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Top pitfalls and tips for EpAOs applying for Ofqual recognition

Jacqui Molkenthin, JEML Consulting

Given the volumes of #EpAOs applying for @Ofqual recognition (first time or resubmission), I thought it may be helpful to highlight some of the areas where I have identified gaps when reviewing organisation documents prior to submission to Ofqual, alongside some of my hints and tips on how to improve a submission. Just as Ofqual say, this list is not exhaustive! but I hope it will provide some help and guidance to EpAOs currently going through the process of recognition:

1, Base your application on both the Criteria and Conditions

Ofqual state that they review applications against the Criteria for Recognition and not the Conditions, but I always advise EpAOs to apply based on both the Criteria and Conditions. There are 2 reasons for this. Firstly, I have seen Ofqual rejection letters referring to things that are only mentioned in the Conditions. Secondly, once approved you must operate to the Conditions, so it would be advantageous to your organisation to check that you are able to operate to the Conditions when working through your application.

2, When detailing your organisation structure, make sure you look across your whole organisation and not just your EpAO.

This is absolutely critical for the identification and management of any potential conflicts of interest as well as the governance and decision making across your organisation. Ofqual will look at your organisation details on companies house to identify the directors, those with significant control, and any companies linked to those directors. If you have not been through this process of identification yourself, it means that you may not have identified, mitigated and managed (potential / actual / perceived) conflicts of interest (Criteria A5 and Condition A4). I wrote an article on governance, including conflicts, which may help.

3, Consider building a role, responsibility, and accountability matrix for your organisation

Contradictions across roles and responsibilities often arise because organisations build or adapt policies and processes as they work though the Criteria and Conditions. With so many documents it is easy to get roles and responsibilities muddled. I would recommend building a matrix of roles and responsibilities across all activities across the lifecycle of your service (set-up, design, development, delivery, award, review, feedback, continuous improvement and withdrawal), and then using that to populate your policies and processes. This should reduce the risk of contradictions, and will enable you to check that all activities of your organisation have people that are responsible, accountable, consulted and kept informed (known as a RACI matrix). It will also enable you to check to make sure that you don’t have the same person both responsible and accountable for any activities/policies/processes (for some micro-organisations this may be unavoidable, in which case make sure you detail the checks you have in place).

4, Take account of independence, not just in assessment

I have seen many references, in Ofqual rejection letters, to the lack of evidence of independence in the investigation and decision making for appeals, malpractice, and complaints. What Ofqual must be able to see, within your policies and processes, are the mechanisms to ensure that investigations and decisions are carried out without any conflicts of interest. Ofqual Conditions often refer to this as “no personal interest” in the result, outcome or decision.

5, If you decide that an Ofqual Criteria / Condition is not applicable, explain why

Just saying ‘not applicable’ will not be sufficient for Ofqual, you will need to explain why. An example is ‘prior learning’, condition E10, which requires awarding organisations to have a policy on the recognition of prior learning. In end-point assessment terms, apprentices are assessed the same regardless of their prior learning, and as such it is not applicable (there may be some exceptions to this based on the assessment plan). Simply stating that condition E10 it is not applicable will not be sufficient, you will need to have a policy on the recognition of prior learning, even if it is to say that prior learning is not recognised. Another example may be Centres (Condition C2); if you do not have centres, instead of saying not applicable, make sure you evidence how you operate to demonstrate that you do not have centres (details on centres can be found in the guidance on page 6).

6, Be clear on what is and what is not already in place at your organisation

You may not have all the staff in place, or IT systems up and running to manage your EPA service at the time of your application. This does not prevent you from applying, but make sure you have identified all roles and systems required to run your organisation, and have provided details of staff or systems in place or yet to be recruited or contracted. If staff are yet to be recruited, make sure you can detail a robust process to get there, for example, already having job descriptions in place and having a clear recruitment and selection process. If a system is yet to be designed or purchased, detail your process for identifying what systems may be required and your processes for selecting appropriate suppliers or third parties.

7, Remember to detail how you design your assessment tools and materials

This may sound obvious, but I have seen cases of EpAOs saying that the design has already taken place through the design of the standard and assessment plan via the trailblazer groups and IfATE. Whilst this is correct to some degree, there is a lot more to design than the standard and assessment plan. The assessment plan is high level, it does not provide, for example, the questions for tests or interviews, or the details of end-point assessment projects or observations. As an EpAO, you will need explain to Ofqual how you will design your all of your assessment tools and materials. This includes the identification and recruitment of the appropriate design experts, any guidance you produce for designers (e.g., language, level and stimulus materials), your processes for review/testing/scrutiny, and your sign off process. All of this will enable Ofqual to see and trust that you are able to design ‘fit for purpose’ assessment tools and materials (Condition D1). I wrote an article on designing MCQs and an article on designing to the correct level which may be helpful.

8, Ensure equality is reflected across your entire organisation and operation

I often only see reference to equalities in the delivery aspects of end-point assessment, in particular reasonable adjustments. As an EpAO you must make sure you detail how equality is embedded throughout your service and organisation, not just the delivery of assessment. For example, how you embed equality in recruitment, assessment design, quality assurance, feedback / review and continuous improvement (Ofqual guidance section 4.1, formally Criteria D1c, and across all Conditions). In design terms, it could be detailing how you ensure that there is no bias in the design of the assessment. In quality assurance terms, it could be about identifying bias in the delivery of assessment by assessors through sampling / observations. In continuous improvement terms, it could be detailing quantitative monitoring of results by age, gender and so on. But with all of this, you must have mechanisms to: a) raise awareness; b) minimise the likelihood of it occurring; c) identify any equality issues as they arise; d) deal with issues should they arise/occur; e) learn lessons and continuously improve.

9, Protect data

Make sure that you have clear policies and procedures for data sharing, storage, security and disposal across all aspects of the organisation and service, as well as between organisations (training provider, employer, ESFA, IfATE, EQA provider). Remember, it is not just about security and confidentiality of apprentice data, it is also about security of assessment tools, complaints, appeals, whistleblowing, malpractice, reasonable adjustments and so on. It is also about your processes for dealing with any breaches of data security should they occur (Ofqual Criteria C and Conditions A1.2, A5.2, B4.2).

10, Remember to detail a process for withdrawal.

This is an area I often seen missed when reviewing applications prior to submission. You may have no intention of withdrawing from the end-point assessment market place, but Ofqual (Criteria C and Condition D6) require you to detail a processes for withdrawal, so as to protect the apprentice.

11, Contingency and continuity plans for your service

Make sure you have plans for ‘what happens if’. This will very much link to your approach to risk, and you may well have it all covered in your risk policy, but please remember that Ofqual condition A6.3 and A6.4 requires you to have a written contingency plan, and Criteria C requires you to have a continuity plan. I have seen many interpret this as disaster management, such as flooding, covid and so on. This is, of course, part of it, but it is much broader than that, for example, what happens if an assessor is ill on the day of an assessment, what happens if the responsible officer leaves, what happens if the funding bands change, what happens if there is a breach of assessment materials and so on.

12, Provide a mapping document of your evidence

I would strongly recommend producing a mapping document to enable Ofqual to see which piece of evidence relates to which Criteria and Condition. Many organisations have up to 100 pieces of supporting evidence with their application. Ofqual will use a range of experts to review your application and as such it will be extremely helpful make it clear which documents relate to which Criteria and Condition, so that the right experts can read the right documents. It will also help you check if there are any areas you have missed prior to submission. There will, of course, be overlap with some documents, but it is none the less a very helpful process to go though. I often use a spreadsheet with the Criteria and Conditions listed and then add a column detailing the document(s) that provide the evidence. You can then filter it to focus on specific areas for checks/reviews. For those resubmitting, Ofqual now has a template to record all the changes you have made from your original submission to your resubmission.

13, Create an easy to follow document refencing process

With EpAOs likely to have up to 100 documents supporting their applications, I have often found it helpful to create a unique referencing system for each document. It does not need to be complex, and you do not have to do it if you don’t want to, I have just found it helpful when I have been navigating and referencing multiple documents.

14, Consider ‘how to’ guides

On a closing note, why not approach Ofqual recognition as a process of writing a set of ‘how to’ guides, induction guides or manuals / handbooks for your organisation. You could break it down into bite sized chunks mapping each to the Criteria and Conditions. For example, a guide/manual/handbook on governance and integrity, one on design and development, one on delivery and award, and one on quality assurance, feedback and continuous improvement. This will help you bring things together into a meaningful handbook rather than a potentially random collection of up to 100 documents, and it may help you cover off some of the Ofqual criteria that must be covered but don’t necessarily require a policy, such as condition B4.1 providing details of where Ofqual should serve any written notices.

I hope you have found the article helpful.

Jacqui Molkenthin, JEML Consulting

You can access regular updates via my LinkedIn page and via my previous articles on FE news.

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