In 2021 we consulted on degree apprenticeships policy. Our response to the consultation detailed changes to how degree apprenticeships will be developed and delivered. These changes are being introduced over a transition period from March 2022 to September 2022.
The changes will ensure that:
The changes involve:
The new policy is being introduced via a transition period. During this period, trailblazer groups can apply the existing policy or this new degree apprenticeship policy for occupation proposals, occupational standards, and EPAs submitted into our approvals process.
This means that, for any new or revised apprenticeship being developed under the outgoing policy, the draft occupational standard and EPA plan will need to have been submitted by the 13 July submissions deadline (cycle 42) at the latest. However, if such a submission is returned rather than approved, we will still accept a resubmission based on the outgoing policy after cycle 42 until it is approved.
The introduction of the new policy does not mean that all existing degree apprenticeships need to be compliant with it by September 2022. Instead, they will need to become compliant as and when revisions to them are submitted from September 2022 onwards. Such revisions could be triggered either by us following a route review or by a stakeholder via our revisions, adjustments and dispensations (RAD) process.
For any submissions during the transition period, we recommend that you discuss which policy to apply with your product manager (PM).
There is no requirement to mandate a qualification in a Level 6 or Level 7 apprenticeship. However, it is possible to mandate a degree where this is desired by employers, subject to certain criteria being met. Under the outgoing policy, the same criteria for mandating a qualification apply to all levels of apprenticeship. Under the new policy, a single new criterion, focused on current labour market requirements, is used to determine this for degree apprenticeships as follows:
To determine whether an occupation is a degree or master’s level entry occupation, we will use the following evidence sources:
These data sources are available in a consolidated form broken down by SOC code in our mandated degree evidence tool here. Your product manager (PM) can help you to interpret the data.
We may add other data sources in the future, including any new academic research which becomes available. We are also exploring the use of comprehensive job advert data sourced from websites. This could be matched by occupation or job title and show the proportion of jobs for which a degree is required. We will update this guidance as necessary to reflect the addition of any new standard evidence sources.
We will make decisions on mandating degrees based on evidence of current labour market practice. This is to avoid the risk of inadvertently changing the market norms and narrowing opportunities to enter an occupation which could occur if we agreed to mandate a degree where this was not the current market norm.
The trailblazer group can also provide additional evidence. You may wish to do so particularly where you believe the occupation is emerging or evolving, potentially making standard historic data sources less relevant. We will consider any evidence that meets all the following criteria:
Under our new approach, the formal decision relating to mandating a degree in a new apprenticeship is taken by the Institute following advice from the relevant route panel when the occupation proposal is submitted. This will provide the clarity needed before development of the integrated end-point assessment (EPA) plan. However, in the majority of cases, based on discussions between the trailblazer and your PM, we would expect to be able to provide a strong steer on the likelihood of the Institute agreeing to a degree being mandated, prior to your trailblazer submitting its proposal.
We are in the process of making revisions to the apprenticeship builder to reflect this. In the meantime, please liaise with your PM on the case for mandating a degree in advance of submitting an occupation proposal and submit any evidence you wish to support this case directly to them.
For revisions to existing Level 6 and Level 7 apprenticeships, the submission of an occupation proposal is not generally required. This means that the formal decision on whether a new degree can be mandated will continue to be taken by the Institute following advice from the relevant route panel when the revised occupational standard (and EPA plan) is submitted. However, as above, we would normally expect to be able to provide a strong steer prior to submission.
There may be some scenarios relating to Level 6 or Level 7 apprenticeships in revision where the case to mandate a degree appears finely balanced. In any such case, we may recommend that we test it out with the relevant route panel and officials before you invest time in revising the occupational standard and integrated EPA plan.
This is primarily a delivery stage issue and does not directly impact on your development of the apprenticeship. However, it is nonetheless helpful if both employers and Higher Education Providers (HEPs) involved in your trailblazer group have in mind the need for effective integration of on- and off-the-job training during this process.
Effective integration of on- and off-the-job training already happens in many cases. To support its application, we are developing best practice case studies and will make these available when ready.
The effectiveness of integration is covered in Ofsted’s evaluation schedule used to determine grades as a result of inspections. Ofsted is therefore able to use its “deep dives” undertaken on inspections to identify any concerns about providers’ training and the extent to which it is effectively integrated with the on-the-job training.
Similarly, it may be possible to identify any such concerns through the Office for Students’ (OfS) risk-based quality monitoring of providers.
Degree apprenticeships work best when all elements of learning contribute to the award of the degree qualification, the achievement of the apprenticeship and the realisation of employers’ expectations of a competent individual.
To support this, under the new policy, the degree learning outcomes must be aligned with the knowledge, skills and behaviours (KSBs) in the apprenticeship standard. This is a key change, as it requires the development of bespoke degrees to support a degree apprenticeship.
Given the need for alignment, we now require any trailblazer developing a degree apprenticeship to fully involve relevant HEPs in the apprenticeship development process. This will ensure that delivery practicalities are considered at an early stage. We recommend that at least three HEPs intending to deliver an aligned degree are involved in this way.
We recognise that employers place significant value on certain KSBs that could be regarded specifically as ‘graduate attributes’ such as critical thinking. Where this is the case and where such attributes are regarded as necessary for occupational competence, it is important that they are covered in the KSBs. They can then be covered in any degrees developed to help deliver the apprenticeship.
The identification of such attributes may occur naturally as part of your trailblazer’s process of identifying all KSBs relevant to the occupation. However, the following sources of information may also help to guide you:
If the KSBs are defined too narrowly, with this reflected in the aligned degree(s), a successful apprentice could be disadvantaged in terms of potential progression compared to someone who has undertaken a slightly broader degree outside of an apprenticeship. Whilst this could be balanced out by the greater on-the-job competence that the apprentice will have acquired, we nonetheless recognise the risk.
However, our “transferability” criterion for approving occupation proposals requires that the occupational standard is “transferable to a range of other employers and secure long-term earnings potential, greater security and capability to progress”. This means that it is legitimate to include some KSBs intended to lay the groundwork for future progression as long as they are still relevant to the occupation covered by the apprenticeship. Anything included in the KSBs can then be included in degrees aligned to the apprenticeship.
The titling of any degree developed to help deliver a degree apprenticeship is a matter for the HEP rather than the Institute. However, we would expect any degree title to always include the name of the occupation covered by the apprenticeship. This is intended as a helpful consistency for learners seeking to enter the occupation and being able to recognise the associated degree apprenticeship.
The reference to the mandated degree in the apprenticeship standard should be along the lines of “a [insert name of occupation] degree/master’s degree that fully aligns with the KSBs within the apprenticeship standard”.
Any new degree version of an existing Level 6 or Level 7 apprenticeship will replace the previous version for new starts in line with our notice period guidance in section 3 of our Revisions, Adjustments and Dispensation guidance. We recognise that any such notice period will need to be sufficiently long to enable HEPs to develop and secure internal approval for their aligned degrees. It is therefore important that the HEPs involved in the revisions process are also involved in consideration of how long the notice period should be.
Any HEP delivering a degree as part of an apprenticeship needs to be on the Register of apprenticeship training providers (RoATP).
A concern about the alignment of degree learning outcomes with an apprenticeship’s KSBs may also be a concern relating to compliance with the OfS’s conditions of registration. The OfS has now published revisions to its ongoing conditions of registration that will come into effect from 1 May 2022. These set a number of minimum requirements for course quality. Among these, revised condition B1.3.e sets a requirement that ‘each higher education course, as appropriate to the subject matter of the course, requires students to develop relevant skills’. The guidance to this requirement states that this may be interpreted as meaning that ‘a course designed to lead to a particular profession that does not require students to develop and demonstrate the skills necessary for success in that profession…would likely be a cause for concern’. A failing of this kind in an apprenticeship might therefore be a matter of concern to the OfS.
In addition, Ofsted’s existing remit includes commenting on the quality of off-the-job training in terms of how it impacts on the progress and skills development of the apprentice.
We are also developing best practice case studies on alignment of degree learning outcomes with the apprenticeship’s KSBs. We will make these available when they are ready.
All apprenticeships, including degree apprenticeships, have an on-programme period, gateway and EPA period. At gateway, the apprentice’s employer believes (with advice from the training provider) the apprentice has reached occupational competence and is ready for that to be tested by the end-point assessment. To pass the gateway, the apprentice will need to have completed new learning related to the occupation’s knowledge, skills and behaviours and any additional (non-degree) mandated qualifications.
In degree apprenticeships, off-the-job training (the degree) and EPA can be delivered by the same organisation as part of the same programme. For assessment, this means the EPA and the degree will both need to be completed, passed and awarded together (with the exception of category 4 EPAs, see below).
The EPAs of degree apprenticeships must be delivered by end-point assessment organisations (EPAOs). EPAOs must be on the register of end-point assessment organisations (RoEPAO) specifically for the relevant degree apprenticeship.
Degree apprenticeship EPAs should meet the Institute’s general requirements for end-point assessments. They will need to include an independent assessor who is working in - or has sufficient knowledge of - the occupation. The exact structure, requirements and parameters of the EPA, including roles and responsibilities, assessment methods and grading descriptors will be outlined in the apprenticeship’s EPA plan. Trailblazer groups may add additional parameters to enhance the EPA’s validity and standing in their occupation.
The EPAO will need to build and deliver a gateway process into their apprenticeship programme. The EPAO will administer the EPA in accordance with the EPA plan, meeting the requirements for integration, assessors and external quality assurance (EQA).
In a very small number of degree apprenticeships, where the occupation has a regulator, the completed degree will be a gateway requirement rather than being integrated with EPA. The EPA will be integrated with the regulator’s assessment process instead (category 2 and category 4 EPAs, see below)
How EPA integration is applied in degree apprenticeships will depend on if and how the occupation is regulated:
Category 1: Degree apprenticeships without a regulator or professional body
Each EPAO must deliver the EPA as set out in the EPA plan and must not award a degree without the EPA being passed. EPAOs will need to build the EPA into the mandated degree they will deliver. The EPA must take place after the gateway and must not include any new learning related to the knowledge, skills and behaviours.
To support comparability between different HEPs’ EPAs, the EPA plan will set out EPA requirements and give an indicative credit value. The EPA’s credit value should be sufficiently large to allow valid measurement of the apprentice’s occupational competence, but not so large as to adversely impact on training. EPAOs can incorporate the EPA into their credit system as necessary. For example, with the EPA as part of a module where teaching and EPA assessment are separated by the gateway; with the EPA as a stand-alone module; or in another way that ensures EPA is delivered as per the EPA plan. Ultimately EPAOs must deliver the EPA as set out in the EPA plan.
EPAOs may work in partnership with other organisations in delivering the EPA. For example, the EPAO may purchase support services or secure independent assessors from a third-party organisation. The EPAO will retain responsibility for the EPA and for ensuring it is delivered according to the EPA plan.
Category 2: degree apprenticeships with a statutory regulator
The requirements for this type of integrated EPA are set out on in our guidance covering statutory regulated occupations.
Category 3: degree apprenticeships where there is not a statutory regulator but there is a professional body
In occupations where it is only desirable for the apprentice to gain professional recognition from a professional body, where possible, trailblazer groups should design an EPA that can also meet the professional body’s assessment requirements. They would do this with input from the professional body. The EPA must still always meet the requirements of a degree apprenticeship.
Ideally, the professional body will simply recognise the completion of the degree apprenticeship to give professional recognition.
For those professional bodies that have their own assessment procedures for membership, trailblazer groups may accommodate these in the EPA if they wish to do so and it is practicable. If a professional body’s assessment requirements are accommodated, the professional body must agree to use the outcome of the EPA in its granting of professional recognition. If the EPA matches only part of the professional body’s assessment procedures, the professional body must agree to not duplicate that assessment when considering the apprentice for membership. Professional bodies must notify the Institute if they wish to change this agreement.
We recognise that it will not always be possible to use the EPA directly as part of a professional body’s assessment process, for example, because:
We recognise that including professional body requirements into EPAs will require flexibility and creativity from the professional bodies concerned, the Institute and the awarding organisation of the degree.
Category 4: degree apprenticeships where the professional body has a regulatory role which controls access to the occupation
In a small number of degree apprenticeships, the relevant professional body, rather than a HEP, may deliver the EPA.
This will be permitted only where the professional body, whilst not being a statutory regulator, has control over who practises in the occupation. The professional body will need be involved in the development of the occupational standard as well as the EPA plan.
The degree in these apprenticeships will be completed as a gateway requirement, but the apprenticeship will continue until the EPA is completed. The EPA will be the professional body’s assessment process. Successful completion of the EPA will grant the apprentice membership of the professional body and allow them to practise in the occupation.
The EPA will need to meet the general requirements for end-point assessment. The structure, parameters and requirements of the end-point assessment will be set out in its EPA plan.
For a degree apprenticeship’s EPA to be delivered by a professional body, the professional body must meet all of these criteria:
The Institute will work with eligible professional bodies and trailblazer groups to develop an EPA that meets all stakeholders’ needs.
EPAs in integrated degree apprenticeships must include at least one independent assessor drawn from the occupation and outside of the EPAO. Ideally all the EPA assessors will be independent assessors.
In addition to independent assessors, the EPA plan may allow EPA assessors from other universities, professional bodies or the university department (subject to safeguards about conflicts of interest). If the EPA is not delivered solely by independent assessors, then the independent assessor(s) must make the final decision on whether an apprentice is occupationally competent.
The great strength of EPA is that it is an independent judgement of an apprentice’s occupational competence by assessors who are experts in, and respected by, the occupation. In integrated degree apprenticeships, where the training provider is also the EPAO, independence is more difficult to achieve than in non-integrated apprenticeships. The EPAO must therefore make the EPA as independent as possible and have policies and procedures in place to achieve this. All assessors, and especially independent assessors, must not have an actual or potential conflict of interest relating to the end-point assessment of an apprentice (including by way of moderation). They must not have been involved in the training or employment of the apprentice. Specifically, they must not receive a personal benefit or detriment from the result of the assessment and must only deem an apprentice to be occupationally competent in accordance with the EPA plan’s grading descriptors.
Any assessors who are not an independent assessor may contribute to the decision on which EPA grade to award, but the final decision on whether an apprentice is occupationally competent or not will rest with the independent assessor(s).
External quality assurance will check independence is being protected in the EPA.
All independent assessors need to:
The requirements for all assessors will be set out in the apprenticeship’s EPA plan.
The EPAO must:
The EPAO is free to make arrangements with other organisations (such as other EPAOs and professional bodies) to facilitate the recruiting of suitable industry and independent assessors.
EQA for integrated degree apprenticeships will be the responsibility of the Office for Students (OfS) and be carried out by the Quality Assurance Agency (QAA) on their behalf. EQA for degree apprenticeships will be conducted in accordance with the Institute’s EQA framework. EPAOs must meet the requirements for EQA as set out by the EQA provider.
OfS will not be the EQA provider for non-integrated degree apprenticeships. Non-integrated degree apprenticeships will be externally quality assured by other bodies approved by the Institute until the non-integrated degree apprenticeships are revised and become integrated.
Where necessary, EPAOs must also meet the requirements of the occupation’s relevant statutory regulator or professional as set out in the apprenticeship’s EPA plan.
For category 4 degree apprenticeships, the Institute will approve the relevant professional body as the EQA provider (rather than OfS). This will allow the same body to externally quality assure the assessment arrangements for apprenticeship and non-apprenticeship routes into their occupation.
The Institute will have overall responsibility for all external quality assurance of apprenticeships, including which bodies may be EQA providers. The overall requirements for EQA are set out in the EQA Framework and EQA providers will set out how they will deliver EQA. The Institute will also work with the EQA providers to assure the necessary oversight of the separation of assessors and apprentices.