This guidance aims support End-Point Assessment Organisations (EPAOs) to provide reasonable adjustments within the end-point assessment process for apprentices with additional support needs.
The matrix, based on the Higher Education Statistical Authority’s (HESA) disability grouping framework, will help support EPAOs in making appropriate and consistent judgements and provide a valid, reliable and manageable approach to supporting apprentices.
1. Reasonable adjustments
A reasonable adjustment relates to an adjustment that helps to reduce the effect of a disability or a physical or mental health condition, which may place the apprentice at a disadvantage compared to others.
Employers, training providers and EPAOs must make reasonable adjustments to ensure apprentices with disabilities or physical or mental health conditions aren’t substantially disadvantaged during training, assessment or when doing their jobs. This is a required duty as part of the Equality Act 2010.
During the end-point assessment the types of adjustments offered may include, but aren’t limited to, changes to elements such as:
- the location and timing of the assessment
- the format, wording or type of assessment activity
- the availability of support personnel for additional needs
- the availability of adaptive software or hardware, or specialist equipment
These adjustments should mirror the types of reasonable adjustments and additional support that the apprentice has received from their employer and/or training provider during their apprenticeship programme.
It is important that reasonable adjustments do not affect the reliability or validity of assessment and they should not give the apprentice an advantage over other apprentices undertaking the same assessment. More information on reasonable adjustments can be found on Gov.uk.
In addition to this, the EPAO will support apprentices by ensuring that:
- The reasonable adjustments provide apprentices with the opportunity to demonstrate attainment against occupational competence;
- The assessment is reliable, and any person using the apprenticeship certificate to identify an individual’s competence can have confidence in their skills and abilities;
- The assessment process is rigorous and fair, and the assessment activity is valid;
- The assessment is practically able to operate within available resources, following the application of any reasonable adjustments;
- Facilities and time allow apprentices to use any commercially available mechanical, electronic or other aids in order to demonstrate achievement so long as they reflect the apprentice’s normal ways of working and do not give the apprentice an unfair advantage.
2. Putting reasonable adjustments in place
This matrix will support EPAOs in applying appropriate and consistent judgements and is based around the Higher Education Statistical Authority’s (HESA) disability grouping framework. Each of these difficulties/disabilities have then been overlaid with the listed assessment methods to ensure the most suitable adjustments are applied for each situation and for each assessment method determined in the end-point assessment plan without changing the demands of the assessment.
These are recommendations only, and it is essential to use this matrix from an apprentice centred perspective on a case-by-case basis. Each assessment will be subject to some variance due to job role, employment context and apprentice support needs, and should be adapted as necessary. The support need for a particular person will be unique to that individual, and may not be listed as a need in the relevant category in the disability grouping framework, so flexibility is required. It is also important to remember that appropriate adjustments are likely to be a continuation of the additional support that the apprentice has received during their apprenticeship.
Employers and training providers should work collaboratively with the apprentice and the EPAO to determine the appropriate reasonable adjustment. They are advised to seek clarification from their EPAO in any case where they consider that they do not have the necessary expertise to judge whether a reasonable adjustment is required.
The outcome produced by the apprentice must at all times:
- meet the requirements of the occupational standard regardless of the process or methods used;
- be as rigorously assessed as outcomes generated by other apprentices;
- be assessable;
- be a valid measure of occupational competence; and
- be able to be moderated or verified.
It is not necessary to obtain approval from the ESFA prior to putting reasonable adjustments into place for an apprentice.
Applying to the EPAO for flexibilities
This process should begin as soon as the employer is aware that the apprentice is likely to need to access reasonable adjustments for the end-point assessment.
In all cases, the employer, with input from the training provider and the apprentice, must apply to their EPAO for reasonable adjustments to be applied to the end-point assessment. Evidence of the difficulty/disability will be required to support the application, along with evidence of any existing adjustments or additional support provided by the employer or training provider. These should also be kept for any future audit.
They should complete the EPAO’s reasonable adjustments application form and return to the EPAO who will aim to confirm a decision regarding reasonable adjustments within 21 working days of acknowledging the request.
As it is a legal duty the EPAO may only reject applications for a reasonable adjustment in circumstances where:
- Any adjustment may create a serious loss of validity or independence within the assessment process.
- Any adjustment may constitute a serious safety hazard that cannot be reasonably
EPAOs are required to keep a record of any reasonable adjustment applications, the decisions they have made regarding these applications, the reasons for making any changes and any appropriate evidence behind the decision. All reasonable adjustments must also be recorded on the apprentice’s registration.
Any records pertaining to the implementation of and/or rejection of reasonable adjustments records should be retained and be made available to EQA Providers when requested.
During the apprenticeship the employer and training provider must make reasonable adjustments to ensure any apprentice with a disability or physical or mental health condition is not at a disadvantage compared to their peers. To do this they may be eligible for additional support through DWP Access to Work funding, which provides support with everyday employment difficulties that are not directly associated with the apprenticeship programme, or the ESFA Additional Learning Support (ALS), which is available to fund apprentices who require extra support to meet the learning goals of their apprenticeship.
In many cases reasonable adjustments will be put in place and funded by the EPAO, as they are classified as an eligible cost that should be reflected in the price negotiated between the employer and the EPAO. The EPAO guidance setting out the conditions for registration explains this in more detail.
In some circumstances, there may be some substantial additional costs associated with providing reasonable adjustments during the end-point assessment process. These should be agreed between the employer, training provider, apprentice and EPAO in advance to ensure that they are appropriate and proportionate. These may be funded through ALS if they meet the criteria of additional support that enables the apprentice to demonstrate how the apprentice meets the occupational competency requirements.
The funding should be claimed by the training provider through the ILR using the standard ALS process and must be evidenced in the same way and to the same standard. These records must be kept for audit purposes. Funding found to be claimed for unnecessary or inadequately evidenced support may potentially need to be repaid to the ESFA.
If an apprentice, for any reason, considers that they have been wrongly refused access to fair assessment and wishes to appeal, they should follow the EPAO’s appeals policy and procedure.
If an employer for any reason, considers that their apprentice(s) have been wrongly refused access to fair assessment and wish to appeal, they should follow the EPAO’s appeals policy and procedure.