Since Innovate Awarding became approved to be an End Point Assessment Organisation (EPAO), we have been banging the drum for clarity on roles and responsibilities and for consistency of approach – particularly for resits, retakes and cancellations. These are areas I fully believe should not be competitive differentials – they must be applied consistently across all EPAOs.
Other EPAO FAB members have supported our lobbying for this clarity and consistency so it was great for all of us to see the new guidance issued from ESFA on apprenticeship gateway and resits for end point assessment (EPA). However, the first question asked by my Head of Compliance was, ‘is this guidance or is this statutory guidance?’ For those who have been in the awarding sector for a long period of time, in Ofqual-speak this determines whether we might wish to apply the guidance, or whether we have to apply the guidance. This question is still being debated within Innovate. This is certainly not a criticism of the guidance, which is welcomed, but I think it is fair to say it has led to further questions and areas for clarification. To an extent, it has raised concerns about how some of the ‘rules’ can be enforced.
The guidance really puts an emphasis on ensuring that providers and employers engage with an EPAO as early as possible in the process and that a confirmed gateway is established three months ahead of this taking place. In reality, this is a process that a number of EPAOs have had in place for a while and a drive towards consistency in approach is fantastic. But in practice, will this aid a change in behaviour to allow EPAOs to better plan and prepare? If this guidance is not adhered to, will ESFA have any consequences for employers or providers? I assume not, so will this practice really change?
Who is responsible for passing an apprentice through gateway? The guidance clearly sets out the responsibilities of the employer, provider, EPAO and apprentice. For the employer and provider, it states that they should ensure the apprentice is displaying occupational competence, meeting the gateway criteria, and is ready to complete their final assessment. This makes perfect sense.
Within the responsibilities for the EPAO, it states that ‘they must have in place a process for checking with the employer and provider that the apprentice has met gateway requirements’. This is a point that FAB members have previously raised – how much checking should take place? Is a signed declaration acceptable? Should all certificates for gateway requirements be made available? How can we really know whether minimum duration is met? This is one area that would really benefit from further clarity to ensure we all implement the same practice.
The final area to mention is the guidance relating to resit costs. It is worth me quoting the wording:
"The employer has responsibility for the majority of their apprentice’s training. Employers are expected to financially support apprentices until completion, including paying the cost of resits, when necessary. Resits are ineligible costs and are not funded by the ESFA. The EPAO and training provider are not responsible for resit costs but may agree to contribute and can include this in their agreement at the beginning of the apprenticeship".
This sounds very messy, don’t you agree? We are in danger of getting involved in debates with employers and providers for any apprentices who pass gateway but are then not successful. Yes, it states that gateway readiness is the responsibility of the employer and provider, but I can predict the tension and this can only lead to resit charges not being paid. Having seen the guidance, we reached out to a number of employers we work with to gain a view. The findings were interesting. Of 74 employers, 50 per cent had worked with providers to factor resits into contracts, whereas the other 50 per cent wished to be charged directly for resits to have full control and visibility of these costs. Let’s hope I am wrong, but I can see this leading to unpaid invoices and further confusion for employers.
So, in short, the guidance is welcomed but a bit more work is required to make sure we are all applying the guidance (if it is statutory guidance) consistently.
Charlotte Bosworth, Managing Director, Innovate Awarding
Charlotte is Managing Director of Innovate Awarding. Charlotte was previously Director of Skills and Employment at OCR Examinations/Cambridge Assessment. Charlotte’s career within Education commenced in 1996 with RSA Examinations Board and she has vast experience in curriculum, assessment and qualification design.
This blog originally appeared in EPA Weekly, published by the Federation of Awarding Bodies. Find out more and subscribe here.