Jacqui Molkenthin, JEML Consulting

@IFAteched consult on simplifying #EQA with @Ofqual and @OfficeStudents delivery only  

The 26th February IfATE Consultation proposes a move away from a system where External Quality Assurance (#EQA) is delivered by a wide range of different organisations, to one where EQA is delivered by Ofqual for non-integrated degree apprenticeships, and by the Office for Students (OfS) for integrated degree apprenticeships.

In February this year there were 38 named EQA providers on the IfATE spreadsheet, 18 of which were marked as TBC (to be confirmed). You can find out more about current EQA in a previous article of mine, and in the results of a survey I carried out in February 2020.

Within the IfATE consultation document it proposes a single, unified, registration (due diligence) process, which will result in EpAOs being on the register of end-point assessment organisations, and recognised by Ofqual or the OfS. To be recognised by Ofqual, it means meeting its Criteria for Recognition.

There are currently 612 standards approved for delivery on the IfATE published spreadsheet (as of 22nd April 2020), of those 50 are marked as integrated degree apprenticeships. This therefore means that, if the consultation recommendations are adopted, 562 apprenticeships will fall within scope of being external quality assured by Ofqual. Currently, just 77 (14%) of these standards are already external quality assured by Ofqual, the remainder are externally quality assured by other organisations – employer led, professional body, or the IfATE (currently delivered by Open Awards).

We know, from the April 2020 ESFA published register of end-point assessment organisations (RoEpAO) that there are 281 approved End-point Assessment Organisations (EpAOs), which therefore means that, if the consultation recommendations are adopted, up to 281 organisations will have to apply to Ofqual to meet their criteria for recognition.  Of these 281 organisations, 54 are shown on the published Ofqual Organisation Register as being approved under Ofqual criteria for recognition (the IfATE consultation document page 27 states 55, but I could only locate 54).  However, this does not mean that they are approved under Ofqual conditions (criteria for recognition) for their end-point assessment. In fact, when you look at the April 2020 Ofqual spreadsheet of recognition permissions (available here), there are just 31 organisations approved by Ofqual for end-point assessment.  Based on this analysis, there would therefore be up to 250 organisations on the RoEpAO who would need to be approved under Ofqual criteria for recognition, should the consultation recommendations be adopted!  

So how does an EpAO apply to Ofqual?

To apply for recognition (which can be done at any time), EpAOs must refer to the Ofqual application guidance and the supporting information document . You can find out more about applying, including Ofqual webinars, here.  Organisations will be given an introductory meeting with an Ofqual officer after registering.

EpAOs must comply with the “General Conditions of Recognition” known as the Ofqual handbook, there are some general conditions which do not apply to End-point Assessment, as detailed in the Ofqual rules for end-point assessment .  They must also comply with the Ofqual EPA qualification level guidance.

I spend a lot of my time advising organisations on how to navigate the Ofqual process, and I have to admit that the level of bureaucracy, some unnecessary, amazes me. I can see so much scope for simplification without impacting on quality.  I have provided feedback to Ofqual, but I am told that there are many things bound by legislation which can’t simply be changed. I absolutely agree with that sentiment, however, there are parts of the Ofqual process that are confusing and are not related to the legislation, so here is a list of my top 10 things Ofqual can do to make the application smoother and more user friendly without impacting on the legislation or quality:

1. Improve the messaging

I have repeatedly heard that potential applicants have been told “you are unlikely to get through first time”, and I have been told (although I have no evidence of this) that only 2 organisations have ever got through on their first application. What sort of message does that give out to organisations looking to apply to Ofqual, and what sort of picture is it painting about Ofqual? It neither encourages organisations to apply, or provides confidence in the level of support or responsiveness.

2. Ensure clear, consistent, and publicly availably advice

One of my clients was recently informed that they could not apply to Ofqual because they did not end-point assess a standard that was EQA’d by Ofqual.  An organisation cannot apply to the ESFA to become an EpAO, for a standard EQA’d by Ofqual, until it is approved by Ofqual, so how is it possible for them to wait to apply to Ofqual until after they are approved on the RoEpAO?! There is no information about this approach on the ESFA or Ofqual website, so whatever the current approach is by Ofqual, it requires clarity and communication.

The introduction to the register of end-point assessment organisations states thatWe do not assess applications from organisations not permitted to deliver end-point assessment by the assessment plan. For example, where the assessment plan states Ofqual will be the external quality assuror, we will only accept applications from organisations who meet Ofqual’s General Conditions of Recognition”.

Another organisation had their application returned and were told their application would not be reviewed further because they had said they would not be designing and delivering qualifications, but that they would be designing and delivering end-point assessment.  Ofqual uses the word ‘qualification’ as their legal term for end-point assessment, and because the applicant had said they would be designing and delivering end-point assessment, and not qualifications, their application was returned. It has since been resolved, but it caused unnecessary delays to the process.

3. Use plain English

The wording of the Ofqual documents is very complex and hard to understand. I am regularly contacted by organisations asking for help in interpretation. Yes, there are certain elements of a legal nature, but the explanations need to be written in a clearer more user-friendly way. When I am designing and testing end-point assessment materials with industry experts, my golden rule is that if people can’t understand, or misinterpret, what is written, it means it needs re-writing.

4. Rationalise the number of documents

Ofqual has multiple documents (at least 5 to read and reference when applying as an end-point assessment organisation). These are spread across multiple webpages, making navigation difficult and risking an organisation missing a key document when writing their application.

5. Remove duplication

When applying to the RoEpAO, an organisation must provide copies of certain policies.  It would be hugely beneficial if Ofqual took into account the information that had already been supplied and explained to the ESFA in the RoEpAO applications. This is covered in the IfATE consultation document, so, if the proposals are accepted the duplication should be removed.

6. Match the Ofqual application form codes to the Ofqual conditions codes

Currently the codes between the Ofqual conditions and the Ofqual application form do not match, making the application process unnecessarily confusing, for example:

  • A4 in the application is “organisation governance”, in the conditions A4 is “conflict of interest”
  • A5 in the application is “conflicts of interest”, in the conditions A5 is “Availability of adequate resources and arrangements”
  • A6 in the application is “governing body oversight”, in the conditions A6 is “Identification and management of risks” (note - there is no section in the Ofqual general conditions handbook entitled governing body oversight)
  • B2 in the application is “integrity of senior officer”, in the conditions B2 is the “annual statement to Ofqual”
  • C in the application is “resources and financing”, in the conditions C is the “arrangements with third parties”

7. Ensure the Ofqual application questions relate to the conditions

One of the application questions asks for governing body oversight, and I have seen an Ofqual rejection letter saying “your governing body is not identifiable in your organisation structure”.  However, the conditions themselves do not require a governing body, they require governance, which is different. I wrote an article on this earlier this year, which may help the understanding https://www.fenews.co.uk/featured-article/40671-an-introduction-to-Ofqual-for-micro-end-point-assessment-organisations

8. Explain what is meant by ‘Centres’ and what is expected within the Ofqual application

Currently the EPA qualification level guidance defines a centre as follows – “A Centre is any organisation that delivers part of a qualification on behalf of an awarding organisation. In an EPA context an employer that delivers or marks an assessment or part of an assessment will meet the definition of a Centre”.

End-point assessment cannot be subcontracted/contracted out (as stated in the conditions for EpAOs section 3.5), and in the vast majority of end-point assessments, the employer plays no part (end-point assessment is independent), so presumably for the majority of applications there would be no ‘centres’.   The Ofqual guidance states that condition C2 would not be applicable in these circumstances, but the use of the word ‘centres’ is referenced across a large proportion of the Ofqual conditions, not just C2. Would Ofqual therefore accept ‘not applicable’ across the other conditions that refer to ‘centres’? 

9. Ensure the Ofqual requirements for assessment expertise reflects the apprenticeship assessment plan

The application, quite rightly, asks for details of the skills, knowledge and experience of staff in the development, delivery and award. 

I have seen an Ofqual rejection letter, with one of the rejection reasons being: “there appears to be no evidence that the staff have assessment expertise”. 

Whilst this may be a legitimate question is it a legitimate reason for rejection? There are some assessment plans that do not require assessors to have assessor qualifications, instead they require them to have vocational qualifications and industry experience.

If an organisation only ever wishes to assess an apprenticeship with an assessment plan that does not require qualified assessors, is that a reason to reject it? I guess it depends on whether assessment expertise is deemed to be the same as assessor qualifications, but I felt it was worth raising.

10. Scalability

Of the 281 EpAOs, 62% end-point assess just 1 or 2 apprenticeships.  These organisations will not have large staffing contingents or governance structures, but it does not mean that they are not high quality or fit for purpose. Ofqual conditions and their application process, needs to be able to reflect the size of the organisations that will be end-point assessing. 

This is not about making it easier or less robust for small organisations, it is making sure that the Ofqual requirements are deliverable for small and micro end-point assessment organisations as much as they are deliverable for large scale awarding bodies.

I know some of my thoughts may be controversial, but I am passionate about quality, transparency and deliverability (and as you can probably tell, minimising bureaucracy!). If this article helps to ‘shake’ things up a bit to ensure Ofqual conditions are fit for end-point assessment, and encourages and enables more EpAOs to apply for Ofqual recognition, then I see it as a positive step to quality and consistency across apprenticeship assessment.

Jacqui Molkenthin, JEML Consulting

If you would like to know more about end-point assessment, I have authored a range of articles that you may find helpful:

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