Mandy Crawford-Lee, Director of Policy and Operations, University Vocational Awards Council (UVAC)

We’ve had a lot of discussion recently about Apprenticeship quality assurance gaps, inconsistent approaches and the way forward. I’d like to contrast the Ofsted and Office for Student (OfS) / Quality Assurance Agency (QAA) approaches.

RoATP Vs the OfS Register

Firstly we have two registers, the ESFA Register of Apprenticeship Training Providers (RoATP) and the OfS Register, and both are central to quality assurance.

In terms of public funding, the RoATP allows a provider access to Apprenticeship levy funding (£2.45bn p.a) and the OfS Register to the far larger student loan book (£13bn p.a.).

Getting onto the ESFA register, while applying has not been a mere formality, getting on hasn’t exactly been demanding to date. Write a good application, stick to the maximum character count, have a bit of luck and you seem to be there.

The FE press and others have highlighted concern over providers gaining registration with a negligible track record, with questionable financial accounts and limited ability or capacity to deliver high quality provision.

This is bad news not just for employers and learners, but also for the many ‘good’ providers who are then subject to the oversight needed by the poorest performing provider.

In contrast, to get on the OfS Register a higher education provider needs to jump through a multitude of hoops – university status and degree awarding powers are not granted lightly.

Monitoring of New Providers

We then come to the monitoring of new providers. Claims have been made that universities (delivering Degree Apprenticeships) subject to OfS regulation aren’t getting early monitoring visits in the same way as Ofsted inspected providers.

While this is true, it is entirely appropriate. Have a robust and reliable registration and market entry system (like HEFCE/OfS) and you don’t need to have early monitoring visits – it’s sensibly covered by the registration process. Indeed, the need for early monitoring visits is indicative of the failure of the ESFA system at the first stage – a weak market entry process.

ESFA, with some prodding from the DfE and IfA seems finally to have realised the need for a more robust register – but it’s taken them over 2 years and they’ve presented Ofsted with a major problem - the vast number of questionable new providers that require monitoring and inspection.

Inspection and Regulation of Apprenticeship Provision

Let’s now look at the inspection and regulation of Apprenticeship provision. Ofsted through the inspection process may well have helped improve the quality of lower level programmes; although I’d like to know:

  1. Why they’ve allowed the plethora of level 2 programmes in questionable occupations to be offered for so long
  2. Why they’ve never tackled the issue of those apprentices under 25 who start their training below their existing level of educational attainment and are ‘treading water’

Apprenticeship is, however, changing with employers focusing on the high level occupations they and the UK economy needs. Here it’s often the territory of professional and statuary regulatory bodies (PSRBs), who know more about occupational competence than anyone else.

QAA works extensively with around 90 PSRBs - think Nursing and Midwifery Council, RICS, RIBA, IMechE, ICE, BCS - and ensures they are integral to the higher education approach to quality assurance and curriculum development.

Do those advocating Ofsted really think Ofsted can rapidly develop appropriate relationships with PSRBs that have taken decades for the HE sector to develop? Does Ofsted have the inspectors who understand how HE working with PSRBs and employers develop and accredit professional occupational competence?

For level 6 and 7 Degree Apprenticeships OfS / QAA is always going to have the central role in quality assurance because in so many cases a PSRB has decided a degree is a requirement to practice and OfS / QAA have the responsibility for the quality assurance of provision offered by institutions with degree awarding powers.

Inspection is not fundamental to quality assurance

One final point concerns the perceived need for ‘inspection’. Many in the Apprenticeship sector assume ‘inspection’ is fundamental to quality assurance – it isn’t.

Let us look at how the HE quality system works. QAA uses a process of peer review to assess whether or not a higher education provider is able to achieve the expectations for standards and quality set out in the Quality Code.

Providers explain their institutional quality assurance processes to show how they meet the expectations and how those processes ensure continuous improvement. Reports of reviews are published on the QAA website.

The external examining system is a process of peer review at course level to ensure that standards and quality are met in individual assessments and courses and that a provider’s individual quality processes are followed.

External Examiner reports are published by the provider on whose programme they comment. Concerns about a course can be raised with OfS/QAA who can investigate.

The independence and impartiality of external examiners has been recognised through the introduction of integrated Degree Apprenticeships. Let me be a little controversial here.

The OfS/QAA quality system is, when analysed in the context of a higher level skills programme, eminently more suitable than the ESFA/Ofsted system.

International Recognition

Ofsted are familiar with assessing the delivery of lower level skills in the workplace e.g. plumbing, hairdressing and motor mechanics. There’s no evidence to suggest Ofsted have the expertise and capacity to quality assure the curriculum or the development of higher level professional competence in the range of areas where higher and degree apprenticeships are being developed.

In contrast, QAA does and has a system that has international recognition. The public rightly rely on the higher education quality system to ensure academic excellence and occupational competence when using the services of a doctor, nurse, vet, social worker and professional bodies use the system in the same way for architects, engineers, those working in information/digital technology etc.

Can I suggest those in the Apprenticeship system do so too?

Mandy Crawford-Lee, Director of Policy and Operations, University Vocational Awards Council (UVAC) 

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