Since the outset of the #ApprenticeshipReforms, @AELPUK has pushed hard in terms of raising concerns about the fragmented approach to external quality assurance of the end point assessment system. Therefore we were obviously pleased to see last week’s confirmation to ‘strengthen and simplify’ EQA by making Ofqual the main regulatory body for EQA, supported by OfS on integrated degree apprenticeships.
The role of both end point assessment and external quality assurance cannot be underplayed and it was a key component in the Richard Review of Apprenticeship in 2012 which recommended that … “The testing and validation process should be independent and genuinely respected by industry…. Employers should be directly involved in assessment…The Government, a government body or regulator should approve and oversee the assessment process….”.
At the start of the reforms, the government’s position was about giving employers choice on the matter – a choice which came in four different shapes and sizes: professional bodies, employer-led groups, Ofqual or IfATE, although IfATE subsequently subcontracted out the service.
External quality assurance providers (EQAPs) should play a key role in both supporting and developing the EPAO providers, but also in holding them to account. It is critical that the quality of assessment outcomes are comparable, high quality, consistent and robust. Without this, it would devalue the whole apprenticeship system for providers, apprentices and their employers.
The early concerns raised by AELP centred on the lack of quality assurance expertise in a number of the external quality assurance providers, the cost of some of these service provided (taking funding away from frontline delivery) and the fact very few had any regulatory powers to enforce action. Clearly this was not a good mix.
The 2-year transition
Following last week’s welcome announcement, the hard work begins now with a two-year transition period. For starters, a significant number of EPAOs are not recognised by Ofqual and will need to undertake a rigorous and extensive recognition process similar to that of an organisation aiming to become an Awarding Organisation. Some non-Ofqual recognised EPAOs have expressed concerns about this and some have said they will consider their future position within the EPA marketplace.
We are aware of examples of EPAOs already going through the Ofqual recognition process and it was apparently both robust and challenging, but they were well supported during it. A number have now been approved and are willing to share their experiences. Further plans are rightly being put in place to support these EPAOs because it’s critical we don’t lose the high quality ones, especially where we have some niche standards with only one EPAO approved. That said, the Ofqual recognition process needs to ensure all EPAOs are not only fit for purpose but are the ‘gold standard’ which our apprentices deserve.
We have seen in the past some trailblazer groups shy away from Ofqual as their chosen EQAP as they couldn’t agree on the assessment plan. Part of the transition phase will no doubt see a few interesting conversations on this bubble to the surface, but at least there is time to work these through. Moreover the changeover will start to smooth out some of the unhelpful or unwitting nuances baked into some of the assessment plans by employer groups.
IfATE’s announcement also ensures that employers still have a role in EQA, recognising that Ofqual will need support and occupational expertise to cover the significant range of occupational standards. Having an employer register helps ensure appropriate assessment and external assurance expertise along with a pool of occupational expertise too – finally providing the right ingredients for successful regulation which were missing from the current system.
Reducing EQA costs
Lastly the announced changes address the cost of EQA. The significant simplification will not only reduce bureaucracy but will ensure better value for money and more of the funding going towards high quality training and assessment.
Currently IfATE approves the EQA charges which EQAPs can quote, as defined in their letter of recognition, although these vary significantly with some EQAPs not charging for their services, some charging a fee per apprentice and others also charging annual fees per EPAO in addition to a fee per apprentice.
Moving forward, the EQA cost will be top-sliced from levy revenue as opposed to the EQAP billing the EPAO, the EPAO billing the provider and the provider having to either absorb that or pass that cost onto the employer. We’re definitely looking at a simpler and much more sensible system.
Simon Ashworth is chief policy officer of Association of Employment and Learning Providers (AELP)