The apprenticeships ladder of opportunity: quality not quantity Contents

2Quality

Administration

Capacity

6.We heard that several bodies responsible for apprenticeship quality may not have sufficient capacity to fulfil their responsibilities.18 Funding for Ofsted and the Education and Skills Funding Agency (ESFA) has been cut significantly in recent years, despite rising numbers of apprentices and training providers.19 The Institute was not able to devote resources to improving its processes until months after its launch.20 The Government has begun to remedy some of these issues: in May 2018 it promised Ofsted significant additional resources following months of discussion.21 We welcome this step, but given the Government’s doubling of apprenticeship funding, it seems strange that such concerns have been allowed to grow and endure: our predecessors expressed similar worries last year.22

7.We recommend that the Government continues to carefully monitor whether bodies responsible for apprenticeship quality have enough resources to fulfil their roles and acts quickly to remedy any emerging capacity issues.

Accountability

8.Responsibility for apprenticeship quality is shared between more than half a dozen bodies, with the Department for Education (the Department) holding overall responsibility and the Institute taking a leadership role.23 Several witnesses criticised the complexity of this system: the Chartered Management Institute described dealing with it as “immensely time consuming”.24 Andrée Deane-Barron, from the charity Central YMCA, warned that “there is some room there for quality to fall down some cracks or to not be consistent or transparent across sectors and across the country”.25

9.We found the apparent overlap in roles between the ESFA and Ofsted particularly worrying. To offer levy-funded training, providers must join an ESFA-managed register, which assesses “due diligence, capability, quality and financial health”.26 Since the register opened, the number of approved providers has tripled: many of them have no record of delivering apprenticeship training.27 Ofsted has begun a limited programme of short monitoring visits for these new providers: it says initial results have been “concerning”.28 The ESFA’s initial approach was to ignore Ofsted’s findings and make its own judgement whether a provider Ofsted had found “not fit for purpose” was worthy of receiving public money and training apprentices.29

10.The Minister agreed with us that the relationship between the ESFA and Ofsted needed to be defined more clearly.30 Following the session, it was reported that new providers judged by Ofsted to be making insufficient progress could be removed from the register in future.31 In August 2018, the ESFA issued new guidance.32 This stated that new providers making insufficient progress would not be able to “start any new apprentices” and such providers must inform the employers of existing apprentices of the judgement. However, such providers will remain on the register and the ESFA can ignore Ofsted in exceptional circumstances. While we welcome this greater clarity, we do not think it goes far enough. A provider whose only mark of distinction is a failing grade from Ofsted has no business providing government-funded training.

11.We recommend that new providers judged by Ofsted to be making insufficient progress should be removed from the register of apprenticeship training providers.

12.Levy-paying employers, and non-levy-paying employers from April 2020, purchase their apprentices’ training directly through a digital service.33 This is intended to drive up quality.34 They are asked to choose between a pool of providers that has grown significantly, yet many have received little if any attention from Ofsted, the body with real expertise in judging the quality of training. The existence of a register which currently offers little guarantee of quality only serves to confuse and alienate some businesses.35

13.The ESFA is conducting a review of the register, working on integrating “more frequent learner and employer feedback” into the digital service and it has reportedly expanded its internal audit team.36 We welcome these steps, but they cannot take the place of proper inspection. Nick Linford, editor of the trade newspaper FE Week, called for a cap to be placed on the amount of training a new provider can offer before they have proved their competence.37 We agree. This cap should be in place until a new provider has received at least a monitoring visit from Ofsted and been found to be making sufficient progress. The Government should consult with stakeholders on the level at which the cap should be set.

14.We recommend that the Government places a cap on the amount of training new providers can offer. This cap should remain in place until they have been found to be making sufficient progress by Ofsted.

15.More broadly, we think the ESFA’s review of the register is an opportunity to limit the number of approved providers. It is absurd to create a system so bloated that it cannot be properly regulated.38 While Ofsted’s increased funding should provide additional capacity, it cannot possibly inspect two and a half thousand providers, even if, as the Association of Employment and Learning Providers (AELP) suggests, a third of those on the register have not offered any training at all since being added.39 We think employers are entitled to expect a minimum level of quality assurance for the training they purchase, and this is best provided by Ofsted. All new providers should receive at least a monitoring visit from Ofsted in their first year. This would limit the number of providers, and the choice available to employers, as Ofsted will only be able to undertake a limited number of visits each year, but we do not think that is necessarily a bad thing. One high-quality option is better than several questionable ones.

16.We recommend that all new apprenticeship training providers should receive at least a monitoring visit from Ofsted within a year of being approved to deliver training by the ESFA.

17.Achievement of an apprenticeship standard is assessed by terminal assessment at the end of an apprentice’s training (an end-point assessment or EPA).40 Organisations performing such assessments must join a ESFA-managed register; these assessments are quality assured by an external organisation (an EQAO), which can be an employer or professional body, the Institute or Ofqual.41 The Institute oversees this system and, while originally intended as a backstop option, directly quality assures the assessment of nearly half of all standards.42

18.Our predecessors described this system as unnecessarily complex and fragmented.43 Some witnesses to our inquiry expressed similar views, one describing it as a “car crash”.44 The awarding organisation NOCN told us that EQAOs are “taking very different approaches” and warned that this would result in a “lack of consistency”.45 In July 2018, Ofqual issued guidance setting out how it will audit EPAs.46 Some awarding organisations warned that the regulator’s more stringent approach, and greater enforcement powers, could create a two-tier system.47 Notwithstanding the argument that giving full responsibility for EQAs to Ofqual would place greater regulatory burdens on assessment organisations, we are minded to agree with our predecessors that the body regulating qualifications should be the qualifications regulator.48 We therefore reiterate its recommendation.49

19.We recommend that Ofqual should be given responsibility for the external quality assurance of all end-point assessments.

Representation

20.Universities told us that the Institute does not understand their sector and that this is hurting the development and growth of degree apprenticeships.50 The Chartered Association of Business Schools said that this ignorance was “readily admitted by the [Institute], but to date there has been no action to rectify it”.51 Similar criticisms were made of the ESFA.52 The University of Essex outlined several problems with funding and assessment stating that

in order to enable us to upscale our current provision it is vital that the complex operating frameworks surrounding apprenticeships are made more accessible to the university sector and take due account of our expertise.53

The Dyson Institute of Engineering and Technology contrasted the relative ease of developing an engineering degree to meet business needs with the difficulty of getting an apprenticeship standard approved to complement it.54 In oral evidence, Sir Gerry Berragan, the Institute’s Chief Executive, seemed remarkably unconcerned, blaming the Department, which was previously responsible for approving standards, for raising the expectations of Trailblazer groups.55

21.We agree with Middlesex University that degree apprenticeships should be the “flagships of the apprenticeship system”.56 Mark Dawe, Chief Executive of the AELP, explained that

they are free. You are in work and earning [ … ] It is giving them HE locally and in work. At the end of it they are guaranteed a job, whereas over 50% of graduates who come out from university do not get a graduate-level job. There is enormous potential.57

HEFCE, the former HE funding body, told us that degree apprentices come from a wider range of backgrounds than traditional undergraduates and emphasised the potential of degree apprenticeships to improve social mobility.58

22.Greatly expanding the number of degree apprenticeships available is crucial if we are to create a high-quality system in which apprentices can expect to progress to higher levels to create a cascade of prestige for apprenticeships and address our skills deficit. As with any innovation, the programme needs nurturing. The Institute cannot afford to be “agnostic”, as Sir Gerry Berragan described its attitude to us.59 The Department should make clear in its guidance to the Institute that the growth of degree apprenticeships is a strategic priority and the Institute should act on this guidance.60

23.We recommend that the Institute makes the growth of degree apprenticeships a strategic priority.

24.Last year the Institute convened an apprenticeship panel to “challenge and make recommendations” to its board.61 This followed a commitment made by the Department during the committee stage of the Technical and Further Education Act 2017.62 While the Department rejected the case for placing the panel on a statutory footing as unnecessarily restrictive, it promised to periodically review the panel’s progress and assured the public bill committee that the views of apprentices would be fed directly into the Institute’s governance.63 The creation of the panel was welcomed by the National Society of Apprentices, part of the National Union of Students (NUS).64

25.However, we are deeply concerned what influence, if any, the panel is being allowed to have. The Institute states that the panel “commented” on its Quality Statement and “shared their views” on Commitment Statements, but it is not clear whether it was consulted on the Institute’s five-year strategic plan.65 It has met five times, but its July 2018 meeting was its first for nearly nine months.66 We are not convinced that the panel, and the apprentices it represents, are being taken seriously by the Institute’s board. To rectify this, it should be given a more formal role with both its minutes and its recommendations to the Institute’s board published. The board should be required to respond to these recommendations publicly.

26.It is not only the Institute that does not appear to be paying enough attention to the apprentice panel. In May the Minister said that she had not met the panel at all, a full year after it was formed.67 This is not good enough. While the Minister doubtless meets many apprentices as part of her duties, the panel exists to represent the views of hundreds of thousands of apprentices up and down the country. It can speak from wide experience and, crucially, with authority. In a system with many powerful lobbies, each with their own agendas, it is vital that there is a strong voice speaking for apprentices and that this voice is listened to and respected. The Minister should meet the panel regularly.

27.We recommend that the role of the Institute’s apprentice panel be formalised: its recommendations to the Institute’s board and the board’s responses should be published.

28.We think the treatment of the Institute’s apprentice panel is symptomatic of what the National Society of Apprentices characterised as an “unequal distribution of power” in the system.68 It told us that apprentices have few ways to challenge substandard provision and called for a new complaints system to be instituted.69 We are inclined to agree. Apprentices must have a clear path of redress when they do not receive the high-quality training they have been promised.

29.We recommend that the Government establishes and promotes an improved complaints procedure for apprentices.

Standards

30.We heard that new apprenticeship standards are broadly an improvement on previous frameworks.70 Considering the time and energy expended on the switch, we are nevertheless concerned by the think tank Reform’s assertion that many still “fail to reach the international or historical definition of an apprenticeship”, an issue also raised by several of our witnesses.71 Given how few standards-based apprenticeships have been completed, we think it is too early to make a judgement.72

31.Some witnesses called for the requirement that all standards include 20 percent off-the-job training to be relaxed, characterising the rule as ambiguous and inflexible.73 KPMG UK, the professional services company, told us that it was a “deal breaker for many low margin organisations who cannot afford to lose staff for this amount of time or are working to irregular schedules”.74 As part of our inquiry into nursing apprenticeships, we also heard how the assumption that off-the-job training would make up 20 percent of an apprenticeship when setting funding bands can make it difficult for employers to affordably deliver apprenticeships in fields like nursing which have stricter statutory requirements.75

32.Jane Gratton, Head of Business Environment and Skills Policy at the British Chambers of Commerce, called for the percentage to be set on a “standard by standard basis” rather than a “one-size-fits-all” rate.76 We have some sympathy for the argument. An apprentice should be learning both on and off the job, and the right balance between these will be different for each standard. If the system was working perfectly having such a rule would seem absurd. But, our concern, shared by the NUS, is that in our current imperfect system removing the protection of the 20 percent minimum, however crude it may be, could hurt apprentices.77 We think the Department should examine the case for greater flexibility, but it should proceed with caution. It should conduct pilots in limited sectors and regions, judge the effect of introducing such flexibility and act accordingly.

33.While we recognise there should be a minimum amount of off-the-job training, we recommend that the Government conducts pilots with apprentices and businesses to explore the effect of introducing greater flexibility in the amount required by each apprenticeship standard. If results are positive it should introduce greater flexibility across the system.

34.Our chief concern, shared by many of our witnesses, is that too few standards are available, which is preventing employers recruiting apprentices and providing high-quality training.78 The replacement process was originally due to finish in time for the 2017/18 academic year, but this has been repeatedly delayed.79 Sir Gerry Berragan told us that roughly half are now ready.80 The Institute has made efforts to speed up the process, and we welcome this, but even the Minister agreed it is still not fast enough.81 It is unclear whether it has begun a promised review of the standards it inherited, despite wide concern about their quality.82

35.Our predecessors were supportive of the creation of the Institute; we have heard more mixed views, with some employers being privately very critical of its approach.83 It has a difficult job: a supposedly employer-led body required to take direction from the Secretary of State, but at times it has appeared more successful at uniting stakeholders in opposition than anything else. We could do with fewer unseemly spats and vainglorious announcements, and more action.84 But it is important to remember that the Institute has overseen the standards creation process for just 18 months. It has been playing catch-up for the mistakes the Department made before it was created. There are not enough standards available now because the move from frameworks to standards has been mismanaged by successive Governments, resulting in delay after delay and frustrating employers who invested much effort and enthusiasm trying to make apprenticeships better. The Institute was always going to need time to get things back on track. It remains to be seen whether it will.

36.The transition from apprenticeship frameworks to standards has been mismanaged by successive Governments. Employers have been let down.

37.The community interest company Investors in People told us that “transparent progression routes” should be considered a crucial part of any apprenticeship scheme.85 Several witnesses emphasised the importance of building clearer progression paths to higher-level qualifications within the wider system.86 The Sutton Trust found that only one in four young people who start an apprenticeship progress from level 2 to level 3.87 It said that

connections between the levels must be strengthened so that level 2 and 3 apprentices do not hit arbitrary glass ceilings and have similar chances as their A-level or graduate peers to access the next level, including higher and degree apprenticeships.88

Its Chief Executive, Dr Lee Elliot Major, told us that

on the academic route [ … ] everything is signposted, you know the options, you get supported at transition points. [In apprenticeships] there are lots of dead ends [ … ] there are pitfalls. Sometimes it is a very confusing route. I think we just need to almost map out steps.89

This lack of progression is particularly concerning given that advanced apprenticeships tend to offer significantly higher wage returns and employers complain of severe skills shortages, particularly at levels 4 and 5.90

38.Things are beginning to move in the right direction—more higher-level apprenticeship standards are being created and higher-level starts are increasing—but far too many people are still being left stranded: their attempts to climb up the ladder of opportunity frustrated.91 London South Bank University suggested that standards “should include reference to the anticipated career trajectory of learners”.92 We think this idea has merit although we would place greater emphasis on the future training an apprentice could be able to undertake. When someone starts an apprenticeship it should be clear where it can take them. We also think there is a convincing case for bringing more general coherence to the system. The Institute currently creates occupational maps that “group skilled occupations with similar knowledge, skills and behaviours”.93 We think it should also build maps that lay out progression routes for apprentices and make these maps widely available.

39.We recommend that the Institute mandates the inclusion of clear paths to progression within apprenticeship standards. These paths should be linked to a system of progression maps created and promoted by the Institute.

Funding

40.The Government introduced the apprenticeship levy, and a new funding system, roughly 18 months ago.94 Research conducted on behalf of the Open University found that less than half of the business leaders it surveyed supported the levy in its current form.95 In June 2018, the Department said that employers had so far used just a tenth of their levy funds.96 While we share the concern of stakeholders about the fall in starts, we are limiting our comments in this section to areas where we consider a change in Government policy could improve quality, rather than just uptake.97

41.We heard that the levy may be incentivising employers to purchase provision that accredits their employees’ existing skills rather than training them for new roles and responsibilities.98 While we support the use of levy funds to reskill existing staff—apprenticeships are an important way for firms to fill internal skills gaps and raise productivity—they are only worthwhile if the employee is truly learning and progressing.

42.Some witnesses told us that the way providers are paid—in monthly increments with 20 percent retained until the apprenticeship is completed—made it difficult for providers to provide training that required high initial investment.99 Others said that the 24-month period during which levy funds can be spent was too short, especially for organisations that train sporadically in the engineering and manufacturing sectors.100

43.In an April 2018 report, EEF, the manufacturing and engineering trade body, called for levy-paying employers to be allowed to transfer more of their levy funds to employers in their supply chain: they can currently transfer only 10 percent.101 It also called for the maximum funding band—£27,000 per standard—to be reviewed, stating that

the delivery of quality higher and degree level apprenticeships in engineering and wider STEM disciplines is likely to exceed this amount. [ … ] it acts as a deterrent to providers from offering such courses on the assumption that Levy paying employers are unlikely to pay the additional excess. It leaves employers without access to provision they need.102

Some witnesses said that funding bands were generally being set too low and warned against them being reduced further.103 University Alliance said that there “may be signs of a ‘race to the bottom’” with the Institute justifying lower funding bands based on the worst available provision.104

44.The Institute has recently altered its funding band structure, replacing the previous 15 bands with 30, although it did not raise the funding maximum.105 It has also reviewed the bands in which some of the most popular standards are placed, with many reportedly to be cut.106 In its yearly strategic direction document, the Department instructed the Institute to ensure its funding band recommendations “maximise the value for money of apprenticeships”.107 Our concern is that value for money is becoming a synonym for cheaper. High quality provision can be expensive, but it is worth it. Setting funding bands so low as to reduce the quality of training or dissuade employers from recruiting apprentices is a false economy.

45.We recommend that the Government increases the top funding band to better match the full cost of delivery for some apprenticeships. It should also double the time employers have to spend their funds to 48 months and allow them to transfer more of these funds to firms in their supply chain.

Subcontracting

46.Subcontracting is a major part of the apprenticeship system.108 Nick Linford told us that it “is a bit of a hidden market that no one really wants to talk about”.109 Some colleges and universities were positive about the increased flexibility and convenience it can provide.110 Other witnesses were more circumspect: acknowledging its value in limited circumstances but questioning its widespread use, and strongly criticising the behaviour of some lead providers and the poor quality of training provided by some subcontractors.111

47.Ofsted characterised the subcontracting market as “very volatile” and emphasised the importance of strong quality assurance by lead providers.112 It has begun a limited programme of “risk-based monitoring visits to directly funded providers” focused on subcontracted provision and increased the emphasis it places on how lead providers manage their subcontractors when conducting full and short inspections.113 We welcome Ofsted’s renewed focus on subcontracting, but we think more can be done. It is vital that subcontracted provision receives the same level of scrutiny and is held to the same quality standard as that delivered by lead providers. Ofsted should be judging the quality of subcontracted training for itself rather than relying on quality assurance undertaken by lead providers.

48.We suggest several changes. Firstly, we need a better understanding of the standard of subcontracted provision across the country. To find this out Ofsted should produce a survey report, like its November 2015 work on apprenticeships.114 Secondly, it should drastically increase the number of monitoring visits it conducts focused on a lead providers’ subcontracted provision. A lead provider could replace all its subcontractors more than once between inspections, dramatically altering the quality of training it provides. Thirdly, it should inspect the largest subcontractors separately, rather than simply as adjuncts to lead providers. They should then receive a rating based on all the training they offer, regardless of lead provider. Only then will we get a clearer picture of whether the widespread use of subcontracting helps or hinders the provision of quality apprenticeships.

49.We recommend that Ofsted conducts a review of subcontracted provision across the country and produces a survey report setting out its findings, drastically increases the number of monitoring visits of subcontracted provision it undertakes, and inspects the largest subcontractors separately so that they receive a rating based on all the training they offer, regardless of lead provider.

50.In recent years the ESFA has tightened its subcontracting procedures.115 It now requires lead providers to deliver more than a “token amount” of their apprentices’ training, formally agree the arrangement with subcontractor and employer, and publish the management fees they charge.116 However, the definition of a “token amount” remains somewhat vague and publication of fee details was repeatedly delayed.117 These details, eventually published in June 2018, were disturbing.118 Analysis by FE Week found that lead providers charged an average management fee of 19 percent; 12 charged over 30 percent.119 John Ruskin College in south London, the lead provider which charged the highest average management fees at 39 percent, was heavily criticised by Ofsted in October 2017 for failing to properly monitor the progress of its apprentices, particularly those whose training was provided by subcontractors.120

51.Earlier this year, the Public Accounts Committee was highly critical of the ESFA’s failure to set clear guidelines about the fees lead providers may charge their subcontractors and the support subcontractors should expect in return.121 This followed the collapse of the training provider Learndirect Ltd which had been charging its subcontractors management fees of up to 40 percent.122 The Committee’s criticism, which the ESFA accepted and agreed to remedy, was echoed by several of our witnesses.123 In August 2018, the ESFA delayed the publication of promised new guidance until the end of this year.124

52.Some large provider bodies have agreed a voluntary cap of 20 percent on management fees.125 The Minister told us that she did not rule out introducing a formal cap in future.126 We think such a cap is a good idea. It would ensure money is spent on what matters: apprentices. However, we are not convinced 20 percent is necessarily the right level. While this may be appropriate when lead providers offer their subcontractors a suite of services, it would be too high when this is not the case. The ESFA should consult on the correct level to set, consider setting multiple levels for different relationships and require lead providers to justify the fees they charge in writing. We also think the training requirements placed on lead providers are too woolly. It is not enough that they contribute “something of substance”.127 They are the lead provider. They should be making a significant contribution to an apprentice’s training.

53.We recommend that the Government caps the management fee a lead provider can charge a subcontractor. It should consult on the level at which the cap should be set. Lead providers should have to justify to the ESFA the management fees they charge.

54.We recommend that the Government tightens the requirements on providers who subcontract their provision. Lead providers should have to deliver a significant amount of their apprentices’ training.

55.More broadly, while we welcome the ESFA’s attempts to take a tougher approach to subcontracting, we are concerned that its recent actions have not matched its rhetoric. Following the much-criticised tender for funding allocations to provide training to non-levy-paying employers, in which many good and outstanding incumbent providers were denied allocations, the ESFA’s advice to these 200 unsuccessful entrants was to become subcontractors.128 We accept that running such a tender may have been unavoidable, yet the way it was conducted, with smaller providers “squeezed out” in the Minister’s words, seems almost designed to encourage subcontracting.129 Given the failure of Learndirect Ltd we cannot agree with the Minister that large providers are less risky, although dealing with them rather than a number of smaller providers may lighten the ESFA’s workload.130 Therefore we share the Minister’s hope that this will be the last such tender and that non-levy-paying employers will be able to purchase their training directly from providers as soon as possible.131 It is crucial that such a system is responsive to the needs of smaller providers.132


18 Q168; Chartered Institution for Further Education (QUA 50) para 3.4; The 5% Club (QUA 71) paras 12 & 14; ESFA, Annual report and accounts, HC 1277, July 2018, pp 11–12

19 AoC (QUA 48) para 11; Ofsted (QUA 88) para 7. This refers specifically to funding related to FE and skills provision. Apprenticeship Statistics: England, Standard Note SN06113, House of Commons Library, July 2018; Q115; ESFA, ‘Apprenticeship training providers’, accessed August 2018

20 Q313. Responsibility for T Levels was to move from DfE to the Institute earlier this year, but this was delayed. A timetable for the transfer is now expected to be agreed by March 2019.

21Ofsted to win apprenticeship money and power”, FE Week, May 2018; Oral evidence taken on 31 October 2017, HC 341, Q144

22 Q318; BEIS and Education Committees, Second Joint Report of Session 2016–17, Apprenticeships, HC 206, paras 64–65

23 DfE (QUA 89) para 27; Industry Qualifications (QUA 74) paras 2.1–2.3; Q311; Q411; DfE (QUA 89) para 58; Institute (QUA 87) para 18

24 Q111; AoC (QUA 48) para 10; NOCN (QUA 31) para 2.5; CMI (QUA 82) para 2.2

26 DfE, ‘Register of apprenticeship training providers’, accessed August 2018; (QUA 89) para 66. Providers whose apprenticeship provision has been judged inadequate by Ofsted are ineligible.

33 DfE, ‘Apprenticeship funding: how it works’, accessed August 2018; ESFA, ‘Apprenticeship service transition, acting on user feedback’, accessed August 2018

34 DfE (QUA 89) para 67; Oral evidence taken before the BEIS and Education Committee on 19 October 2016, HC (2016–17) 206, Q219 [Peter Lauener]

35 AELP (QUA 39) para 23; British Chambers of Commerce (QUA 78) para 7; The 5% Club (QUA 71) para 3; Qq70–71 [Paul Devoy]

38 The new “market-style environment” the previous Government was keen to foster required more providers to ensure competition. This experiment seems to have failed: HMG, English Apprenticeships: Our 2020 Vision, December 2015, para 5.12; “95% of apprenticeships agreed at full cap price, despite negotiation ‘experiment’”, FE Week, March 2018

40 ESFA, ‘Register of end-point assessment organisations’, accessed August 2018

41 Institute, ‘External quality assurance’, accessed August 2018

42 Institute (QUA 87) para 17; ”Last resort’ IfA quality assures almost half of all apprenticeship standards”, FE Week, April 2018. The Institute has subcontracted its EQA activities to the awarding organisation, Open Awards.

43 BEIS and Education Committees, Second Joint Report of Session 2016–17, Apprenticeships, HC 206, para 98

44 Q186; British Institute of Facilities Management (QUA 68) para 28

45 NOCN (QUA 31) para 2.5

48Smelting apprenticeship gold: the alchemy of EQA”, FE Week, May 2017; Ofqual, Guidance to the General Conditions of Recognition, July 2016. Technically, standards whose assessments are not regulated by Ofqual are not qualifications: Oral evidence taken before the BEIS and Education Committee on 19 October 2016, HC(2016–17) 206, Q216

49 BEIS and Education Committees, Second Joint Report of Session 2016–17, Apprenticeships, HC 206, para 100; BEIS and Education Committees, First Joint Special Report of Session 2017–19, Apprenticeships: Government Response to the Second Joint Report of Session 2016–17, HC 450, paras 26–27

50 Sheffield Hallam University (QUA 42) para 3; Middlesex University (QUA 55) para 7; MillionPlus (QUA 37) para 12; University of Essex (VAL 82) para 3

51 Chartered Association of Business Schools (QUA 96) para 6.2

52 UVAC (QUA 36) para 6; University of Essex (VAL 82) para 3; Sheffield Hallam University (QUA 42) paras 18–21

53 University of Essex (VAL 82) para 9

54 Dyson Institute of Engineering and Technology (QUA 102) para 11

56 Middlesex University (QUA0055) para 17

58 Dyson Institute of Engineering and Technology (QUA 102) para 11

60 Enterprise Act 2016, Schedule 4

61 HC Deb, 29 November 2016, col 145

62 HC Deb, 9 January 2017, col 86

63 HC Deb, 9 January 2017, col 85

64 NUS (QUA 51) para 36

65 Institute, Apprentice panel recruitment information pack, March 2018, p 5; Institute, Strategic plan 2018–2023, July 2018

66IfA apprentices panel hasn’t met for 10 months”, FE Week, June 2018; Institute. In advance of its July 2018 meeting 21 new panel members were appointed: Institute, ‘The Institute for Apprenticeships has appointed 21 new members to the apprentice panel’, accessed August 2018

67 HC Deb, 1 May 2018, col 136052W

68 NUS (QUA 51) para 26; TUC (QUA 30) para 4.4

69 NUS (QUA 51) para 27. Apprentices can complain to the ESFA, but only after exhausting their employer or provider’s informal and formal complaints procedure. No phone number is listed: ESFA, ‘Complain about a further education college or apprenticeship’, accessed August 2018.

70 National Hairdressers Federation (QUA 61) paras 8–9; Lifetime Training (QUA 21) paras 13–14

71 Reform, The great training robbery, April 2018, p 5; CIPD (QUA 59) paras 8–9; Learning and Work Institute (QUA 85) paras 10–11

73 Our predecessors criticised the lack of a clear definition for off-the-training; 18 months on this does not seem to have been resolved. Institute, ‘What is a quality apprenticeship’, accessed August 2018; AELP (QUA 39) paras 6 & 13; Greater Manchester Learning Provider Network (QUA 23) para 1.3

74 KPMG UK (QUA 35) para 13

75 NHS Employers (NWF 2) paras 2–5

77 NUS (QUA 51) para 8; Qq329–330

78 University College of Estate Management (QUA 46) paras 12–15; British Constructional Steelwork Association (QUA 6) paras 1.1–1.2; Galvanizers Association (QUA 47) para 3; The 5% Club (QUA 71) para 8

79 BIS, The Future of Apprenticeships in England: Guidance for Developers of Apprenticeship Standards and related Assessment Plans, October 2014, para 3; The Future of Apprenticeships in England: Guidance for Trailblazers, December 2015, para 175

81 Institute, Faster and better, accessed August 2018; Q313; “Skills minister: IfA is better but still not fast enough”, FE Week, June 2018

83 BEIS and Education Committees, Second Joint Report of Session 2016–17, Apprenticeships, HC 206, chapter 3

85 Investors in People (QUA 91) para 25

86 Q8 [Joe Dromey]; Q56 [Tim Thomas]; Q129 [Graham Hasting-Evans]; Q152 [Alison Birkenshaw]; Centre for Vocational Education Research (QUA 58) para 1.3

87 Sutton Trust (QUA 38) para 8

88 Sutton Trust, Better apprenticeships, November 2017, p 35

90 Q57; Federation of Master Builders (QUA 97) para 2; UKCES, Employer Skills Survey 2015:UK Results, June 2016; CBI, Helping the UK Thrive, July 2017, p 21; Centre for Vocational Education Research (QUA 58) para 3.1; QAA (QUA 62) para 18; HEPI, Filling in the biggest skills gap, August 2018. For an explanation of qualification levels see: HMG, ‘What qualification levels mean’, accessed August 2018

91 Institute, ‘Search the apprenticeship standards’, accessed August 2018; DfE, Apprenticeships and Traineeships Release, July 2018. Advanced level starts are falling but slower than the general trend.

92 London South Bank University (QUA 8) para 5.3

93 Institute (QUA 87) para 5

94 DfE, ‘Apprenticeship funding: how it works’, accessed August 2018

95 Open University, The apprenticeship levy: one year on, April 2018, p 6

96 HL Deb, 6 June 2018, col 8152WA

98 Q6 [Lee Elliot Major]; Centre for Vocational Education Research (QUA 58) para 1.2

99 University College of Estate Management (QUA0046) p 8

100 DfE, Apprenticeship funding in England From August 2018, May 2018, para 22; Galvanizers Association (QUA 47) para 3.b; EEF (QUA 17) para 7.2; AoC (QUA 48) para 6; NHS Employers (QUA 63) paras 3.1 & 3.4

102 EEF (QUA 17) para 7.1

103 Chartered Society of Physiotherapy (QUA 69) para 3.1; Council of Deans of Health (QUA 10) para 7 & (NFW 1) para 9

104 University Alliance (QUA0098) para 4

108 ESFA, Using subcontractors in the delivery of apprenticeships, April 2018; DfE (QUA 89) paras 89–90; Ofsted (QUA 88) para 30; Q122. In 2016/17, 26% of provision was delivered by subcontractors, down from 29% the year before. General FE colleges subcontracted 36% of their provision; independent training providers 21%: “Private providers deliver 3 in 4 apprenticeships”, TES, June 2018

110 AoC (QUA 48) para 15; Warwickshire College (WCG) (QUA 60) para 11; Gateshead College (QUA 13) para 6; UVAC (QUA 36) paras 15–18

111 MiddletonMurray (QUA 67) paras 28–32; Chartered Institution for Further Education (QUA 50) para 4; Q11; Q120 [Graham Hasting-Evans]

112 Ofsted (QUA 88) paras 31–37

115 DfE (QUA 89) paras 92 & 94–96

117 The ESFA’s guidance states: “We do not define or quantify ‘substance’ in absolute terms. We also do not define a point in time at which the level of substance should be measured. This is because an employer’s apprenticeship programme may well evolve over time, with a varying nature and scale as apprentices start and finish their programmes”. Q123; “Providers told to declare subcontracting fees by late April”, FE Week, April 2018

121 Public Accounts Committee, Twenty Second Report of Session 2017–19, The monitoring, inspection and funding of Learndirect Ltd, HC 646, C & R 3

122 As above, para 3

123 HM Treasury, Government response to the Committee of Public Accounts on the Twentieth to the Thirtieth reports from Session 2017–19, Cm 9618, May 2018, p 16–17; Q11; Q120 [Stephen Evans]; Q191 [Mark Dawe]; University of Kent (QUA 83) para 12

128 Q195; Q399; AELP (QUA 39) para 24

130 Public Accounts Committee, Twenty Second Report of Session 2017–19, The monitoring, inspection and funding of Learndirect Ltd, HC 875; Q397

131 Qq396–397. In August 2018, the DfE announced that non-levy employers will not be able to purchase their apprentices’ training directly until at least April 2020: ESFA, ‘Apprenticeship service transition, acting on user feedback’, accessed August 2018




Published: 8 October 2018