So let me firstly declare my interest: I am a fan of the UKs qualification system for vocational education and training and as a CEO for an awarding organisation, it’s no surprise that I should be championing the cause for regulated occupational qualifications. FDQ is also an approved end-point assessment organisation, so we have even more skin in the game.
Against that backdrop, I was delighted when IfATE’s long-awaited consultation on mandating qualifications in apprenticeships launched in December included proposals for updating the policy and criteria for trailblazer groups when deciding whether qualifications should be included in the future.
I have completed many consultations in my 30 years in the sector, and with IfATE approaching its sixth year as the overseeing body for apprenticeships, I was hoping to see a detailed analysis of several hundred thousand apprentices who have started, left and/or completed their programmes and end-point assessments.
Disappointingly, the consultation provides no such information. Why not? EPAOs submit grade requests for completers to the DfE each week, and this data is reconciled with apprentices’ individual learning records (ILRs). The information on retention and relative success is available for each standard, and should be available for publication.
This is a significant omission in a consultation proposing to make it harder for employers to decide if qualifications will benefit apprentices on standards. These facts should have been presented to enable stakeholders to consider whether apprentices undertaking standards with mandated qualifications achieve at a higher or lower rate (I suspect higher) than those on standards with no such requirement.
Understandably, with 650 standards available across multiple occupations, the landscape is complicated. However, the consultation does confirm that around 60 per cent of apprenticeships do not mandate a qualification. Therefore, if 50 per cent of these apprentices leave without completion, it must mean thousands of leavers each year have no formal transcript of accreditation (Certificate of part-achievement) from an awarding organisation to show for their time on their programmes.
The reason awarding organisations can award and training providers can claim part-achievement certificates is because they are protected to a large extent by regulatory centre assessment standards scrutiny (CASS). This system requires awarding organisations to have quality assurance controls in place with centres to ensure the consistency and reliability of assessment practice.
I am therefore incredulous at the suggestion from IfATE that qualifications will no longer be mandated on the basis of providing better structure for off-the-job training and/or adding breadth and depth to an apprenticeships. Structure, breadth and depth are precisely the bedrock of the current system.
The consultation is unlikely to attract universal consensus. The CASS, for example, is costly to implement. However, FDQ has seen many employers and providers continue with qualifications even where the trailblazer has withdrawn the mandating requirement. IfATE ought to investigate this type of scenario.
The updated criteria proposed in the consultation would allow for a qualification to be mandated only if it is required by a regulator or a professional body. The other option provided by the IfATE is based a ‘labour market requirement’, where it appears trailblazer groups will be subjected to a burdensome justification exercise, not to mention the work of aligning the qualification with the occupational standard, potentially resulting in adaptation of current qualifications or design of entirely new ones.
But trailblazer groups are mostly made up of busy employer representatives, all volunteering their time. New burdensome requirements will present a significant barrier to qualifications being included. Employers know what their businesses need, but they are not bureaucrats with the time or inclination to gather evidence to prove those needs.
The IfATE proposal states that it will only consider qualifications if the apprentice is heavily disadvantaged as a result of not obtaining one. Arguably, that England is the only nation in the UK where apprentices can leave with no accreditation heavily disadvantages them all.
So let’s have a balanced debate on the relative merits of qualifications in apprenticeships. But to do so, it needs to be an informed debate, and that means IfATE must supply trailblazer groups with labour market information underpinned with achievement data. Anything less undermines the consultation.