Select Committee on Innovation, Universities, Science and Skills Written Evidence

Memorandum 18

Submission from the Association of Colleges (AoC)



  AoC (the Association of Colleges) is the representative body for colleges of further education, including general FE colleges, sixth form colleges and specialist colleges in England, Wales (through our association with fforum) and Northern Ireland (through our association with ANIC). AoC was established in 1996 by the colleges themselves to provide a voice for further education at national and regional levels. Some 98% of the 415 plus general FE colleges, sixth form colleges and specialist colleges in the three countries are in membership. These colleges are the largest providers of post-16 general and vocational education and training in the UK. They serve over four million of the six million learners participating in post-statutory education and training, offering lifelong learning opportunities for school leavers and adults over a vast range of academic and vocational qualifications. Levels of study range from the basic skills needed to remedy disadvantage, through to professional qualifications and higher education degrees.

  The key role played by the sector and its 250,000 staff in raising the level of skills and competitiveness of the nation's workforce make colleges central to the Government's national and regional agenda for economic prosperity and social inclusion. AoC services to member college corporations include information, professional development and support in all aspects of institutional management, governance, curriculum development, quality, employment, business development and funding. AoC also works in close partnership with the government and all other key national and regional agencies to assist policy development, continuously to improve quality and to secure the best possible provision for post-16 education and training.




  World-class Apprenticeships: Unlocking Talent, Building Skills for All, published in January 2008, set out the Government's plans for the expansion and strengthening of the Apprenticeship Programme. The draft Bill establishes a statutory basis for the Apprenticeship programme and sets out the proposed legislation for consultation. We have initially outlined the principles which underpin our response, and then summarised the main provisions of the draft Bill which we have used to provide the structure of our response.


  The legislation:

    —  should facilitate the expansion of the Apprenticeships programme by allowing sufficient flexibility to allow innovative models of delivery to flourish;

    —  should ensure that apprenticeships are seen as a high quality choice for young people, for those in the workplace and for employers;

    —  should facilitate the development of models of good practice and not have unintended consequences that adversely affect (or prohibit) existing good practice;

    —  should facilitate ways in which colleges can work with employers;

    —  should reduce bureaucracy;

    —  should be fair and not penalise non achievement, where this is outside that apprentice's or that organisation's control;

    —  should facilitate links to the other elements of the 14-19 Curriculum Reforms to ensure apprenticeships for young people are seen as a viable and attractive pathway which does not "shut doors" on future educational opportunities; and

    —  should fully utilise the potential of QCF to offer specialisms, options and choice for apprentice and employer.


  Main points:

    —  This Bill will establish a statutory basis for the Apprenticeship programme.

    —  A duty is placed on the LSC to provide sufficient places for all suitably qualified young people 16-18 who want one (entitlement by 2013), in one of their two chosen apprenticeship sectors.

    —  The Secretary of State will approve the apprenticeship specification/blueprint.

    —  Sector Skills Councils, employers and others can submit apprenticeship frameworks for approval, in line with the specification.

    —  There will be a new certificate for framework completion.

    —  There will be a new Apprenticeship Agreement between each apprentice and their employer. This will form a "contract of service" and will set out details of on-the-job-training; the learning away from the workplace; the apprentice job role on completion; and the amount of supervision an apprentice will receive.

    —  Provision is made for the establishment of a National Apprenticeship Service which will provide a one-stop-shop for employers and potential apprentices. Initially the NAS will work under the auspices of the LSC, but ultimately it will have "end-to-end responsibility" for the apprenticeship programme.

    —  Provision is made for changes to the Education Act of 1997 in relation to IAG in schools, to ensure schools provide comprehensive information about apprenticeships.


A statutory basis for Apprenticeships

  1.  AoC welcomes the intention to raise the status of Apprenticeships so that they are seen as a third viable learning pathway at levels two and three alongside Diplomas and GCSE/A levels, as an option for young people who want good career prospects or progression to higher education. However, this Bill will establish a statutory basis for the Apprenticeship programme, and there is a danger that this may result in the imposition of too many restrictions when what is required is flexibility to engage employers and meet their diverse needs. We would wish to ensure that there is still sufficient flexibility to allow innovative models of delivery to flourish, and that there are no unintended consequences on current provision as a result of the legislation.

Employed status for Apprenticeships within a climate of economic slow-down

  2.  The legislation requires Apprentices to be employed and AoC is concerned that the ambitious targets of: 400,000 apprenticeship places by 2020 (Leitch Implementation Plan 2007); the aim of one in five young people to be undertaking an apprenticeship in the next decade; and an entitlement by 2013 (World Class Apprenticeships 2008), will not be met if demand from employers is not stimulated. Exact data is hard to obtain but we know that demand by young people for apprenticeships already exceeds the supply of employers offering apprenticeship places, and that this is particularly the case in some regions. It is also clear that the current economic downturn is likely to affect the willingness and ability of employers to offer apprenticeship places. This needs to be taken into account and alternative solutions explored: this might involve innovative college-led partnerships managing work-based training.

  3.  According to the Labour Force Survey (Federation of Small Businesses response to World Class Apprenticeships March 2008) 69% of apprenticeships are delivered in SMEs. The average SME employs only four people, with little time for off-the-job training and equally little time to devote to devising training programmes. AoC has concerns that many small employers have little confidence that SSCs understand their needs. This leads us to believe that there are several options for Government:

    —  Ensure the Bill does not put barriers in the way of providers working directly with employers, so that they can work with SMEs to develop apprenticeship frameworks to meet their needs.

    —  Ensure the Bill empowers providers to develop fit for purpose apprenticeships, for example to meet the needs of SMEs, taking into consideration the greater flexibilities to accredit apprenticeships in partnership with SSCs.

    —  Consider ways of incentivising SMEs to make it easier for them to release staff for essential apprenticeship training off-site that they cannot provide themselves because they are so small.

  4.  In addition, the effect of an apprentice being made redundant needs to be thought through, with every means being explored to provide an opportunity for them to complete their training. AoC welcomes the announcement by the Secretary of State to establish a "clearing house" to match apprentices in the building industry at risk of redundancy with other employer's vacancies, so that they can complete their qualifications. We would advocate that other occupational sectors could benefit from such a scheme in the current economic climate, and see a role for the National Apprenticeship Service here. However, since publication of the draft Bill and the subsequent severe economic downturn, colleges are telling us that this concern is becoming a reality and apprenticeships are indeed being made redundant in situations where there are no other employers willing or able to take them on. AoC wonders whether an innovative short term solution needs to be found for example, rather than transferring an apprentice onto an unemployment register, transfer them to a college to become a full-time student and complete the off-site elements of their apprenticeship programme (see paras 23 and 24).

  5.  Finally, we note that non-completion of training as a result of redundancy will impact negatively on the college or training provider's retention, completion and success rates. Whilst we naturally would wish every apprentice to complete, our argument is that in uncertain times there are many reasons, outside the control of either apprentice or provider, that might now impact on an apprentice's capacity to succeed. This is causing particular concern in relation to the LSC's Minimum Levels of Performance which are calculated differently for Apprenticeships than for other FE provision. For apprenticeships these are calculated on the basis of each framework and by each level. Numbers involved can be very small and losing even one or two trainees because of redundancy can have a significant and disproportionate impact on apprenticeship success rates. This poses a considerable risk to providers where aggregated results fall below MLPs. Where this occurs, the provision will be terminated and put out for open tendering causing de-stabilisation for the provider and disruption for the apprentices involved. We advocate that a means should be found to remove penalties from colleges and training providers for things which are out of their control. It will serve no purpose to de-stabilise the training supply side in an economic downturn; on the contrary, we believe that training provision needs to be strengthened to support re-skilling and up-skilling in an uncertain world.

Duty on the LSC to provide Apprenticeship entitlement

  6.  The legislation places a duty on the LSC to provide apprenticeship places for all those suitably qualified who want one and this will become an entitlement by 2013, but where demand outstrips the supply of employed places it is difficult to see how responsibility for this can rest with a funding and planning body. The situation is compounded by providing a potential apprentice with a choice of two areas and building an entitlement that the applicant will be placed on one of these. This implies that more places will need to be provided than may be taken up, which would result in under or over supply (if so many places could be found), and more turbulence created in the system. This is a further example of responsibility and duty being given to the "supply" side for something which is not within its control.

  7.  We believe that IAG and pre-course assessment will need to be thorough, taking full account of students' prior attainment and aptitude, to ensure that only those who have the ability to succeed are able to start an apprenticeship, and the that right of the provider to say no must be preserved. For those young people who need an opportunity to develop and improve their existing attainment, AoC advocates development of a new Access to Apprenticeship programme (see para 23 and 24 below).

  8.  AoC notes that duties are placed on the LSC in same Bill in which legislation is introduced to remove the LSC, and would welcome clarification as to who will fulfil this function in the future.

Sector Skills Councils (SSCs), employers and others to submit frameworks for approval

  9.  It will be necessary to stimulate demand from employers in existing and new occupational sectors if the ambitious Government targets for apprenticeships are to be met and AoC welcomes the provision in the Bill for SSCs, employers and others to submit frameworks for approval. We believe that there is a need for increased flexibility in framework design, along with a simplification of the process of validating new frameworks, to allow programmes to be developed which meet the needs of employers. We would anticipate that colleges will be able to work with employers to develop apprenticeships tailored to meet their needs with a strong degree of in-house training, and that they will be able to submit these for approval. This may be beneficial in attracting SMEs in particular to the Apprenticeship programme. AoC would like coherent development of such Apprenticeships. The AoC Skills Groups, working with the SSCs, could provide a vehicle for this on behalf of the sector.

  10.  AoC would hope that colleges which meet agreed standards will become awarding organisations allowing them to develop "bespoke" apprenticeships—in line with a Blueprint that allows for standardisation of the Apprenticeship brand, but sufficient flexibility for innovation—in conjunction with employers, which could then confer the same benefits to SMEs that larger employers will gain from being able to submit their own framework proposals.

  11.  AoC has suggested to QCA a coherent model in which AoC Skills Groups would apply to become Awarding Organisations, sector by sector and in close partnership with relevant SSCs as one possible option. The college itself would benefit, in being able to provide bespoke qualifications to the employers it serves, and others would similarly be able to accredit through the one college. We believe this will work well in niche and specialist markets where traditional awarding bodies may not see a big enough market.

  12.  Apprenticeship provision mainly consists of Apprentices (level 2) and Advanced Apprentices (level 3) and, although some Higher Apprenticeships do exist, there is minimal progression of Apprentices to higher level learning. AoC believes that elements that will facilitate progression to higher level skills need to be built into Apprenticeship programmes, and that as well as showing the UCAS tariff, Advanced Apprenticeship Frameworks should be required to demonstrate progression opportunities to higher study, either in the workplace or elsewhere.

Certificate for Framework completion

  13.  AoC believes that a certificate for framework completion may raise the credibility of apprenticeships—particularly if UCAS points are attached to Advanced Apprenticeship programmes. However, whilst having benefits for apprentices and apprenticeship programmes in general, we are concerned that non completion may adversely affect the success rates and funding. The apprenticeship is a complex qualification, often involving two or three separate organisations supporting the achievement of separate elements of the qualification. Currently, funding can be drawn down by each respective partner involved in delivering the apprenticeship qualification in a straightforward transaction. There would be extra bureaucracy, a significant time-lag, and the potential for unfair penalisation of organisations if, for any reason, the apprentice fails to complete and funding was changed so that it was only payable on full completion. As described above, completion may lie outside of their control.

  14.  AoC sees possible potential to include within the completion Certificate a Licence to Practice. Where these exist they have proved to be a good way of professionalizing a sector by ensuring minimum standards of performance. They add value to a sector, becoming recognised and sought after (ie Corgi Gas fitters), and are a proven way to stimulate the market, for example the massive growth of NVQs in the Care sector when these became a requirement to practice. In uncertain times this might offer a way forward in many more sectors in which there are good reasons (ie health and safety) why standards must be met. However, this needs careful consideration as there are potential risks to the labour market which would need to be assessed.

  15.  We believe that it should be possible for the system underpinning this not to be overly bureaucratic, nor to result in additional costs to apprentices or providers, and that it should have a short turnaround time for the issuing of certificates. We would anticipate that the extra volumes might offset any extra costs.

  16.  We note that the certificate will include only employer and apprentice details, and think that inclusion of the training provider may facilitate progression to higher levels of training and/or study.

Apprenticeship agreement

  17.  The legislation includes the requirement for an apprentice to have an Apprenticeship Agreement which will form a "contract of service" with the employer. There is some concern about the effect of this contract particularly on early termination, redundancy, employer liability and group approaches to apprenticeship delivery.

  18.  AoC believes that Group Training Organisations, which are working successfully in Australia and are now being developed by some colleges in the UK, offer an innovative method by which employers can host an apprentice without employing them directly. We hope that, under the terms of the Bill such schemes will be encouraged.

  19.  AoC welcomes the announcement of the increase in the level of apprenticeship pay from £80 to £95. We recognise that there is a tension between payment of the National Minimum Wage, as reasonable payment for a job of work, against the arguments that this will have a negative impact on the taking-on of apprentices by employers. However, the Federation of Small Businesses (FSB) report that their members support the payment of the National Minimum Wage for apprentices (FSB Apprenticeship survey 2008)

Apprenticeships in the Public Sector

  20.  World Class Apprentices makes a commitment to reducing the inconsistencies in the public sector's usage of apprenticeships and states that public sector targets for each component of the public sector and duties will be introduced. AoC notes that this is a non-traditional sector for apprenticeship provision and would see the need for the development of new frameworks at all levels. Evidence suggests that apprenticeships, where available in the public services, tend to be in business and support service areas (as AoC research below supports) which raises issues regarding progression from apprenticeships to professional qualifications and of the need for the development of higher level apprenticeship frameworks.

  21.  We believe that the development of new frameworks should be considered at two levels. The first is at the local level where colleges, acting as advocates of apprenticeships for young people and adults, can work with local public services such as health and Local Government to develop frameworks that meet their needs. The second is at a national level where we believe that the national workforce strategy for each of the public sector services needs to include processes for public service apprenticeship delivery; as well as processes for the development of these with the relevant SSC.

  22.  As the representative organisation for a publicly funded sector, AoC recently carried out some preliminary research to determine the number of apprentices currently employed in Colleges across England. Approximately 20% of general FE colleges were approached directly, and early indications are that these colleges employ on average five apprentices each, with over 60% employing at least one. The apprentices are employed almost exclusively in business support or administration roles. More anecdotal feedback suggests that there is potential for an expansion of apprentices employed by colleges if the profile of apprenticeships and the processes associated with them are better understood.

Proposal for a new preparation programme—A2A (Access to Apprenticeship)

  23.  The requirement for an apprentice to have an Apprenticeship Agreement with an employer which will form a "contract of service" appears to imply an end to the current Programme Led Apprenticeship programme. Whilst there may be a case for restricting the term "apprentice" to those with employed status, we would be concerned that the concept of Programme led is lost. In some industries where permanent contractual arrangements are limited such as the creative industries, or others where a level of skill is required from the start of employment as in the Care sector, and there are age restrictions, it is difficult to implement traditional apprenticeship programmes. Innovative solutions to this situation need to be explored to ensure that these potential future apprentices are not lost.

  24.  AoC believes there is an opportunity for a fresh look at the way in which young people can access the Apprenticeship programme. We strongly believe that many young people will need an opportunity to develop and improve existing attainment prior to becoming eligible for an apprenticeship. We would advocate therefore the development of a flexible, new Access to Apprenticeship programme (A2A) which would enable employers and further education colleges to properly prepare recruits with employability skills, functional skills and perhaps the technical certificate (or elements of a Diploma/other education routes) as a funded and recognised precursor to Apprenticeship training. We are aware that this new title does not accord with Government thinking which is to decouple the word "apprentice" from anything that is not employer led. However, we think that each learning route should be clearly signalled for young people, including for those with a commitment to apprenticeships, but who haven't got the minimum requirements, or employers willing to take them on at their current level of attainment.

  25.  If we look at the existing Programme-led Apprentices (PLA) Programme, we note that Ofsted sees significant value in this provision. The Ofsted Report on PLAs published in July 2008, found that PLAs are an important alternative to traditional employer-led apprenticeships, providing a path for young people who may find it difficult to gain employment, or for those who require an initial phase of upfront training before progressing onto an employer-led apprenticeship; that the majority of employers are positive about the impact of PLAs as learners were found to be better prepared for the workplace, more confident, had greater knowledge and skills and were able to complete the full apprenticeship framework in a shorter time. We believe any criticisms could be addressed in the new approach we are advocating.

National Apprenticeship Service

  26.  The National Apprenticeship Service aims to simplify the organisation and management of apprenticeships, and although it remains to be seen how this will work in practice we believe it should not be overly bureaucratic so that colleges and other providers are still able to respond quickly to employer requirements. It is intended to be the single point of contact with employers but we believe that the relationship between employer, provider and apprentice is often based on experience and reputation, and that colleges will not want to lose contact with their employers through the setting up of an intermediary. Apprenticeships are a key component of many colleges employer engagement strategy and thought needs to be given to maintaining the ongoing relationships between colleges and employers, whilst encouraging other employers into the system. The solution for Train to Gain was use of a brokerage system where this was needed, but allowed alternative routes where it was not.

  27.  We believe that the success of the service will depend to some extent upon its links with local and regional structures and providers; its understanding of regional variations in the nature of programmes, employer needs and types of provider; its understanding of the provider base in local areas; the establishment of transparent and adequate funding models; the ability to interface with Train to Gain; the promotion of the vacancy matching service to all learners, employers and providers; its capacity to support SMEs to engage with the vacancy matching service; and, its ability to reduce bureaucracy.

  28.  However, we believe that the NAS could provide an effective marketing and promotion programme for schools and employers and could be used to raise the profile of Apprenticeships which would be of benefit to all concerned.

Information, advice and guidance in schools

  29.  AoC welcomes moves to improve IAG in schools and to ensure impartiality, and believe that the legislation could go further to ensure that this is embedded in the careers education curriculum in schools and colleges. We believe that this will need to be backed up by a full CPD programme for staff in schools to ensure their understanding of apprenticeship programmes. However, it is unclear how this requirement will be monitored and enforced, and what the penalty will be for those who do not meet the requirements of the Act.

  30.  In addition, AoC believes that it is the curriculum itself that should be the vehicle to apprenticeships, and that IAG by itself will not achieve this. We would anticipate that, as the 14-19 Qualifications Strategy is embedded in schools and across consortia, and as young people studying Diplomas move more freely between institutions there will be a breaking down of traditional routes and more opportunities for young people to discover alternative routes including apprenticeships, hopefully coming directly into contact with young people who have chosen this route. Advocates are needed for apprentices.

Progression into and from apprenticeships—integrating apprenticeships into the other aspects of the 14-19 Curriculum and to higher level study

  31.  AoC supports the Government's aim to develop a coherent curriculum model 14-19, a single framework of which Apprenticeships are part, and believes this is essential to the success of plans to raise the participation age. However, we believe that much clearer links and progression pathways need to be made between the different routes in the 14-19 Strategy, namely Apprenticeships, Diplomas and GCSE/A levels. We believe that work needs to be done to map each route respectively to ensure each meets the requirements of the other, to facilitate progression between them. We believe that the requirements of the draft new Blueprint are appropriate and have the potential to link well to the different learning routes within the new curriculum, including the Foundation learning Tier and to HE.

  We believe that each Diploma Line of Learning should be mapped to the knowledge based element of the Blueprint (represented by the technical certificates of the current apprentice frameworks), to facilitate progression into apprenticeships from Diplomas without the need for learners to repeat learning.

  32.  We are aware that the Foundation Learning Tier Progression Pathway to Employment is designed to replace the current Entry to Employment programme. However, we remain concerned that progression from this programme into an apprenticeship will be too big a jump for these learners who need considerable support, and are concerned that there is likely to be early drop out if young people progress to an apprenticeship programme and then can't do it. We see progression to A2A as a means of providing these learners with a stepping stone to a full apprenticeship programme.

19+ year olds

  33.  We note that the legislation relates to 16-18 year olds, and wish to see provision made for those over 19 to also receive public funding for apprenticeships programmes as suggested in World Class Apprenticeships.

  34.  Just as there is a need for a bridge from level one to level two for those 16-18 year olds, so there is a need for this for those over 19 and AoC would advocate the development of the Access to Apprenticeships model for those over 19 year olds, and would see this flexible programme as meeting the needs of those out of work and now subject to new requirements by DWP to undertake training to improve their prospects of gaining long-term employment.

  35.  In advocating the expansion of publicly funded apprenticeships to those over 19, which is suggested in World Class Apprenticeships and supported in the Grant letter to the LSC (2008-09) and by the Federation of Small Businesses (FSB), AoC would wish to highlight that attention needs to be paid to the marketing and pricing of Train to Gain to ensure that a preferential market is not created.

Models of Apprenticeship Delivery

  36.  AoC has gathered examples of apprenticeship delivery in colleges which is being complied into a pack of case studies and which will be available on request.

September 2008

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