Tackling The Confusion Of The Apprenticeship Assessment Reforms

In February 2025, the government announced large scale and wide reaching reforms to apprenticeship assessment, yet, in the months that have followed, detailed information has been notably scarce. 

The only exception is Ofqual, which has taken proactive steps by launching a consultation and engaged awarding organisations through a series of targeted webinars around the regulatory impact of the reforms on awarding organisations.

This absence of communication, however unintentional, is generating unease, speculation, and confusion, risking misdirection, disengagement, and the erosion of confidence in the apprenticeship system.

This Is A Whole System Reform

There is no escaping it, this is a whole system reform.  Simplified assessment plans, on-programme assessment, employers confirming behaviours,  and provider involvement in assessment. The reforms therefore impact training providers, assessment/awarding organisations, employers and learners.

The Richard Review back in 2012 reminded us that it is about the ‘system as a whole’, which means that all organisations (DfE, Skills England, DfE, Ofsted and Ofqual) and representative bodies across training and assessment should be working together, communicating with, and supporting the sector to prepare for the changes.   Whilst it is widely acknowledged across the sector that extensive work is underway behind the scenes with DfE and Skills England, the continued lack of public communication has created an information vacuum.  

The Top 10 Aeas Of Concern

In this article, I will share the top 10 areas of concern I have received from the assessment/awarding sector:

1, Funding

If assessment can be on-programme as well at the end, if providers take part in assessment delivery, and if awarding organisations need to set up and manage ‘Centres’, how will the funding work? In theory, the funding will need to be released earlier, training providers will require paying for the elements of assessment they undertake, and awarding organisations will require funding to enable them to operate Centres as well as undertake assessment. With no news on funding and with the knowledge of the financial burden of these changes, awarding organisations and providers are rightly questioning the viability of providing apprenticeship assessment going forward.

2, Resources (staff)

• AOs will now need to take on EQA functions, in addition to their existing assessor and IQA functions. This means they will need to recruit and train EQAs and recruit and train staff to manage the operation of Centres and the CASS. In addition, they will need to play a greater role in assessment design which, will require additional resource and expertise. For many AOs these are new areas, so they will also require support, training, and time to be ready.
• Providers will need to take on assessment and IQA functions. Many training providers have reduced their banks of assessors and IQAs since the apprenticeships reforms back in 2012 when end-point assessment was introduced.  Training providers will therefore need to recruit and train assessors and IQAs if they are to deliver assessment. They will also need to go through a process of Centre approval with the awarding / assessment organisation and be subject to monitoring and external quality assurance by the AO, which means they will require staff to operate the Centre and manage the relationship with the AO.   

All of these activities take time and money to set up and operate at a time when budgets are already squeezed due to the national insurance changes, a lack of inflationary increases to apprenticeship funding bands.

3, Assessment Development

AOs will be moving into a more complex world of assessment design, switching from detailed assessment plans to high-level assessment plans with assessment outcomes. This means that AOs will need to take on a greater role in design and development, producing assessment strategies to explain and justify the choices that have been made in the development of the (synoptic) assessments and their associated grading structures to ensure that they are fit for purpose.  This approach will bring greater flexibility, but it will increase the burden on AOs. Without support and scrutiny, it will risk negatively impacting the quality of assessment and will undoubtedly increase the inconsistency of assessment between AOs.

4, Consistency

There is no hiding the real and legitimate concern around inconsistency between AOs for the same apprenticeship.  Concerns around inconsistency are not new, but there is recognition that the variation between AOs will increase as a result of the flexibility that the new approach brings.  Some see the diversity of approaches as a positive step for the market, whereas other see it as causing confusion for employers, providers, and learners and risks a race to bottom on quality. Many have asked how Ofqual will ensure consistency, but we must recognise that consistency is not the role of the regulator. Ofqual focuses on comparability, making sure that grades mean the same thing across AOs, across subjects, and over time  “Generating assessment outcomes that are comparable in standards between assessments within a qualification, between similar qualifications, with other awarding organisations, and over time”.  Skills England and the DfE will need to respond to these concerns by being clear with the sector about their views in relation to consistency of assessment between awarding organisations on the same standards.

5, Centre versus AO marked

I have lost count of the number of questions raised on this area. Ofqual have proposed that a significant proportion is marked by the AO, but are clear that the AO must determine and justify the approach they take.  This means that AOs will have varying delivery methods as well as varying assessment approaches. However it also raising other concerns around provider capacity.

If an AO, through their assessment strategy, determines what assessments can be Centre delivered, what happens if one Centre does not have the capacity or if a Centre decides that they would rather the AO undertake the assessment?

This could potentially mean that an AO will require multiple delivery options per assessment method per standard. 

6, Conflict of Interest Management

The use of Centres has raised concerns around conflict of interest management because neither the new assessment plan structure nor the foundation apprenticeship assessment plans mention independence.

However, the DfE funding rules  do state “Although both the employer and the main provider will be involved in administrative arrangements for assessment, the end point assessment itself must be independent” and “training providers who have delivered the training cannot assess their own learners”.

In addition Ofqual Condition A4.5 states “An awarding organisation must take all reasonable steps to avoid any part of the assessment of a Learner (including by way of Centre Assessment Standards Scrutiny) being undertaken by any person who has a personal interest in the result of the assessment.” And condition G4.3 refers to the confidentiality of assessment.

7, Occupational competence versus employer competence

The increased flexibility of apprenticeship assessment and the proposal within the Ofqual consultation for AOs to secure employer support for the detail of their assessment design and delivery decisions has raised concerns about whether occupational competence will be lost to employer competence. For example, an AO designing assessment to meet the needs of the employers they work with as opposed to the needs of the occupation.  Occupational competence has been defined by Skills England as follows: “The occupational standard must define competence in an occupation so that, on completion, the new entrant to the occupation is able to carry out the role in any size of employer across any relevant sector.”

8, Behaviours behaviours behaviours

This area really does require clarification. The Ofqual consultation makes it clear that behaviours are not part of the assessment “‘behaviours’ will no longer be assessed by AOs”. But then when you look at Skills England documentation it seems to imply that behaviours will be either assessed or that AOs will be accountable / responsible.

For example, the foundation apprenticeships state  “EPAOs must confirm with employers that they have been suitably demonstrated”, and the apprenticeship principles “As they do now in apprenticeships, employers are best placed to confirm apprentices are demonstrating the required behaviours”. If there is no accountability for apprentice behaviour, it raises the question of the value in including it as part of the apprenticeship. There is no point in creating a bureaucracy driven tick box exercise for employers to complete to confirm that the behaviours have been demonstrated when there is no accountability measure that sits behind it.

9, Gateway

There is confusion about the gateway going forward and whether it even exists. The new assessment plan structure does not mention gateway, but the new foundation apprenticeships use the words  “typical duration to gateway”  and the DfE funding rules state “On-programme End-point Assessment is any assessment activity related to the end point assessment where the standard allows this to be delivered prior to gateway”.  So when is the gateway and what is required?

10, Mandated qualifications

There is no hiding that this is a bit of a dog’s dinner. It raises a whole host of questions: If apprenticeship assessments must not duplicate, who determines what is covered by the mandated qualification and what is covered by the apprenticeship assessment?

This is particularly important when the regulated qualification may be delivered by many awarding organisations, as their content will not be identical. What happens if, by developing a synoptic assessment, you need to include some aspects of the mandated qualification (therefore duplicating)?   What happens if the mandated qualification is not a regulated qualification? What happens if there is no mandated qualification specified, but the portfolio requirements include a qualification?  and what if a mandated qualification covers all the knowledge and skills requirements of an apprenticeship, can it really be considered an apprenticeship?

I do not envy the work of DfE, Skills England and Ofqual during this programme of reform, but the sector really would benefit from improved communications. A lack of communication can erode trust and confidence, which would not be a good start for the newly created Skills England. This may be an early indication of the challenges arising from Skills England reporting directly to the Secretary of State, rather than operating as a Non-Departmental Public Body, perhaps they lack autonomy over their communications?

Before I sign off on this article I have one final point – timeframes – the sector need to know the timescale for these changes, when will the new assessment plans be released, when will awarding organisations need to be ready, when will apprentices be able to start on the new approach?

By Jacqui Molkenthin from JEML Consulting