Let’s invest properly in them and simplify the quality assurance regime, argues TOM BEWICK.
One of the newest aspects of the apprenticeship reforms is end-point assessment. The Richard Review used a neat analogy in making the case for a final competence-based examination at the end of an English apprenticeship standard.
When adults learn to drive they have a choice of which driving schools to enrol. How many lessons they will take depends of course on the aptitude of each learner driver. But every novice will have to pass a universal theory test and a practical examination when ready, undertaken by an independent examiner.
Crucially, the examination centre works to a single standardised quality assurance framework. And ultimately, the Department of Transport, with advice of DVLA, is accountable for road safety in this country.
The IFA boss, Sir Gerry Berragan, has built on the analogy by telling the Education Select Committee recently that it is right: “training providers do not mark their own homework.”
He has gone a step further arguing that the credibility of the entire reforms hinge around getting end-point assessment right. That’s because if the quality of apprenticeship training can be guaranteed in terms of an individual reaching the same standard, irrespective of where they work, then it should secure employer confidence in the system.
Like any new approach there have been some teething problems. After all what we are seeing is the operation of a nascent marketplace. Some providers may not be happy with the fact they can no longer mark their own homework. Without fear nor favour, end-point assessment bodies must apply the assessment plans drawn up by employer groups with rigour.
This is a wholly new aspect of the apprenticeship system so it is too early to pass judgement on its efficacy until an entire cohort has gone through each new standard. In a number of cases employers have enrolled apprentices on standards for which there is, as yet, no approved end-point assessment organisation (EPAO).
However, there are clearly some early lessons to take on board as well as some principles the awarding and end-point assessment community would like to see policymakers sit up and take notice of.
It can be boiled down to four key things:
- Public confidence being put centre-stage in these reforms
- A genuine level playing field in the marketplace
- A clear line of sight in terms of accountabilities
- A single quality assurance framework that everyone adheres to.
The overriding principle must be one of securing maximum public confidence in the assessment and quality assurance of apprenticeships. The marketplace for EPAOs is no different from the market for colleges, awarding organisations and training providers.
Assessment organisations are required to be on an approved register currently held by the Education Skills Funding Agency (ESFA). Choice in the marketplace drives competition, which is why employers can choose from an approved list of EPAOs.
Where public confidence could be really undermined, however, is when the criteria governing registration is not applied stringently enough; or where new organisations come into the market with little or no track record of vocational assessment and awarding but see EPA as purely a revenue generator.
This is potentially exacerbated by a lack of transparency about the pricing mechanism where EPAOs are still finding out the true cost of delivery, including what margin they can ‘negotiate’ with providers or employers. There is currently an accepted upper limit on the price of EPA, but no lower limit, opening the door potentially to EPAOs undercutting on price simply to win market share or knock others out of delivery.
By far the easiest way to undermine public confidence in any quasi-regulated market is when it is unclear where the buck stops for guaranteeing quality in the system.
Who gets to walk the proverbial plank in two years’ time if quality in apprenticeship is still found to be wanting? Is it the IFA, ESFA, Ofqual or Ofsted?
The advent of end-point quality assurance (EQA) is meant to address such a challenge. But one major complexity is that there are already five different EQAOs sitting in judgement of EPAOs. This number is set to grow significantly. In addition, the IFA, with its contractor Open Awards, as well as Ofqual undertake EQA on certain standards.
So back to the driving test analogy. There is clearly a marketplace for diving schools and instructors. Driving examiners, often former instructors, can offer their services to DVLA testing centres.
But here’s the crucial difference with EQAOs: there is no competitive marketplace in quality assuring the overall integrity of our driving licensing system.
The buck stops with the Department of Transport and DVLA who must police the system so that our roads remain amongst the safest in the world. In other words, it is properly regulated like the financial services sector and most qualifications.
Of course, all this adds up to robust public confidence in the driving licensing system. Why? Because the Highway Code (revised from time to time) acts as the single quality framework against which all driving standards in this country are measured.
The big contradiction of EQA currently is that it is unclear what quality assurance framework they are all working to. And just like adhering to the rules of the road; if regulatory bodies are not being consistently held to account for applying the same rules evenly then it opens up the whole system to the charge of systemic risk.
In consideration of these obvious design flaws it is time for Ministers to insist on the implementation of a single EQA framework; even if it remains that more than one body delivers end-point quality assurance. Such a framework, with the aim of maximising public confidence, should ultimately be owned by a single public body accountable to Parliament.
The Federation of Awarding Bodies and other representative organisations have already made this point.
Graham Hastings-Evans, group managing director of NOCN, has put it thus:
“As well as the lack of clarity over Ofsted’s and ESFA’s roles for training providers, EQA for end-point assessment (EPA) is equally bewildering, bureaucratic and costly.
"The role is currently split between IfA, Ofqual and five independent EQAOs; doing it differently, with no consistency, no common rules and different charges. This will get worse as the number of EQAOs is expected to grow to 40.”
Level playing field
Markets can only work efficiently when there is a level playing field on which organisations can participate. The fact that some EQAOs are charging fees and others not, as well as variable practices in terms of the quality and implementation of assessment plans, has made it more difficult for awarding and assessment organisations to plan effectively.
While the idea of negotiated prices sounds laudable in the context of giving employers market choice, the recent announcement of new funding bands suggests the government’s overall aim is simply to cut financial support to apprenticeship standards. Given the teething issues and complexity of what is still an immature market, this is probably the last thing policymakers should be doing.
Instead, the IFA advising DfE should be working more closely with awarding and assessment bodies to ensure this new aspect of the apprenticeship reforms is able to bed in without precipitating a funding crisis.
One of the main drivers of the apprenticeship reforms in 2012 was to streamline the accountability for apprenticeship. The fact primary legislation was enacted to establish the IFA, as well as other measures were taken to boost quality, demonstrated a cross-party commitment to putting England on the path to world-class technical education.
But the reality is that the new system architecture was grafted onto some old ways of working. These inherent contradictions were on full display at the select committee hearing where the senior accountable officers from ESFA, IFA and Ofsted could not really answer MPs questions about where the line of sight for quality in apprenticeships, provided by Parliament, both began and ended. Instead what we have at the moment is a set of competing institutions and muddled policy accountabilities.
Take the issue of the EPAO register and the funding of apprenticeships provided by the Apprenticeship Service. This currently sits with the ESFA. However, the logic of the 2012 reforms would suggest that this function would sit more appropriately with the IFA.
That’s because without the IFA having both the registration and funding responsibility; as well as a direct line of site to the employers, it is hard to see how the levers at their disposal in providing overall leadership of the apprenticeship system can be truly effective. This would still leave Ofsted with a role to independently check on the quality of provider training; as it would Ofqual in terms of the regulated awarding community. Moreover, when you look at our major competitors it is clear they vest both the funding and overall leadership of their apprenticeship systems in a single public body.
Single quality assurance framework
All these challenges in implementing the new end-point assessment and quality assurance reforms, points to the urgent need for the development of a single quality assurance framework. The fact is many awarding organisations have already invested a huge amount of money and expertise in ensuring the model of independent assessment is a success. It is time to really harness the sector’s expertise and listen to what EPAOs are saying about their experience on the front-line. There is simply too much at stake to get this wrong.
Tom Bewick is the chief executive of the Federation of Awarding Bodies