complete removal of the 10 per cent contribution that have doubtless influenced the DfE’s thinking.

The notion that some employers simply “can’t pay” is far from universally credible, even in the case of small firms. A 10 per cent contribution to a £2,000 apprenticeship spread over 18 (or even just 12) months represents a monthly payment of only £11 (or £17). Of course many apprenticeships cost more. But even for a top-end £27,000 degree apprenticeship, where one might reasonably expect an employer to be a little bigger than purely “micro” or start-up level, the contribution is spread over three years and thus the monthly payment is only £75. This is obviously a more substantial outlay, but it is unlikely to be a bank-breaker if it really does represent an important resource acquisition for the employer.

Furthermore, the quality of investment made by employers in something they are paying for – even at just 10 per cent – is likely to be higher than for something that is given for free. That particular aspect of human psychology is well documented.

A simple truth is that 10 per cent co-investment may be less of a barrier for employers than it is for training providers’ engagement teams, who would obviously find it easier to sell apprenticeships if there were no charge at all. But that nature of provider-employer interaction does not always promote good quality. Furthermore, removing the 10 per cent would also significantly reduce, or remove entirely, the downward negotiating pressure from the employer on the fee. What’s the point if it’s free anyway? That change would clearly be for the benefit of providers.

Social mobility is often quoted as a reason to support calls for the removal of the 10 per cent contribution. However, if paying 10 per cent really is a big financial problem for employers, and if removing it will boost their participation, then that will largely be for existing employees only. If an employer can’t afford the (often) modest amounts associated with 10 per cent, then they are hardly going to meet the cost of a new employee, even at apprenticeship pay rates, never mind the cost of off-the-job training and everything else. So removing the 10 per cent will not really support social mobility in the way that proponents argue.

Levy-paying employers subjected to a compulsory payroll tax might also rightly question why they then have to pay the full (or maybe negotiated) list price when they see non-levied counterparts going from just 10 per cent to absolutely nothing. It is not cost-invisible for levy-payers just because they have had the money deducted up front.

There is obviously a powerful argument for championing social mobility through apprenticeships, but given the minister’s recent remarks, modifying the calls for a blanket removal of the 10 per cent co-investment may be more fruitful. For example, campaigning more selectively for the removal of co-investment for:

  • all level 2 apprenticeships;
  • all new apprenticeships – e.g. new positions/jobs;
  • apprenticeships in defined disadvantaged postcode areas, whether relating to the employer, the apprentice, or both;
  • employers below a certain redefined size for 19+ aged apprentices – “small” is not the same as “micro” (or the current sub-50 employee “no contribution” rule could be extended to 16-18 and 19-24 EHC apprentices).

Additionally, given Ms Milton’s comments about the need to “demonstrate causality”, and if the 10 per cent contribution really is a disincentive, then robust research should be quickly commissioned and presented.