David Lockhart-Hawkins, Compliance Expert, Strategic Development Network (SDN)

@SDN_HQ - Universities across the UK are expected to have a significant drop in income from international students in 2020-21 because of the Covid-19 pandemic. To mitigate this loss of income, many HEIs are looking at how an improved degree-apprenticeship offer this autumn could soften the financial blow and support businesses retrain their workforce for a ‘new normal’.

But what are the risks of deploying an expanded degree-apprenticeship offer? We ask SDN’s compliance expert, David Lockhart-Hawkins, to outline the degree-apprenticeship opportunities for HEIs and what compliance issues to be wary of when implementing or growing a degree-apprenticeship offer...

What is the business case for HEIs having a serious look at degree-apprenticeships over the coming months?

“As organisations re-open following the Covid-19 pandemic, many will be determined to create a more efficient and effective workforce, to help them through a difficult period. Degree-apprenticeships will be an attractive offer for a large proportion of these businesses who want their staff to learn high-level skills – to keep their business innovating and adapting, whilst improving staff retention and satisfaction by paying for their employees to gain graduate qualifications.

“Not only can HEIs work with levy-paying employers (who may have unallocated levy-credits in their account), but with smaller businesses too – as the digital apprenticeship service opened to all employers at the start of the year.

“The ability for all main providers to enrol non-levy employers’ apprentices has not been fully utilised. This ‘non-levy’ opportunity, aligned with a ‘levy offer’ will be a vital way for HEIs (and all providers) to deliver effective employer and student solutions.

“This is particularly true at higher levels of apprenticeship, where the substantial learning and development programme can be used by employers to offer what would be an improved salary package (i.e. an employer explaining they’re funding a several thousand pound degree alongside salary or in lieu of salary increases).”

Why is it important to consider compliance before implementing or growing a degree-apprenticeship offer?

“HEIs shouldn’t be put off of looking at expanding their degree-apprenticeships this autumn, but they must continue to be conscious of the risks of non-compliance. SDN has worked with dozens of HEIs and we’ve always found a need for there to be a development journey i.e. we uncover a risk that exists at the start of our work and have a process for mitigating it by the end.

“I go so far in my workshops as saying there are two types of HEIs delivering apprenticeships:

Those that know they have a compliance risk
And those that do not yet know they have a compliance risk.
“The apprenticeship product (although it may contain the degree award that is so familiar to HEIs) has numerous unfamiliar compliance steps that are often left to be picked up by individuals in underdeveloped administrative functions, which is where things can go wrong further down the line.

“For an HEI, the risk isn’t purely financial, as in a bad audit and clawback. The protection of reputation often outweighs any immediate financial penalty. Most procurement tenders will include a key scoring question relating to audit performance and a bad result in-year could significantly affect long-term success in tenders. Although this information is not made public, there is risk of reputational damage as a result – certainly in the eyes of the key individuals choosing the apprenticeship provider to work with.

“Beyond that big picture, there is the financial picture; you want to ensure that any revenue earned is kept. This means that the training price you apply must be accurate and that the end-point assessment (EPA) price you apply (within your overall price) is also accurate. If that last sentence doesn’t make sense to you, it is likely you have a current funding error!”

What are the main compliance considerations HEIs delivering degree-apprenticeships should think through?

“HEIs must ask themselves...

Is there a risk that current systems and controls are not effective in capturing core evidence? For example, when apprenticeship agreements are separate from commitment statements, or where the apprenticeship agreement is inconsistent with other documents as far as dates, durations and off-the-job hours. In a nutshell, are the off-the-job hours clearly designed and evidenced?
Is there full awareness and tracking of engagement evidence? Though often held in well-developed learning management platforms, such as Moodle, Canvas or Blackboard, collating this and being aware of disengagement or unfulfilled off-the-job hours is a significant operational risk.

Are we confident we have an up-to-date understanding of the ESFA’s compliance expectations in an HEI context? It isn’t easy to get compliance right. There are no perfect systems. The post-May 2017 funding system changed the evidence expectations substantially. At the same time, the ESFA apprenticeship auditors experience of HEIs is limited. Degree-apprenticeships have not existed for that long and very few monitoring activities having occurred, which means auditors may not yet know the common evidence that could be obtained and the HEI team may not know what they could present. Having your programme looked at by people that understand apprenticeship compliance in an HEI context is a very good idea and should give you the evidence you need to prove compliance and retain funding.
“Ultimately, there are significant opportunities for delivering an expanded degree-apprenticeship offer, but there are risks. We encourage HEIs to engage in the opportunities because the quality of delivery is often exceptional, however quality does not always mean compliance. The key is engaging in the opportunity, and having the confidence that your funding will be secure.”

Further support
Led by David Lockhart-Hawkins, SDN has worked with dozens of HEIs across the country to set-up, grow their provision and establish robust funding and compliance systems. We provide tailored support to HEIs, to help you:

  • Understand ESFA funding, systems and processes
  • Set-up effective data, funding and compliance systems
  • Sample the quality of your data, reduce errors and avoid claw-back
  • Establish evidence collection systems that helps to drive quality provision
  • Design effective Skills Gap Analysis tools and practice

    If you’d like to know more, do get in touch: This email address is being protected from spambots. You need JavaScript enabled to view it.

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