Training Qualifications UK is an Ofqual recognised Awarding Organisation and in the process of applying to become an End Point Assessment Organisation.
The comments below are in response to the Draft Strategic Guidance to the Institute for Apprenticeships Government Consultation issued on 4 January 2017.
Role of Assessment Experts
TQUK strongly feels that there is a need for the IFA to ensure the involvement of assessment expertise at all stages of standard and assessment plan development, delivery, and review. We absolutely support the involvement of employers and agree that it should be they who drive the content of the apprenticeship standards. There is a need, however, to draw a distinction between the content of the standard itself and the assessment plan which should produce valid, reliable and comparable evidence of achievement. Apprenticeships awarded on the achievement of a level of competence are only useful if that competence can be properly and reliably measured.
There are already examples of approved assessment plans that are poorly designed and make valid, reliable, comparable assessment of particular skills difficult or even impossible. As an Ofqual Awarding Organisation these concepts are the very core of what we do when we award regulated qualifications and it is essential that the same level of rigour is applied when assessing apprentices; especially in situations where a regulated qualification forms part of the apprenticeship.
The strategic guidance mentions several times the importance of employer inclusion. It is not enough to have assessment experts feeding into the process at various points: they must be properly represented at all levels. We note that the consultation reassures that the ‘majority’ of Institute board members are employers, however there is no mention of assessment expertise. We would encourage the DFE and the Institute to consider at least one position on the board being dedicated to an assessment expert to ensure an appropriate balance between plan content and deliverability of assessment plans for those plans.
In addition there is a need for similar representation on every Trailblazer Group to ensure consideration of assessment challenges at the very start of the process. It is unlikely that any group putting together a standard will do so without any consideration of what an assessment might look like. The assessment plan will begin to be shaped early on and it is important that this is done with input and advice on assessment.
We note that the review system for standards will ensure that they remain ’relevant and up to date’. We would encourage the addition of ‘deliverable’ to this remit. Currently there is no appeal process for EPAs to challenge aspects of an assessment plan. Whilst the inclusion of experts in assessment at the design stages would minimise the possibility of undeliverable plans, it is inevitable that the first deliverance of the plans will uncover areas for improvement. We should always be aiming for continuous improvement and it is important that there is a robust and effective mechanism in place to gather feedback not just at set review stages, but as and when assessments are happening to ensure that apprentices are being given the best possible opportunities to demonstrate competence and are not disadvantaged.
Advice Function – Advising on maximum level of government funding
It is right and proper that the Institute works closely with the SFA to ensure that public money is directed and spent appropriately. With its involvement in approving standards and assessment plans it will be in a unique position to provide the SFA with valuable information in real-time on how much delivery actually costs.
We would urge the Institute and the SFA to give particular consideration to the cost of assessment delivery as part of their discussions relating to maximum funding bands. Some of the current assessment plans are unavoidably expensive to deliver and leave little room for flex when constrained by the recommended 20% allocation of funding totals to assessment. The current system motivates providers to ‘drive a hard bargain’ and negotiate with EPAs for the lowest price possible. Whilst we should all be conscious of the economies involved when spending public money, this race for the cheapest option may price some EPAs out of the market entirely and encourage some to cut corners in order to deliver at the demanded price.
We would also urge consideration of some of the more hidden costs that will be incurred by EPAs, not only those directly related to the delivery of assessments. Tendering processes for contracts can be time-consuming and require a lot of resources. EQA costs per apprentice will be incurred and we are not yet clear whether resit costs are to be accommodated within that 20%. We do not yet have details on certification costs which need to be established as soon as possible in order to allow for accurate forecasting.
We foresee a potential issue with cash flow arising from the arrangement where providers are only able to claim the last 20% of funding per apprentice upon completion. This means that the costly process of assessment must be undertaken without access to that money and may cause issues for training providers which will be required to pay EPA costs before assessment commences. There is potential for this to be a barrier for providers who do not carry large cash reserves (typically smaller centres).
There is a need for the Institute to play a role in ensuring that large training providers do not become an apprenticeship brand and, along with that, the training providers chosen EPA. This is not to say that a large, successful provider should not be allowed its success, but that employers should not be blinkered to the range of choice available by the dominance of one particular company.
We have been watching with interest the publication of new standards. It is looking likely that the number of standards will outnumber the old frameworks and we would encourage proper consideration as to how many is too many. Some standards already published seem particularly granular and, we believe, run the risk of low take up because they have become so specific. In addition to this it is confusing to employers and potential apprentices.
Working closely with key partners is an essential function of the IFA. Clarity is needed over how the IFA will operate within, or work with, Northern Ireland and Wales and what arrangements will be made for learners achieving in one country and then working in another. It is important that their achievements are valued across borders.
We would very much welcome the Institute taking an active role in promoting correct practices across the organisations that it governs. We note that it has already made ‘efforts to discourage’ some undesirable behaviours but would like to see this taken further and the Institute to take steps to stop it.
Lastly, we hope that the Institute will work to educate the wider public about its work and encourage use of the correct registers. It cannot be expected that stakeholders will automatically know where to find information and there is much work to do if we are to ensure employers and apprentices have access to, and understand, all of the information that they need in order to make informed choices. Like Ofqual introducing a new GCSE grading system, the IFA needs to proactively engage and educate in order to ensure success of what is a big change to a long established system.