Training Provider Preparation for the new system of Apprenticeship Assessment
The forthcoming world of apprenticeships assessment marks a significant change in the way apprenticeship assessments are designed and delivered. For non-integrated apprenticeships it will be moving away from very detailed assessment plans and independent assessment at the end of apprenticeship (after gateway), to a world where the EpAO (now called Awarding Organisation, AO) designs the assessments from a high level assessment plan, and where parts of the assessment may be delivered at any time during the apprenticeship either by the awarding organisation, employer or training provider. It also sees other changes such as the introduction of assessment outcomes and sampling, the responsibility for the verification of behaviours passing to the employer, and the requirement for AOs to consult users of apprenticeship assessments when designing and developing the assessment.
Whilst many initially jumped for joy thinking the changes opened a world of flexibility and opportunities, the reality is not quite as simple. There is no doubt that there are opportunities, but it must be handled and delivered in the context of struct rules and regulations and the involvement of many interested parties, Skills England, DfE, Ofqual, Ofsted, OfS and in some cases professional bodies.
There has been a range of information drip fed over the past 12 months but there are still many gaps to fill before the sector has full clarity around the reforms. DfE released a set of principles, guidance around the changes to apprenticeship assessment, and an annex to the funding rules on the new apprenticeship assessment. Skills England have released some assessment plans in the new format, and Ofqual have published their Apprenticeship Assessment Qualification Level Conditions and associated guidance.
This article is intended to highlight some of the key considerations for training providers as they plan for the future of apprenticeship assessment, whilst acknowledging that further guidance is expected over the coming months.
Help Shape The Assessments
Under the apprenticeship assessment Ofqual conditions, AOs will be required to consult with the users of the apprenticeship assessment as they design and develop it (Condition E1), so I would recommend reaching out to any AOs you work with to find out more about their plans for consultation and feedback around the design and development of the new assessments. AOs must take into account of the views of all users whether that be learners, employers, providers, or professional bodies so please recognise that there may be trade-offs to be made in order for the AO to ensure it develops fit for purpose apprenticeship assessments.
Explore What it Means to be a Centre
Probably the most important change is that of potential training provider or employer involvement in the delivery and marking of the assessment, in regulatory terms this is known as a ‘Centre’ of an AO.
Many training providers and employers will have already been acting as third parties to EpAOs through the provision of facilities and equipment, but going forward, they may play a role in the invigilation or marking assessments on behalf of the AO. The critical point to note here is that the decision about whether an assessment can be invigilated or marked by a Centre will be down to the AO, either at the stage of initial assessment design by the AO, or at the stage of determining whether a potential Centre has the capacity or capability to invigilate or mark an assessment on an AOs behalf. It is also important to remember that a Centre cannot deliver all assessments (DfE apprenticeship Funding rules paragraph 353, and Ofqual Apprenticeship Assessment Qualification Level Conditions).
Some training providers may already be operating as Centres for AOs across other qualifications, but for the majority of those that only deliver apprenticeships, being, or becoming, a Centre is a brand new concept. Even for those used to operating as a Centre for an AO, it will not be quite the same for apprenticeship assessment because of the potential mix of provider / employer / AO marked assessments within an apprenticeship.
An AO must carry out a detailed process of due diligence to provide assurance that the Centre has the capacity and capability to deliver / mark assessments on their behalf. This will cover areas such as governance, financial stability, compliance history, organisational policies, procedures and staffing. Once approved, the AO must have a written enforceable agreement with the Centre (refer to Ofqual Condition C2.3) and operate monitoring and scrutiny monitoring and scrutiny by the AO. (Condition H2.1).
As a training provider, it would be worth exploring your current staffing skills, expertise and capacity to be able to deliver, mark and internally quality assure apprenticeships assessments, alongside reviewing your current policies to check they can cater for areas such as reasonable adjustments, malpractice, appeals and complaints.
Be Mindful of Contracting
Under the DfE funding rules (paragraph 348) the provider must contract with the AO. Under the Ofqual conditions if a Centre is marking an assessment on behalf of an AO the AO must have a written enforceable agreement with the Centre (Condition C2.2) . This means that if a provider becomes a Centre of an AO there will be more than one contract in place for the purposes of apprenticeship assessment.
As a training provider, it would be worth reviewing the requirements of the provider/AO contract (paragraph 349 of the funding rules), and the AO/provider requirements (Condition C2.3) to ensure that where there is more than one contract in place it does not unintentionally cause conflicts or contradictions.
Manage Conflicts of Interest
An AO is subject to strict conditions around the identification, mitigation and management of conflict of interest, and those conditions extend to its Centres. For example, the Ofqual conditions require AOs to “take all reasonable steps to avoid any part of the assessment of a Learner being undertaken by any person who has a personal interest in the result of the assessment”, and “Where, having taken all such reasonable steps, an assessment by such a person cannot be avoided, the awarding organisation must make arrangements for the relevant part of the assessment to be subject to scrutiny by another person”.
As a training provider, are you able to provide assessors that are independent of those who have trained the learners? If not, what processes do you have in place to ensure that assessments are delivered and marked consistently, fairly, and free from bias, and that the confidentiality of assessment materials is maintained?
The AO will be monitoring conflicts of interest as part of its Centre Assessments Standards and Scrutiny strategy and may well carry out additional external quality assurance activities and scrutiny of a Centre marking where there are concerns or risk around the management of conflicts of interest.
Be Aware Of Funding Rules And Requirements That May Distort Provider Behaviour
As a training provider the opportunity for conflicts of interest to occur under the new assessment regime will increase, and as such you should start to consider where there are conflicting pressures within the funding rules and technical guidance. For example, the Apprenticeship Accountability Framework (AAF) has recently changed, and some of the criteria used by the DfE to measure performance have been revised. This may lead to competing pressures regarding learners who are approaching or already past their planned end date. On the one hand you will want to ensure that your assessment regime as a Centre is rigorous, and delivers a robust and fair outcome for the learner, but this may come into conflict with your desire to ensure that learners complete their apprenticeship by the planned end date, and do not therefore count negatively on your AAF dashboard. As a training provider you will need to ensure you identify and mitigate or control such conflicts within your organisation to ensure the ongoing integrity of apprenticeship assessment.
Explore Budgets
The DfE technical funding guide provides the details of how training providers receive their funding. Training providers may wish to undertake some financial scenario planning for the new system because if the AO designs assessments that can be delivered early on and / or determines that assessments can be marked by the training provider, the current EpAO fee and invoicing model may need to change. For example, an AO will have fees for Centre approval and may charge earlier for assessments if they are undertaken earlier on in the apprenticeship. Please do not assume that if a training provider delivers/marks an assessment instead of the AO that fees will be reduced, they may do in some cases, but the cost of Centre approval, external quality assurance and scrutiny may well outweigh any savings on assessment fees.
As a training provider, it may be worthwhile talking to AOs to see if they know what their fee and invoicing models may be for the new apprenticeship assessment, however, please remember that the assessment design work can only commence once the new assessment plans are published by Skills England, and as such many AOs will not yet know the timings of assessments, or whether they will have Centre delivered assessments.
Consider the Timings of Assessment
In terms of timings of assessments, the qualifying period for funding is 42 days, so presumably assessments prior that timeframe would be unwise and highly unlikely. However, there may be instances in some apprenticeships where some knowledge and skills are required to access the workplace, and in which case an assessment may be early on. Don’t forget that not all assessments can be early on, the DfE apprenticeship funding rules state that there must always be an assessment at the end of the apprenticeship (paragraph 350), and the Ofqual conditions require synoptic assessment, which by its very nature of demonstrating occupational competence is unlikely to be able to be delivered early on.
As an training provider, start to build a picture of it what may be realistic timeframes for the delivery of different types of assessment across the apprenticeships you deliver, as the intelligence will be helpful to AOs when they are designing the assessments (refer to point 1).
Measure Apprentice Behaviours
The DfE principles and guidance confirmed that behaviours will no longer be assessed. Instead they will be verified by employers. No further detail has yet been released on what this verification will look like, but at a recent (3rd February) webinar Skills England indicated that the employer behaviour verification will be requested by the provider. Based on this, I would recommend that providers (and employers) look at the progress reviews they undertake with learners, and explore how the behaviours of the apprenticeship (occupational) standard could be embedded into them. This could then make the process of verification smoother. Skills England did say that more information would be released soon around their requirements.
Train to the Whole Apprenticeship (Occupational) Standard
There has been a lot of concern raised about the impact of sampling during apprenticeship assessment and whether it will lead to occupationally competent employees. From a provider perspective, the introduction of sampling should not impact on how you deliver your apprenticeship as all apprentices should be trained in, and acquire all, of the knowledge and Skills in the occupational standard, even if they’re not going to be directly assessed on all of them. The intention, under the reforms, is that only the assessment plans will change.
Be Clear on How You Use Subcontractors in Apprenticeships
As a training provider, do you work with subcontractors or third parties? If yes, would you plan to work with subcontractors or third parties to deliver or mark apprenticeship assessments? If yes, remember that you will need to seek approval from the AO to use subcontractors for the delivery or marking of apprenticeship assessments, you can not assume that your existing due diligence processes for using subcontractors or third parties is suitable for the delivery of apprenticeship assessment.
Regularly Check For Updates
The reforms are new and evolving, we are still awaiting clarifications and further guidance, so please make sure you keep checking the Skills England, DfE and apprenticeship webpages for updates. For example, Skills England are adding surveys to their website on the new assessment plans, the DfE have been making further updates to their Apprenticeship training provider accountability framework, and we are beginning to see additions to the key information sections of apprenticeship stating the minimum hours for compliance (an example is provided in the AI and automation practitioner apprenticeship).
On a closing note, there is a lot training providers can do to begin preparations for the new system of apprenticeship assessment even with pieces of the puzzle still missing. The most important thing to remember is that this system is new for everybody and that the best way forward is to engage wherever possible to shape a strong and robust apprenticeship system into the future.
By Jacqui Molkenthin from JEML Consulting
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