Unfair: Large apprenticeship providers ‘disproportionately penalised’ by new ESFA rule

Agency to penalise providers for more than 100 withdrawals or delayed completions

Agency to penalise providers for more than 100 withdrawals or delayed completions

Large apprenticeship providers have hit out at a “nonsensical” funding rule that proposes to punish their firms if they have more than 100 withdrawals or delayed completions.

A new apprenticeship accountability framework, mooted in last year’s skills for jobs white paper, was published for 2021/22 and sets out the quality indicators that providers will be measured against when it comes to intervention, from April.

Controversially, it states that providers will be placed in a ‘needs improvement’ category and become subject to “enhanced monitoring” when the number of apprentices in a cohort are past their planned end-dates, on breaks in learning or have withdrawn is more than 15 per cent or “greater than 100”.

A clarification version of the framework released last month showed that enhanced monitoring could include management conversations with government officials, the development of “improvement plans” and potential referrals to Ofsted.

Providers have accused the ESFA of launching an attack on large apprenticeship firms as they will be “disproportionately penalised” under the “greater than 100” threshold.

“There are many holes in the framework and lots of unknowns but the initial comms seems nonsensical and will more than likely put the majority of apprenticeship providers into ‘need improvement’ category,” said Brenda McLeish, chief executive of the Learning Curve Group.

She gave the example of a provider with 2,500 apprentices that could have a withdrawal rate of only four per cent yet still be subject to enhanced monitoring.

Nichola Hay, chief operating officer of Estio Training, said the policy has “good intentions” but its implementation is “wrong”.

“It is not a fair rule,” she told FE Week. “From sector to sector there are different impacts for breaks in learning, for example, especially following the pandemic.”

Sector leaders estimate that around half of the almost 1,500 apprenticeship providers in England are medium to large in size and typically have more than 100 withdrawals each year.

Sharron Robbie, managing director of the Devon and Cornwall Provider Network, questioned where the government’s resource would come from to adequately monitor all those providers in scope.

Sharron Robbie

She added that while she is supportive of ESFA action to tackle poor-quality apprenticeships, using a “blunt figure” of greater than 100 for all providers was “disproportionate”.

The accountability framework states that from April 2022, the ESFA will use the indicators and thresholds as the starting point for informing where there may be areas of concern.

The ESFA told FE Week that the agency does recognise the greater than 100 threshold will “capture” larger providers.

In defence of the rule, the agency said that while 100 apprentices may for some providers still represent a small percentage, in volume terms this is “still potentially high numbers of apprentices where we would want to seek further information and assurance”.

For those providers showing a significant or highest risk of poor-quality apprenticeship delivery the agency will consider whether suspending apprentice recruitment until improvements are seen.

The accountability framework added that each intervention will be “based on evidence and appropriate to the level of risk to the quality of apprenticeship delivery”.

Jane Hickie, chief executive of the Association of Employment and Learning Providers, said her members are “extremely concerned” by the proposals. “We strongly support ensuring that more learners complete their apprenticeship, but as the agency well knows, there are often factors for non-completion that are out of the provider’s control, particularly in certain sectors,” she added.

Providers can email feedback on the proposals to provider.strategy@education.gov.uk until March 1.

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  1. Just saying

    15% including withdrawal numbers rightly or wrongly, is so far from the starting point where average achievement rates for Apprenticeships reported in recent years are three times this figure. At best this is an aspirational target surely not one that will be required immediately to be hit. Are government advisors and civil servants really this ignorant? Maybe this indicates a new category of learner is to be introduced which wont be included in the number i.e. “did not complete” rather than “withdrawn” !

  2. Ed in Hands

    It’s poorly thought through, most likely by someone who has never worked in the actual delivery of provision.

    The fact that the document is still labelled as ‘minimum standards 14/15’ demonstrates the attention to detail that has been put into this.

    Using a one size fits all approach drives dodgy behaviour and gamification – the last incarnation of minimum standards and timely achievement failed to grasp that the longer the duration, the more time there is for something to go wrong and that a 10% overshoot on planned end date is different for a 16 month apprenticeship than on a 48 month one!

    This is the same, a fixed number of 100 withdrawals – You could have a stratospheric achievement rate of 90%. But if your cohort was 1010, you could have 101 withdrawals and be deemed as ‘NEEDS IMPROVEMENT’

  3. Phil Hatton

    Over the years many of the problems of poor apprenticeship provision (TECs, LSC and several other encounters to the now ESFA) have been down to the quality of those monitoring and making rules in the funding bodies. Can someone with common sense look at this and ensure that a provider with thousands of apprentices is not unfairly targeted? Seriously, who came up with this absurd measure? If they believe it makes sense please come on these pages and defend it. When it comes to it the single most effective measure is having staff at ESFA who understand apprenticeships linking to individual providers so that they can ensure the best providers are encouraged to have the most apprenticeships and vice versa.

    • Completely agree. Absurd.

      Some years ago when functional skills level 2 national rates were in the low 50%s, any provider who had a significant volume was almost certainly in line for a notice to improve due to falling foul of minimum standards – even if they were 10% above the national average!

      This resulted in providers pulling out of that level. Some did it for a year to ‘reset’, some for longer and some have never reinstated. Others came up with ‘creative’ curriculum designs to mask it, but it drove behaviour. Then, when poor decisions like this permeate down through a workforce, it tends not to result in positive outcomes!

      Personally, I think leaders at providers should have stood their ground to defend the interests of their learners, so they are just as culpable for allowing absurd rules to become established.

      Perhaps you could argue that minimum standards caused the national average to rise over time, but you don’t have to look too hard at participation rates to conclude that cherry picking learners and the creative use of non regulated provision are what really lies beneath. That, in turn, generates the mistrust that exists between ESFA and providers and sadly leads to more absurd counter measures!

      I’d like to be able to say that quality issues should be left to Ofsted…