FAB Response to the consultation on the review of apprenticeships

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1 FAB Response to the consultation on the review of apprenticeships April 2014 Overview The Federation of Awarding Bodies (FAB) is the membership organisation for vocational awarding bodies and we currently have over 115 awarding bodies in membership ranging from generic awarding bodies to small sector specific organisations. We also have more than thirty professional bodies in membership. Many of our members award qualifications that form part of apprenticeship frameworks and are committed to the quality and rigour of apprenticeships and to the continuance of the opportunities that apprenticeships can offer to a range of learners. The Federation therefore welcomes the opportunity to respond to the Review of Apprenticeships Consultation. The Federation wishes to make the following submission for your consideration. This response is submitted on behalf of the FAB membership following consultation with them and with the Federation s Board of Directors. Awarding bodies are a diverse community and our members may wish to make their own individual submissions containing their own particular perspectives and emphases, in addition to any comments forwarded to FAB for inclusion in this overall response. The Federation s response has been produced to address the questions within the consultation that we feel are of particular relevance to our members; we have not offered our views on all areas questioned in the consultation but would be happy to discuss any of these areas if it would be useful. Consultation response Theme 1 (Part A): The Components of An Apprenticeship Question 2: Should apprenticeships be for a new employee or, in the case of an existing employee, a new job role? The Federation believes that apprenticeships should be available to all learners where there is the opportunity for a substantial amount of learning and skills development to take place. We understand the need to ensure that existing experienced and qualified staff are not put onto apprenticeship schemes to 'make up the numbers' or maximise access to funding but we would want to avoid cases where existing employees who would genuinely benefit from the opportunity to significantly expand their skills and knowledge are barred from accessing apprenticeships. An apprenticeship may be just as relevant and valuable to an existing employee where it offers the opportunity to expand the breadth and depth of skills and knowledge required for a job role or where the job role has changed significantly e.g. as a result of new technology.

2 The Federation believes that it is important for an apprenticeship to provide the opportunity for the development and practice of substantial new skills. By the time an apprentice completes an apprenticeship they should have skills and knowledge that are significantly enhanced compared to those with which they entered the programme. It is important for Northern Ireland that apprenticeships make a significant contribution to the development of a highly skilled workforce that can perform to high standards in an increasingly competitive global market. Question 3: Do you agree that the apprenticeship system should commence at Level 3, and above? The Federation believes that there are sectors where it may be appropriate for apprenticeships to begin at level 2 and that flexibility should be maintained within the approach to apprenticeships to ensure they can respond to the needs of the employers in each individual sector. The Federation believes that it is important to allow flexibility to ensure apprenticeships meet the needs of a specific sector. A one-size fits all approach is not appropriate. In sectors where apprenticeships are not available at level 2 we believe there should be support provided for those learners who are not yet ready to enter a learning programme at level 3 to enable them to develop to a point where they can access the opportunities that apprenticeships offer. The Federation further believes that apprenticeships to level 8 need to be developed in close consultation with the specific sectors to ensure there really is the demand at these higher levels. The apprenticeship brand is understood and respected by parents, employers and sector bodies; therefore consideration needs to be given to the potential quantitative consequences of offering only a Level 3 apprenticeship option. Historical evidence suggests that Level 2 is the most feasible entry point for school leavers in particular and the aim should be for most to progress to Level 3. By essentially restricting entry to Level 3, the outcome will be fewer starts and the brand may be weakened as a result. Question 4: Do you agree that the minimum duration for apprenticeships should be two years? The Federation agrees that apprenticeships should be of a length that ensures there is sufficient time for the apprentice to develop the skills and knowledge they require to perform the relevant job role to the required standard. Whether this can be achieved in one, two or three years will vary from sector to sector and employers are best placed to advise on the minimum duration required. Two years does not sound unreasonable, particularly at level 3, but flexibility should be provided where employers can make a credible and well-evidenced case for a shorter minimum duration. The application of blanket rules to something as necessarily varied as apprenticeships will undoubtedly cause difficulties in some sectors and the Federation would support the availability of an exceptions process as a means to providing some access to flexibility in this matter. The Federation also believes that simply stating the required apprenticeship duration will not ensure quality. The content of the apprenticeship will be of greater importance i.e. it would be better all round to have an apprenticeship that lasted for 18 months, if those 18 months are full of learning opportunities, skills acquisition and practise and the acquisition and application of knowledge. Simply adding another 6 months to the time requirement will not necessarily add

3 any value to the apprenticeship. A 12 month minimum may be more relevant but we do not believe a 24 month minimum is in the best interests of learners or their employers. Question 5: Should apprenticeships involve a breadth of training beyond the job role? Apprenticeships are about work and the apprentices ability to function effectively in a job role in the workplace. It is therefore important that an apprenticeship extends beyond just the skills and knowledge required to operate in a specific job role and supports the apprentice to develop their generic skills and knowledge in areas such as team working, communication, innovation etc. as relevant to the sector they are in. Question 6: Should apprenticeships facilitate progression into professional or technical training or onto a higher academic pathway? How can the outcome of apprenticeships support this? The Federation believes that the progression aspects of apprenticeships should be considered during the development of the apprenticeship content. We believe that a choice of progression routes is desirable and where these include routes into professional or technical training or into HE this is a positive feature. It will be important to engage with Professional Bodies in the development phase to ensure that apprenticeships can effectively provide progression into their professional training and development offers. Theme 1 (Part B): Underpinning Elements of Apprenticeships Question 8: Do you agree that there should be a single award/qualification to denote the outcome of an apprenticeship for each occupation at each level? The Federation does not believe that one size will fit all industry sectors this area of apprenticeships. There may be some sectors /job roles where it would be appropriate to have more than one qualification. This may be because of the nature of the job role or some aspect of practice in the industry e.g. the requirement to have a food hygiene qualification as a basic licence to practice as well as (an) other qualification(s). Equally, in longer apprenticeships, having only one qualification will not provide the opportunity for apprentices to have their achievement recognised along the way or provide a route to achievement for those who have to leave the apprenticeship part way through. In aiming for consistency in apprenticeships, the Federation believes that this can be achieved by having an agreed standard for each apprenticeship. This is not the same as having a single qualification/award. The common industrial standard, which the Federation believes should not be developed at too detailed a level, can be used to specify the skills and knowledge that the apprentice will need to develop over the course of their apprenticeship. Having one consistent standard could aid the clear communication of what an apprenticeship is and what it is intended to deliver and help employers and other stakeholders to more easily understand what apprentices should know and be able to do once they have completed their apprenticeship in a given sector. It may also help to ensure that apprentices are clear about what skills and knowledge they can reasonably expect to develop during their apprenticeship. The common standard should be made available to be the basis of a range of qualifications/awards for a job role. This will ensure that there is a choice available to

4 employers who can select the qualification, provider and awarding body that best suits their needs. Having some competition in the market may help to drive innovation in qualification design and delivery. In some sectors there may well be one leading qualification that the majority of employers generally seek for a specific job role. Where this is the case then the sector should be able to decide to have this one qualification as a key part of the apprenticeship (assuming it meets the required standard). However, where this is the case the Federation would see it as being essential that this one qualification can be awarded by a number of different awarding bodies. This is already a commonplace approach within the market. Where there are a number of awarding bodies offering the same qualification they compete and innovate in other areas of their service offer e.g. support materials, customer service etc. and this competition delivers significant benefits to the marketplace. In a number of sectors there will be a range of qualifications that employers know and respect and where the sector decides that there is value to be gained from continuing to have access to a range of qualifications (which meet the standard) then the Federation can see no benefit to artificially restricting the market to one qualification. This would seem to be in direct conflict with the drive towards ensuring apprenticeships deliver what employers need. Having a range of qualifications and competition in the market will help to drive the development of innovative new qualifications that ensure the apprenticeships keep up to date with employer needs, technological advances and improvements in qualification design and assessment methods. The Federation believes that competition in the qualifications market, as in other markets, drives innovation and contributes towards ensuring that awarding bodies continue to strive to provide qualifications that fully meet the needs of employers and learners. Without competition there is a real risk that innovation in qualification design will be stifled in the future. Making only one qualification available for each occupation at each level will also limit the potential for apprenticeships to be fully responsive to the wide range of employer needs. Where there is diversity amongst the employers in a sector it is more likely that the provision of a range of qualifications (which all meet an agreed standard) will ensure that employers can identify a qualification offer that closely meets their specific needs. Question 9: Should apprenticeships be available for all ages? If apprenticeships are open to all ages, how can Government best ensure that young people are not crowded out of apprenticeship provision? To succeed, apprenticeships need to offer employers an effective means to develop the skills and knowledge in the workforce that they need to compete and succeed in their specific markets. Removing any barriers to employers being able to develop the workforce they need for the future is more likely to encourage employers to embrace apprenticeships and embed them in their skills development strategies. The Federation believes that apprenticeships offer a valuable route to the acquisition of skills and knowledge, irrespective of age, and older learners should not be barred from accessing apprenticeships where they could benefit from the acquisition of significant new skills and knowledge. Many older workers change career after many years in the workforce, either through choice or necessity, and apprenticeships can offer a valuable route to training and development in new occupational areas. Older workers are a valuable resource pool for employers and can bring a range of skills and prior experience that can add value to an

5 employment situation. Making apprenticeships available to all ages also supports the aims of the Skills Strategy for Northern Ireland which aims to raise the level of skill of the whole workforce. The Federation does not believe that allowing older workers to access apprenticeships will necessarily lead to a wholesale shift of opportunities away from young people. If the Government has evidence to believe that this shift is a real risk they could introduce a number of incentives to encourage employers to take on young people such as enhanced funding for younger age groups. Consideration should also be given to how to promote apprenticeships as a valid progression route for young people so they and their parents appreciate the opportunities that apprenticeships offer and seek them out. Question 21: Do you agree that the Careers Service should promote the benefits of the apprenticeship pathway to young people and their parents, as appropriate, highlighting the parity of esteem with other pathways such as higher education? The Federation believes that the information, advice and guidance that young people receive about the opportunities that are available to them are in many cases skewed towards HE options and do not provide young people with the full range of information required to make a fully informed and balanced choice. The Federation believes the most effective ways of informing young people and their parents about the opportunities provided by apprenticeships are: 1. by ensuring that any careers guidance activity that takes place in schools is balanced and includes information on apprenticeships as well as other more traditional progression routes. Raising awareness of apprenticeships as a valid and worthwhile option for young people needs to begin early in their school life to ensure they know all of the options that are available to them and are able to select subjects and routes through school that best support their progression into their chosen area. Ensuring that there is balanced careers advice available, either delivered by well-trained advisors or through IT solutions that offer access to a wide range of information is an important element in informing young people. Information on apprenticeships should be made available to all young people including those who are viewed as academic high-fliers who may choose to take an apprenticeship route as a valid alternative to university. 2. by providing young people with the opportunity to experience vocational education and training in schools from an early age so that they are better placed to make decisions on the types of learning and qualifications that best suit them and more likely to actively investigate apprenticeships as a progression route. The Federation believes that the inclusion of vocational qualifications of varied types and sizes in the curriculum provides young people with useful exposure to the style of teaching and learning that could make it more likely that they consider vocational routes including apprenticeships. 3. by promoting events that showcase and celebrate skills such as World Skills and the Skills Show. These can be an effective way of illustrating to young people and their parents the level of skill and expertise that it is possible to aspire to in a range of areas. 4. by using apprentices or those who have recently completed an apprenticeship in advertising and promotional activity to illustrate the benefits of apprenticeships.

6 5. by using local employers in advertising to demonstrate the career opportunities that an apprenticeship can open up for a young person. Promoting the involvement of large, well known employers in apprenticeships is important but it is equally as important to advertise that smaller local employers believe in apprenticeships and invest in them too. This can help young people and their parents to see that apprenticeships are a viable option for them in their part of the country and that the opportunities exist in all regions, not just in areas where large, high profile brand companies operate. Theme 3: Partnership - the roles of the key players Question 24 (b): Please comment on which stakeholders should be involved in the advisory group? If an advisory group is established the Federation feels it is important that awarding bodies are represented as well as employers, apprentices, training providers, and careers services. Such a group has the potential to provide a useful opportunity for all stakeholders to discuss/advise on a range of relevant issues. We note that there is little, if any, reference to awarding bodies in the Review of Apprenticeships interim report and wish to emphasise the expertise that awarding bodies can offer in relation, not only to qualification design and awarding, but to assessment of skills and knowledge whether this be throughout an apprenticeship or at the end point. Question 25 (b): Please comment on which stakeholders should be involved in the sectoral groups? If sectoral group is established the Federation feels it is important that awarding bodies are represented. Theme 4: Ensuring Quality Question 26: Do you agree with the following as indicators of the apprenticeship programme s success: quality, achievement and progression? The Federation agrees that quality, achievement and progression are broad indicators of the success of apprenticeships. However, these terms are very broad and are open to interpretation, especially quality. It is not clear what would be used to indicate quality is it employer feedback on the abilities of apprenticeships from a particular apprenticeship, is it pass rate of the end point assessment, or is it employment rate after 6-12 months of the apprenticeship completion? To be a useful indicator it must be clearly defined. Similarly, achievement and progression need some clear definition is it achievement of the whole apprenticeship, of key areas of learning within the apprenticeship of particular component parts? Is progression to mean progression to a job role in the sector or HE provision related to that area or will any job/he outcome be classed as a success? Clarity of the indicators is essential.

7 Question 28: Do you agree that apprenticeships should be subject to rigorous assurance? How should the content, duration and assessment of each apprenticeship be monitored to ensure it meets the needs of the key stakeholders? the level of monitoring that would be required are not presented in the consultation document and so it is not possible to comment on whether this is feasible or not. The Federation would like to emphasise the expertise that awarding bodies have in monitoring the quality of assessment and the value of the role they can play in any future plans for apprenticeships. Question 29: Do you agree that quality of teaching and learning should be supported through minimum qualification and related pedagogy requirements for each occupational area? the level of minimum qualification that would be required are not presented in the consultation document and so it is not possible to comment on whether this is feasible or not. Question 30: Do you agree that those involved in the delivery of off-the-job training should undertake professional training in pedagogy? the level of professional training that would be required are not presented in the consultation document and so it is not possible to comment on whether this is feasible or not. Question 31: Do you agree that stringent conditions should be established for continuous professional development to ensure that those delivering training remain expert in their field? the level of CPD that would be required are not presented in the consultation document and so it is not possible to comment on whether this is feasible or not. For instance, we would want to know that assessment approaches/ methodology are included in the professional training. Contact details Contact can be made by: telephone: