Memorandum 3
Submission from the Association of Learning
Providers (ALP)
A. INTRODUCTION
The Association of Learning Providers (ALP)
represents the interests of a range of organisations delivering
State-funded vocational learning. The majority of our 450 member
organisations are independent providers holding contracts with
the Learning and Skills Council (LSC), and Department of Work
and Pensions (DWP), for the provision of a wide-range of work-based
and work-related learning. Amongst our members we also have a
number of consultants, regional networks, and around 60 Colleges
of FE in membership, alongside nearly 50 charities, giving ALP
a well rounded and comprehensive perspective and insight on matters
relating to its remit.
With regard to Apprenticeship provision, our
members deliver the majority of Apprenticeships in England, probably
in the order of 75%. We believe therefore that we are in an excellent
position to pass comment on aspects of this current inquiry, and
we are pleased that our Chairman has been invited to give oral
evidence to the committee.
B. SUMMARY
— It should be recognised that, as
demonstrated by the most recent completion figures (64%), Apprenticeships
can be regarded as a "world class" programme. (Paragraph
1.)
— ALP is content with most aspects
of the Bill, but greater involvement of providers, especially
but not only in framework development, is essential and the Bill
should make this involvement a requirement. (Paragraph 2.)
— ALP has severe doubts as to the feasibility
of putting into practice any requirement on the LSC to secure
the availability of Apprenticeship places. (Paragraph 5.)
— ALP supports the description of Apprentices
as an employed programme. (Paragraph 6.)
— Whilst National Apprenticeships Vacancy
Matching Service (NAVMS) will be a useful tool it alone will not
result in the increased employer engagement needed. (Paragraph
7.)
— ALP wholeheartedly supports the need
for proper information, advice and guidance on all options for
all young people but it is not clear if the Bill goes far enough
to ensure this. (Paragraph 8.)
C. SUBMISSION
1. Recent developments have already seen
a dramatic rise in both the number of young people opting for
this route and the quality of Apprenticeships, as demonstrated
by the completion rate—now at 64%, a truly world class achievement.
We must not become complacent, however, and ALP welcomes the introduction
of this Bill, seeing it as a positive move for Apprenticeships.
That said, we do have some concerns and/or questions about some
aspects which are set out below.
2. We are satisfied that the proposals relating
to the issue of certificates seem reasonable but we do have some
concerns about the process for approving the core elements of
Apprenticeship frameworks. We fully support the concept of employers
and Sector Skills Councils (SSCs) submitting draft frameworks
to the Secretary of State or authorised person. We believe, though,
the process for identifying and approving the frameworks must
involve a range of interested stakeholders, which must include
the training providers that would be required to deliver them.
Without their involvement there is a very real danger of frameworks
being approved that are in fact undeliverable. For this reason,
too, whilst we welcome the requirement (in clause 11) for the
LSC to consult during its preparation of a draft specification
of Apprenticeship standards for the Secretary of State, it should
stipulate that providers in particular must be consulted. The
current requirement to `consult such persons as appear to it appropriate'
is totally inadequate.
3. The draft implies that frameworks will
be issued for a maximum of five years, but it does not indicate
what will happen at the end of the framework issue period. Will
every framework have to be resubmitted, re-approved and reissued,
or will there be a mechanism to allow frameworks that are still
appropriate and effective to continue to be used with a minimum
of bureaucracy?
4. We hope that the clarification of the
status of the Apprenticeship agreement will clarify the status
of Apprenticeships in law as there have been a number of cases
where the contractual status of an apprentice has been questioned.
5. Whilst welcoming the intentions behind
the Bill, we do have some doubts if some aspects, notably the
duty on the LSC to secure the availability of Apprenticeship places
for all eligible persons who have elected for the scheme, can
be delivered. It is not widely recognised that the vast majority
of Apprentices take on an Apprenticeship after they have started
work with their employer. Very few employers, apart from a few
of the large `Blue Chip' companies set out to recruit Apprentices.
Whilst in the longer term the plans to raise the age of participation
will undoubtedly have a positive effect on this situation, for
the next few years, any substantial growth in Apprenticeship numbers
will need to come from training providers using their strong links
with local employers to persuade them to put the young person
they have taken on onto an Apprenticeship. Until this is recognised
and measures introduced to enable training providers to maximise
their expertise in this area any growth in Apprenticeships will
fall far below what might actually be achieved.
6. We wholeheartedly support the definition
of Apprenticeship, which makes it clear it requires "employment".
We have always argued against the use of the term "Programme
Led Apprenticeships" to describe what are in fact simply
college based "Programme Led Pathways" offering the
young person a programme of learning that could lead them into
an Apprenticeship proper further down the line. We do of course
recognise that there are a few instances where the young person
is legally unable to be employed as an Apprentice (eg Care, where
there are age restrictions that prevent this) and in those specific
cases we do therefore support the definition of these unemployed
but "work based" learners as Apprentices
7. From the start ALP has supported the
concept of the National Vacancy Matching Service (NAVMS), feeling
it will play a useful role in matching potential Apprentices with
appropriate employers, but we do not believe it to be the sole
answer to increasing employer engagement in the way needed to
grow the programme in line with government targets, or indeed
the most significant element. That will only be achieved by making
better use of the training providers and their very experienced
sales teams, and by taking off the restrictions to growth of Apprenticeship
numbers imposed by the current LSC contracting system.
8. ALP has consistently argued the need
for universal, impartial information, advice and guidance (IAG)
for all young people on all the options and routes open to them,
including Apprenticeships. We have argued that the decision to
place the responsibility for IAG with local authorities and children's
trusts was a backward step and hope that the proposed changes
to the Education Act 1997 will go some way to address our concerns.
It is not completely clear from the draft, however, exactly what
the requirement is, ie if the requirement is just to consider
whether the young person needs to be told about Apprenticeships
or not. If that were the case some young people might still not
be told of the option, and we believe that would be wrong. All
young people must be given information on all the options available
to them. Given ALP's wholehearted support for the need to ensure
that all young people in schools are fully informed about the
high quality vocational opportunities open to them, as recognised
in this Bill, we would argue that this must be tackled by changes
to primary legislation as proposed, rather than through other
mechanisms such as statutory guidance. That would be much weaker
in practice and easily ignored, whereas a legal right can be acted
upon within the legal system by any student (or even provider).
September 2008
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