Memorandum 10
Submission from the Financial Services
Skills Council (FSSC)
DRAFT APPRENTICESHIPS
BILL
The Financial Services Skills Council (FSSC)
is an independent, employer-led organisation, established in 2004
to provide strategic leadership for education, training and skills
development for the financial services, accounting and finance
industries across the UK. The FSSC aims to improve productivity
and business performance by ensuring that the industry is equipped
with the range and level of skills that it needs.
We, the FSSC, welcome the publication of the
Draft Apprenticeships Bill for the future of Apprenticeships in
England "World-class Apprenticeships". The future of
competitive and productive financial services, accounting and
finance industries depends on providing employers and employees
with the skills they need. We have been successful in raising
the profile of apprenticeships in the financial services sector
and believe the prominence given to Apprenticeships by the Government
will support our work in this area.
1. Does the bill meet the Government's policy
objectives to set up a system of "world class" apprenticeships
in the most effective way within a reasonable time frame?
As previously mentioned in our response to "world
class apprenticeships" we would have concerns over the review
of the current apprenticeship blueprint and the proposals to include
personal learning and thinking skills and functional skills in
maths and English. Apprenticeship frameworks should be employer
led and these proposals may stop employers engaging in apprenticeships
because of qualifications they do not want. We have also had difficulties
in the past inserting a level 3 qualification in a level 2 framework
as requested by employers.
We are also not convinced by the proposals for
employers and providers to develop their own frameworks and believe
that this has the potential to conflict with the desire for consistency
in the standard of frameworks. We believe that a truly flexible
Blueprint would negate the need for frameworks to be developed
by a number of organisations and approved by the relevant SSC.
We are concerned of the proposals that the Secretary
of State can approve frameworks without further recourse to the
Sector Skills Council. We are concerned that this could dilute
the impact of Sector Skills Agreements and Sector Qualifications
Strategies, both of which should form the basis of future development
for a sector. As these are living documents, it is important for
SSCs to be aware of all initiatives linked to them and for that
awareness to remain current.
2. Is the bill workable?
3. Will the bill lead to a renaissance in
apprenticeships?
No, not unless employers across all sectors
are convinced of their benefits.
4. What is the cost?
5. What impact the bill will have on current
institutional structures?
6. Is there anything missing from the draft
bill?
As previously mentioned in our response to "world
class apprenticeships", we would like to propose that the
current 5 year cut off for key skills exemptions be waived. At
present, this arbitrary rule acts as a barrier for individuals
and employers enrolling onto Apprenticeships. We believe the prior
achievement of qualifications in communication and numeracy to
be acceptable evidence of mastery in these areas.
For those who do not hold prior qualifications,
we would like the provision of a portfolio of evidence to suffice
and for the key skills tests to become optional. Mastery of the
requirements is demonstrated adequately through a portfolio and
the insistence on a further test adds nothing. The success of
the model in Wales, where the key skills test requirement was
removed some years ago, illustrates that the portfolio is strong
enough to stand alone.
We support, in principle, the idea of new matching
services for employers and individuals. However, we must emphasise
the importance of field staff having excellent sector knowledge
in order to engage employers effectively. Our experience of skills
brokers working with financial services through Train to Gain
has been far from positive. A notable lack of sector knowledge
among skills brokers has had a detrimental effect on financial
services employers' willingness to engage with Train to Gain.
We are very keen that this experience not be repeated for Apprenticeships.
We would welcome the opportunity to be included in any national
or regional strategy to ensure synergy with the financial services
Sector Skills Agreement and Sector Qualifications Strategy.
We believe that the provision of high quality,
accurate information, advice and guidance will be key to the success
of Apprenticeships and all other learning programmes. Clarity
must be given to parents, schools and employers on matters such
as the benefits of Apprenticeships, how they sit alongside other
options such as Diplomas, how to select and begin an Apprenticeship
and what progression opportunities exist.
We feel strongly that the current Blueprint
is not flexible enough to respond to employers' needs. We faced
a concrete example of this barrier in 2006, when attempting to
include a Level 3 unit in a Level 2 apprenticeship. This was in
direct response to employer demand and followed a model that had
operated successful in a previous framework. However, this was
not accepted by the Apprenticeship Approvals Group as it did not
conform to the prescriptive requirements of the Blueprint.
We feel that there are insufficient employer
incentives to raise employer demand. Apprenticeships will need
to be made attractive to employers or the expansion will not happen.
September 2008
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