Amid the talk of certain apprenticeships not being “appropriate” for government funding, it’s time to be honest about a problem hiding in plain sight. One that needs to be addressed before the axe comes down on funding for operations manager, team leader or any other apprenticeships.
It is likely that many of the so-called “apprenticeships” delivered to adults and funded by the levy are not actually apprenticeships at all.
Had they not been funded, the number of true adult apprentices would not have increased by anything like as much, freeing up money for more apprenticeships for younger people and genuine adult apprentices, including up to level 7 where funding has now ceased for the over 21s.
It’s not too late to fix the problem, but time is short.
It’s worth reminding ourselves of the rules.
- All government-funded apprentices have a right to receive the amount of off-the-job training they need to reach occupational competence. Every apprenticeship has a minimum requirement but there’s but no maximum. In most cases the minimum is set at roughly six hours a week. So, just less than a working day each week.
- Off-the-job-training (all of it – not just the minimum required) must happen during the apprentice’s normal paid working hours. If, by exception, training takes place outside these hours then, a bit like paid overtime, the apprentice must agree and must be paid. It makes no difference how the training is delivered.
- If there is insufficient off-the-job training, or training takes place outside paid working hours, the apprenticeship is not compliant or fundable.
- The agreed off-the-job training requirement serves as proxy for the size of the apprentice’s skills needs. The absolute minimum is 187 hours of training over 8 months – most apprentices need significantly more. This means someone with modest skills needs (a few discrete management topics, say, or they want to learn how to use AI tools to help them in their role) is unlikely to be eligible.
So, for an employer, a genuine apprenticeship is a huge investment, regardless of government funding for the actual training.
Take an operations manager on £50,000 a year, or £25 per hour. The employer, manager and training provider review their skills needs and agree they need 418 hours of training (the usual minimum for the operations manager apprenticeship).
This means the employer has to make an investment just in salary (excluding NI and other costs) of £10,450 (418 x £25). True investment is more because of lost productivity during the training period and the need to cover the apprentice’s work.
The level 6 chartered manager apprenticeship has a minimum requirement of 926 hours and, at this level, the apprentice will be paid more. Do the maths.
No sensible employer makes this kind of investment unless they have a colleague with great potential but a significant skills shortfall. I’m pleased to know many employers who regularly make such investments, and the returns to their organisations and colleagues are huge.
However, I fear this is not the case across the sector. I suspect that, too often, the skills gap is narrow or significant off-the-job training is taking place outside normal paid hours.
I bet I’m not the only person who has come across degree apprentices who get six hours a week of study time at work but also need to study at the weekend (and not just on an occasional basis). I’m sorry but they are not apprentices.
To free up money for more apprenticeships for young people and for older people with significant skills needs, the government needs to ask:
- How many apprentices are doing significant amounts of study in their own, unpaid time?
- How many apprentices are not actually undertaking the minimum required amount of off-the-job study (regardless of what might be recorded)?
This is fiddly work. It means having honest conversations with employers, apprentices and providers. It may cause some pain, even embarrassment. And it’s harder than simply drawing a line through “inappropriate” apprenticeships or putting in place more age restrictions.
But it’s the right thing to do.
Age restrictions and de-funding would capture some ineligible apprentices but also harm eligible apprentices from disadvantaged backgrounds, those with “squiggly” careers and later-life career changers. It would be unfair on the many fantastic employers already investing more than the minimum and following the rules.
And so, if we are to ensure access to great apprenticeships for those who need them, and maximise the impact of apprenticeships on our economy, it is work that needs to be done.
A good article.
It ignores the supervisory cost in the business as well.
The result is employers should revert to commercial training to achieve the same end at a fraction of the cost. The levy has distorted employer thinking. I was speaking to a major VP of a major international business just three months ago and asked them if they measured the costs of Apprenticeship programmes in their organisation – the cost of the team built to support apprentices, the cost of the supervisory time. She looked me in the eye as if i was some rocket scientist and said they had never measured it.
If they did, they would never have gone ahead for sure.
Put simply (and not L7) how can you justify an AAT commercial course at £495 and an AAT L3 Apprenticeship costing £9000 of funding (plus all the time off the job and supervision time) for what is exactly the same qualification and its the qual that is needed to progress. Both individuals have to attain the same level of competence !
Thanks Peter – I’ve added a few more thoughts below.
Slightly pedantic but hours outside of usual working hours can be TOIL, they don’t have to be overtime. Also, if the Apprentice is getting 6 hours a week of work time, then they *are* eligible. If they are *choosing* to do additional study outside of work time then, as long as these hours are not used to meet the minimum requirements, then it’s none of our business. Whilst we might question these rules, they are the rules.
If anything, the problem we’ve got at the moment is that providers are reducing the funding they get for an App too much (through misunderstanding the “Recognition of Prior Learning” rules).
Thanks Steve, I’ve added a few more thoughts below.
With most apprenticeships being funded from larger employers levy contributions or transfers. I can only see that by cutting pathways routes limits progression opportunities only and encourages staff to look elsewhere for their development. I think we would all agree that there is a problem with the growing number of young people not in employment. With finances in most organisations being tight or scutinised, there is not the salary funds availalble to take on young people to get that vital first step on the employment ladder. I dont beleive cutting pathways is the correct route, at best perhaps capping numbers per organisation may be a better option. Perhaps the government should consider what financial support can be given to incentivise employers to look at recruiting more younger people, in support of this employers should look more closely at succession planning this would then create openings for young people.
There are some degree apprentices, for example Pre-Registered Nurse, where the employer is releasing the apprentice for 100% of their time on the apprenticeship, to attend University, and undertake placements, not solely back at their base employer, for a 3 year programme, and paying that apprentice whilst they study, they also have to back-fill that post to ensure patients are being treated. The commitment from employers is real for apprenticeships, and that includes degree apprenticeships, and the comment about them working at weekends, for some that is their normal working hours. Other apprentices are embracing the learning journey they are on, see the apprenticeship as valuable as the employer does, and are motivated to achieve the best they can. They are getting the support from employers, but are also putting in extra time for themselves, which is a credit, as long as, if that is not their normal working hours they do not claim that as OTJH.
Careers are now changing, 2 or 3 times during a person’s working life, are government saying that an individual, or an employer, cannot choose to invest in that career change. The employer owns the levy, if they do not have the right to choose how they spend that levy on apprenticeships, and for whom, then it is purely another tax on employers from the government. Employers are better positioned to know what they need in the short, medium and long term, to retain staff, succession plan and talent spot. Why are they not being allowed to do that?
Well Said Karen
Thanks Karen, I’ve added a few more thoughts below.
An employer has a duty to give the apprentice enough time to pass/achieve occupational competency, not excel. If apprentices want to do more in their own time, to achieve better that is their right, but doesn’t make them less of an apprentice or the employer non-compliant.
I am pleased to have got some discussion going – that’s what I’d hoped! In turn:
1. Peter, agreed that employers ought to consider the full cost/benefit of the apprenticeship v. a commercial course and I agree too on supervisory time as well as the salary and other costs mentioned. My point is that, were OTJ to be fully embedded during normal working hours by employers and providers, then we’d inevitably see a big drop in adult apprenticeships and shift towards younger learners – without the need for further intervention.
2. Steve, agreed on TOIL, so long as the apprentice agrees to taking time off in lieu and does actually take it. I disagree on your second point though. Funding rule 81.3 says: “Some apprentices and standards will need more than the minimum requirement. Apprentices must receive the volume of high-quality apprenticeship training that they need to develop full occupational competence.” Whilst this rule does not explicitly say “high-quality off-the-job apprenticeship training”, this is what “minimum requirement” refers to. Rule 86 clarifies: “The provider is ultimately responsible for the delivery of all required off-the-job training, to enable the apprentice to reach full occupational competence against the standard.” And all off-the-job training must happen (with rare exceptions) during “normal working hours” (Rule 77.1). NB, Rule 86 is problematic because in many delivery settings the provider cannot compel the apprentice to do the training – this is down to the employer. However, the rules are clear: if the apprentice needs 8 hours per week of OTJT and only 6 of those happen during normal paid working hours, the apprenticeship is not compliant. An apprentice can choose to do some study in their own time but “There must be no pressure or expectation that the apprentice will undertake any training in their own time in order to complete the apprenticeship” (Q12 of the DfE’s OTJ “policy background” document). So, it can’t be a requirement.
3. Karen, it’s great that some employers are fully supporting significant off-the-job training and the investment that entails. However, for most degree apprenticeships, the investment of time is enormous, certainly where (as very often) the university has embedded a part-time degree in an apprenticeship. A full time academic (undergraduate) year is 120 credits and 1,200 hours of study. Over three years, that’s 3,600 hours. Assuming 46 working weeks a year, it’s 26 hours of study a week. Over 6 years, it’s still 13 hours a week. It would need to be a 12 year+ programme to get down to 6 hours of OTJT per week. Even assuming some element of efficiency from the fact that the apprentice is working with competent practitioners in their field and so may learn faster, it is very difficult to make these models work unless the apprentice has significant prior learning, which would bring down the funding of course. Even if the apprentice is doing the minimum OTJ required for the apprenticeship standard during working hours, if they actually need 3,600 to get to occupational competence, then it’s an issue (Rule 86). Conversely, if they need a much lower amount (e.g. the 835 hours for the L6 social worker apprenticeship) but Levy funds are being used to pay for 3,600 hours of study, that’s a different problem.
It’s not just about employer/provider behaviour though. Much of the problem here though lies with inconsistency and poor drafting in the Funding Rules and other documents, which create confusion. For example, the Employer Agreement says: “4.5. The Employer shall ensure completion of the minimum off-the job training hours or delivery hours as required by the Funding Rules.” It is silent (but the Funding Rules are not!) on the position if more than the minimum is required. However, at 1.2.3 i, one of the employer’s responsibilities is “ensuring that the Apprenticeship… meets the requirements of the relevant Funding Rules”. This appears to catch the employer if more than the minimum is needed.