This guidance provides information on reasonable adjustments within end-point assessment (EPA). It can be used by: 

  • apprentices
  • employers
  • training providers
  • end-point assessment organisations (EPAOs)
  • awarding bodies (for the purpose of integrated mandatory qualifications)

This guidance helps to explain:

  • when reasonable adjustments may be required
  • what should be considered before reasonable adjustments are applied
  • the types of reasonable adjustments that can be applied
  • who is responsible for applying reasonable adjustments
  • how reasonable adjustments may be implemented without impacting the: validity of the EPA, reliability of the EPA

The guidance includes a reasonable adjustment matrix. The intention of the matrix is to:

  • provide examples of adjustments that can be made to different assessment methods 
  • provide examples of adjustments that ensure EPA remains valid and reliable 
  • support EPAOs to make appropriate and consistent decisions on reasonable adjustments 

Information is also provided on special consideration and when this may be given. 

All users must consider the following points when utilising this guidance:

The information included in the reasonable adjustment guidance and matrix provide recommendations only. EPAOs must consider all requests for reasonable adjustments on an individual, case-by-case basis. 

The information included within the reasonable adjustment guidance and matrix is not exhaustive. It is also not a definitive list of what can, or cannot, be requested or approved. 

Reference to legislation within this document is for context and guidance. It does not substitute reading the relevant part of the statue in its entirety. Users are encouraged to seek their own legal advice regarding the scope of their legal duty.

The reasonable adjustment guidance and matrix work best when used together. The matrix should not be used on its own to support or make decisions. 

It is vital that EPAOs have arrangements in place for making reasonable adjustments. These should be accessible to training providers, apprentices and employers. In some instances, having arrangements is a mandatory requirement. This includes:

EPAOs must make decisions around reasonable adjustments in line with their arrangements. The arrangements should include:

  • how an apprentice qualifies for a reasonable adjustment
  • what reasonable adjustments may be made

 

1. Reasonable adjustments

Section 20 of the Equality Act 2010 creates a legal duty to make reasonable adjustments.

The duty applies where a person with a disability would suffer substantial disadvantage in relation to a relevant matter in comparison with persons who are not disabled. 

This is applicable to:

  • provision, criterion or practice
  • a physical feature
  • the provision of an auxiliary aide

Section 6 of the Equality Act 2010 defines a disability as a physical or mental impairment which has a substantial and long-term adverse effect on a person's ability to carry out normal day-to-day activities. 

Schedule 1 of the Equality Act 2010 sets out supplementary provisions regarding disability, providing helpful definitions and clarifications.

Schedule 1, Paragraph 2 clarifies that the effect of an impairment is ‘long term’ if it: 

  • has lasted for at least 12 months
  • is likely to last for at least 12 months
  • is likely to last for the rest of the life of the person affected
  • is likely to recur

Schedule 1, paragraph 6 stipulates the following medical conditions are to be treated as disabilities for the purpose of the Act:

  • cancer 
  • HIV infection
  • multiple sclerosis

Therefore, a reasonable adjustment is a step taken to remove, or prevent a substantial disadvantage that apprentices, who have a disability within the Equality Act definition, encounter during their apprenticeship. 

In an apprenticeship, this legal duty to make reasonable adjustments applies to:

  • employers
  • training providers
  • EPAOs
  • awarding bodies (for integrated mandatory qualifications)

Adjustments must be made if it is reasonable to do so. What is a “reasonable” adjustment will be assessed by looking at numerous factors. The Equality and Human Rights Commission (EHRC) suggests the following can be considered:

  • the apprentice’s disability
  • how practicable the changes are
  • if the change asked for would overcome the disadvantage the individual experiences
  • the size of the organisation
  • the financial resources available to the organisation making the adjustments 
  • the cost of making the changes
  • if any changes have already been made

Reasonable adjustments should be consistent across all aspects of the apprenticeship. In the EPA, where possible and appropriate, these should be the same as those made in the apprentice's:

  • workplace 
  • off-the-job training

It is important that all organisations work together to ensure the correct reasonable adjustments are in place at each stage. Within EPA, the EPAO makes the ultimate decision on the reasonable adjustments made. 

The following section outlines the suggested roles each organisation should take. 

 

In work

The role of the employer:

  • discuss with the apprentice the reasonable adjustments needed in the workplace. These discussions should happen as early as possible
  • put in place the reasonable adjustments needed for the apprentice in their work. These may include: making a change to the way things are done, making changes to any physical barriers, providing auxiliary aids that assist the apprentice 
  • pay for any reasonable adjustments required within the workplace. The apprentice may be eligible for support through Access to Work funding
  • support the apprentice in discussing reasonable adjustments with the training provider. The employer may wish to discuss what has been implemented in the workplace. The apprentice should agree to any information being disclosed

Employers and apprentices may find GOV.UK information on reasonable adjustments helpful.

The following sections of the EHRC website may also be helpful:

Employing people: workplace adjustments

Reasonable adjustments in practice

 

In training

The role of the training provider:

  • discuss with the apprentice the reasonable adjustments needed as early as possible. Where appropriate, the employer should support these discussions
  • implement the reasonable adjustments needed for the apprentice in their off-the-job training. Where possible, and appropriate, these should be the same as those in the workplace 
  • fund any reasonable adjustments needed during off-the-job training. Support for these costs may be available through Additional Learning Support
  • notify the EPAO that the apprentice will need reasonable adjustments in EPA. This notification should be as early as possible. This should follow the EPAO's arrangements for reasonable adjustments

 

In EPA

The role of the EPAO:

  • review the request for reasonable adjustments in line with their reasonable adjustment arrangements. Decisions should be confirmed as soon as possible
  • where appropriate, discuss the adjustments in place in the workplace and off-the-job training.  These discussions could involve the: apprentice, training provider, employer 
  • implement the reasonable adjustments needed for the EPA. Where possible and appropriate, these should be the same as those made in the apprentice’s workplace and off-the-job training
  • maintain records of any applications for reasonable adjustments and the decisions made. This should include the evidence used to support the application and decision

 

2. The reasonable adjustment matrix

The intention of the matrix is to support EPAOs in applying appropriate and consistent judgements. It uses the Higher Education Statistical Authority’s (HESA) disability grouping framework to categorise disabilities. These are then overlaid with different assessment methods. This provides examples of reasonable adjustments that could be applied to EPA.

The examples in the matrix are recommendations only. The included examples are not a definitive list of what can, or cannot, be requested or approved. EPAOs must consider all requests for reasonable adjustments on an individual, case-by-case basis.

 

Reasonable adjustment matrix:

  1. No known disability
  2. Cognitive processing need such as dyslexia, dyspraxia; a need in executive function, visual processing speed, visual perception,
    literacy, numeracy, verbal reasoning, verbal memory, nonverbal memory
  3. Social/ communication need such autistic spectrum condition
  4. Long standing illness such as cancer, epilepsy, Crohn’s, IBS, Chronic Fatigue
  5. A mental health condition
  6. A physical need such as crutches or wheelchair user, arthritis, paraplegia, quadriplegia, cerebral palsy
  7. Hearing need
  8. Visual need

Table 1 contains examples of reasonable adjustments that could be applied to EPA

  Observation Practical Skills Test Test Project Presentation Professional Discussion
Extra time allowance 2,3,4,5,6,7,8 2,3,4,5,6,7,8 2,3,4,5,6,7,8 2,3,4,5 2,3,4,5,7 2,3,5,6,7
Scribe - - 2,6,8 - - -
Reader - - 2,8 - - -
Personal support worker in attendance 2,5,6,8 2,5,6,8 2,5,8 2,5,8 2,5,6,8 2,5,8
Timed rest breaks 2,4,5,6,7,8 2,4,5,6,7,8 2,4,5,6,7,8 2,4,5,6,7,8 2,4,5,6,7,8 2,4,5,6,7,8
Bathroom breaks 4,6 4,6 4,6 4,6 4,6 4,6
Voice explanation 2,8 2,8 - - - -
BSL interpreted and extra time 7 7 7 7 7 7

 

 

Table 2 contains further examples of reasonable adjustments that could be applied to EPA

  Observation Practical Skills Test Test Project Presentation Professional Discussion
Assistive technology - voice recognition - - 2,4,6 - - -
Assistive technology - screen reader - - 8 - - -
Assistive technology - text to speech - - 2,4 - - -
Flexibility with location - - - 3,4,5,6 3,4,5,6 3,4,5,6
Flexibility of time of assessment 4 4 4 4 4 4
Flexibility with the method of assessment - 6 3,4,5,6 3,4,5,6 3,4,5,6 3,4,5,6
Pre-recorded evidence - delivered by video link - - - 2,3,4,5 2,3,4,5 -
Permission to write notes - - - - - 2,4,5
Permission to bring notes - - - 2,4,5 - 2,4,5
Info presented in required format - size, font style, colour - - 2.8 - - -

 

 

Table 3 contains further examples of reasonable adjustments that could be applied to EPA

  Observation Practical Skills Test Test Project Presentation Professional Discussion
Individual testing - - 3,4,5 - - -
Paper based option - - 2,4 - - -
Supervised assessment taken at home - - 3,4,5,6 - - -
Written questions to back up verbal - - - - 2,4,5,6 2,4,5,6
Rewording of questions - clarification if needed - - - - 2,3,7 2,3,7
Time allowance for processing verbal questions - - - - 2,4,5,7 2,4,5,7
Information presented in small chunks - - - - 2,4,7 2,4,7

 

3. Upholding the EPA

Reasonable adjustments should support an apprentice in showing their occupational competence. EPAOs must balance this with upholding the validity and reliability of the: 

  • assessment methods
  • EPA plan
  • occupational requirements

Additionally, the outcomes of the EPA must:

  • meet the requirements of the occupational standard regardless of the process or methods used
  • be as rigorously assessed as outcomes generated by other apprentices
  • not provide an unfair advantage to the apprentice. This should be in comparison to other apprentices undertaking the same EPA without adjustments. There should be no unfair advantage in relation to the grading of the assessment.
  • be able to be moderated and verified

The process of considering reasonable adjustments must be rigorous and fair. 

Where any concerns are raised against these requirements, further discussion may be required. To find a solution, the EPAO should discuss their concerns with the:

  • apprentice
  • training provider 
  • employer  

Applying reasonable adjustments is a legal duty. The EPAO may only decline a request for reasonable adjustment when it is determined that the adjustment would not be a 'reasonable' one. 

The EHRC provides further information on reasonable adjustments. This may be helpful to apprentices, employers, training providers and EPAOs. 

 

4. Special consideration

Special consideration can be given to apprentices who have temporarily experienced:

  • an illness
  • an injury 
  • any other event outside of their control.

Special consideration may be given where these events have affected an apprentice’s ability to either:

  • undertake EPA
  • demonstrate their occupational competence

EPAOs should have clear arrangements in place for special consideration. The arrangements should be accessible to apprentices, employers and training providers. In some instances, having arrangements is a mandatory requirement. This includes: 

Any request for special consideration should be submitted to the EPAO. This should be in line with their special consideration arrangements. The EPAO should make any decisions in line with their arrangements. Any records of requests, including supporting evidence, should be retained by the EPAO. 

 

5. Using and sharing this guidance

This guidance is covered by Open Government Licence (OGL). Stakeholders can use the reasonable adjustment guidance and matrix for their own needs. However, all users should familiarise themselves with the conditions of the OGL. 

 

Last updated 21 June 2023
(MG, NS)