Degree apprenticeships already play a hugely important role in our education and skills system. They give people who may not previously have had the opportunity a chance to progress their careers through higher education.
They create a practical link between employers and our universities. This helps to bring the latest cutting edge working practices and industry knowledge into our higher education system. And of course, they help employers to fill skills gaps by offering really high-quality training and development to apprentices.
But for all the strengths of the current system, we can make degree apprenticeships even better, and take advantage of the unique status degrees have in the labour market. We have a real opportunity to align degree apprenticeships more closely in terms of on- and off-the-job experience, training, and assessment. By doing this we can create a clearer brand for degree apprenticeships, with distinctive characteristics. Delivering on this ambition has been the focus of our proposed changes.
We received over 200 responses from a wide range of different stakeholders, and we are grateful to each one of them for taking the time to feed in their views. The number of responses and the considered views contained within shows the desire and commitment from all to get these reforms right.
I am pleased to say that the consultation responses were overwhelmingly in favour of implementing all five of our proposed changes, which is what we now plan to do.
However, there were a number of important issues raised by respondents, which will need further work and clarity from us.
These include the practicalities of alignment and integration, and how to undertake compliance monitoring of both, plus how to build independence into the assessment. We have listened to the points made, and publishing this response is the start of a process, with further guidance and support materials planned for the coming months.
We also recognise that the originally proposed implementation timetable was very tight, making it difficult for some trailblazers who have upcoming submissions to plan ahead. Again, we have listened and so, whilst we still intend to allow submissions based on the new policy from March 2022, we are now planning to have a transition period until September 2022 after which complying with the new policy will become compulsory.
By taking these changes forward, I am confident we can offer the apprentices of the future a fully integrated product, combining the very best of both degrees and apprenticeships.
Jennifer Coupland
Chief Executive, Institute for Apprenticeships and Technical Education
A degree apprenticeship brings together the day-to-day experience of undertaking a higher level occupation with the academic rigour of a relevant degree. It is already a good product, but we believe we can make it even better for the benefit of apprentices, employers and the economy.
To deliver this improvement, we launched a consultation on 16 July 2021 proposing several policy changes to the development, approval, and delivery of degree apprenticeships. Although relatively technical in nature, these are intended to:
The consultation ran for nearly nine weeks (until 16 September) during which time six briefing sessions were held to help potential respondents engage with the detail of the proposals prior to formally responding.
The consultation received 208 responses from a wide range of organisations including higher education institutions (HEIs), employers, end-point assessment organisations (EPAOs) and occupation representative bodies. A breakdown of respondents by organisation category is contained in Annex 2.
The above chart is an overview of the percentage of respondents who agreed, were neutral, disagreed and did not know for all the main changes. Agreement is highest for change two at 85%. Agreement for the other changes ranges between 73% and 79%. Disagreement is highest for change four at 14% of respondents. However, respondents were not required to answer each question, meaning that these percentages do not necessarily reflect the views of all respondents to the consultation.
The following is a brief summary of the responses relating to each proposed change. The strong support has encouraged us to implement each one of them, and we have therefore focused this response primarily on the issues raised and what work is left to do to support the changes.
75% of respondents supported the proposed change to the way we determine whether a degree should be mandated in an apprenticeship, with a further 15% being neutral. In addition, the majority of respondents were either supportive (51%) or neutral (35%) on using the proposed evidence base for such decisions.
Issues raised included the risks of relying on cross-sector data sources at the expense of employer views, and of such data being backward looking at the expense of future requirements.
The need to reflect labour market realities in our decisions necessitates the need to base such decisions on data. However, we agree that trailblazers should be free to offer evidence from sector-specific sources which will be considered alongside evidence from the data sources that we will use for all such decisions.
In terms of future-proofing, we fully support building this into occupational standards as far as possible. However, we must not start with the default assumption that a degree is generally required to be able to undertake an emerging or evolving occupation.
85% of respondents supported ensuring that effective integration of on-the-job and off-the-job training occurs in the delivery of degree apprenticeships, with only 3% disagreeing.
Issues raised by respondents included the need for strong employer / HEI / professional body partnering and best practice sharing; the need for a rigorous inspection regime to ensure effective integration becomes the norm; and flexibility on how integration is achieved in different scenarios.
We agree with all these points and will provide further advice and guidance over the coming months to help those delivering degree apprenticeships to optimise such integration. We are also working with the Office for Students (OfS) and Ofsted to ensure effective but proportionate monitoring of compliance and evaluation of quality.
79% of respondents supported the alignment of the degree learning outcomes with the KSBs in the relevant occupational standard, with only 7% disagreeing.
Issues raised by respondents included the need to require trailblazers to involve relevant HEIs in the development stage of occupational standards; the need for greater clarity on what good alignment looks like and to ensure such alignment happens in all cases, and the risk of the aligned degrees being too narrow.
We agree with the first three of these points. We already recommend to trailblazers that they should involve other stakeholders such as training providers in the development process. However, in future, we will require trailblazers to involve relevant HEIs in the occupational standard development process for degree apprenticeships, without this compromising our overriding commitment for the process to be employer-led. We will provide further advice and guidance over the coming months to help HEIs align degree learning outcomes with the KSBs, and we are working with the OfS and Ofsted to ensure proportionate quality monitoring and evaluation of such alignment. In terms of the risk of degrees being too narrow, whilst we understand the concern, we do not believe that this needs to be the case if the KSBs are correctly developed at the outset, and we will develop further guidance to support that process.
73% of respondents supported integrating the end-point assessment (EPA) of occupational competence in a degree apprenticeship with the final assessment of the degree, with a further 11% being neutral. 14% of respondents disagreed with this proposal.
Issues raised by respondents included the need for clear inspection and quality assurance processes to support high quality apprenticeship training, consistency, and fair and valid EPA; the need to ensure independence is not compromised and the need to clarify how alignment with professional, statutory, and regulatory body (PSRB) requirements will be captured.
We agree with these points. We will continue to apply oversight of the external quality assurance (EQA) system to EPA. The OfS and other EQA providers will ensure the EPAs comply with the requirements of the assessment plan and meet the needs of employers and apprentices, and that they are fair, comparable, and consistent. We will clarify the requirements to ensure independence of EPA in the assessment plans. We will continue to work with PSRBs to incorporate their requirements into EPAs as necessary which, in some cases, will involve integrating EPA with professional body assessment systems.
73% of respondents supported requiring the integrated EPA of all degree apprenticeships to include assessment by trained individuals with appropriate occupational and industry expertise, with a further 13% being neutral. 12% of respondents disagreed with this proposal.
Issues raised by respondents included the sourcing and training of independent assessors with occupational expertise; the need to clarify external quality assurance arrangements; and use of the external examiner system.
We agree with the points relating to independent assessor recruitment and will build requirements relating to the role into future assessment plans and will explore with stakeholders how HEI EPAOs can build their pool of independent assessors. We do not believe EQA will be an issue, as the changes can be accommodated within the existing system. We do not believe that the external examiner will be able to act as the occupational assessor for degree apprenticeships because they do not assess all apprentices. The external examiner will have a role to play in ensuring a degree apprenticeship’s EPA is carried out correctly in accordance with its assessment plan.
The strong support for the proposed changes from a broad range of stakeholders, with frequent references to the envisaged benefits for apprentices and their employers is evidence of the likely positive impact of the reforms. A small number of respondents referenced potential negative impacts on HEIs and non-HEI EPAOs, and these are addressed in the updated impact assessment.
In terms of equality, the majority of respondents felt that the proposed changes would have a positive impact on particular groups, but the responses contained little information about the specific groups they had in mind. A small number of respondents identified potential negative impacts on groups of persons who share certain protected characteristics. We have carefully considered the suggestions made and whilst we do not believe these impacts are likely to arise, we will closely monitor the impact of implementing the changes and take any relevant steps in accordance with the public sector equality duty as and when they arise. In general terms, we believe that the changes will have a positive effect for all learners, including those with protected characteristics.
Based on the overwhelming support for the proposed changes from consultation responses, we intend to press ahead with their implementation. However, in commenting on the proposed timeline for this, as detailed in the consultation document, 33% indicated that they had concerns, with 49% of respondents saying they had no concerns and 18% saying they didn’t know.
Key concerns raised were: limited trailblazer and HEI resource available to apply the new policy so soon; whether the guidance would all be in place by autumn 2021; and whether introducing the new degree apprenticeships policy in March 2022 allows enough time to secure starts by autumn 2022.
Taking these points into account, but also the fact that more respondents did not have any concerns about the timeline, we have concluded that a practical way forward will be to:
This will ensure that any early adopter trailblazers (i.e. employer groups leading on the development of occupational standards) who are planning submissions in line with the new policy based on the timeline outlined in the consultation document are not delayed, whilst enabling other trailblazers to continue to apply the current policy for six months beyond the March 2022 deadline if they wish. Beyond this, is it worth noting that the new policy will be applied to revised degree apprenticeships as and when they come up for review rather than requiring them to all be compliant by September 2022.
Related to this work, the Institute has also been working with Department for Education to review the approach to non-degree qualifications in apprenticeships. This work is following the same principles as applied to degree apprenticeships in terms of the mandating of non-degree qualifications within apprenticeships when they are needed, and ensuring they work effectively as part of the apprenticeship. We plan to engage with stakeholders and set out our proposals on this in spring 2022.
We will amend our mandatory qualifications policy to recognise the currency of degrees, including where there are no specific subject discipline requirements for entry to an occupation. We will mandate degrees in apprenticeship standards that will be occupationally-specific, only in the case of graduate-entry occupations at level 6 and level 7. There will be no compulsion on employers to develop a degree apprenticeship if they do not want to (i.e. if they would prefer to develop an apprenticeship at level 6 or level 7 that does not lead to the award of a degree).
Table 1: Responses to the question “Do you agree or disagree with the proposal set out in ‘Change 1’?
|
|
Agree |
Neutral |
Disagree |
Do not know |
|
Number of responses |
114 |
23 |
13 |
1 |
|
Percentage of responses |
75% |
15% |
9% |
1% |
Table 1 shows 75% of respondents supported the proposed change to the way we will determine whether a degree should be mandated in an apprenticeship, with a further 15% being neutral.
Table 2: Responses to the question “Do you agree or disagree with the proposed evidence base on which the Institute will evaluate whether an occupation is a graduate occupation suitable for a degree apprenticeship? Note: percentages do not add up to 100% due to rounding
|
|
Agree |
Neutral |
Disagree |
Do not know |
|
Number of responses |
72 |
49 |
18 |
3 |
|
Percentage of responses |
51% |
35% |
13% |
2% |
Table 2 shows the majority of respondents were either supportive (51%) or neutral (35%) on using the following evidence base for such decisions:
Some respondents suggested that using various data sets to determine whether a degree should be mandated must not be at the expense of the employer view. However, given that our intention is for any such decision to reflect hard evidence of labour market realities, we believe that an evidence-based approach is the correct one rather than simply relying on an employer view.
Some respondents suggested that data sets will look to the past whereas employers want to look to future occupational needs. We fully support the desire to future-proof occupational standards both as they are developed, to the extent that this is possible, and via our revisions, adjustments and dispensation process as the need for change arises. For emerging or evolving occupations, we would not want to start with a default assumption that they are degree level entry occupations, and nor would we want to risk inadvertently changing labour market norms by doing so where there is no evidence to support it. In view of this and, as already highlighted, the decision-making process must remain evidence based. However, in such scenarios, we are mindful that the evidence base may be limited and would want to keep an open mind and consider all legitimate sources of evidence in coming to a decision. In addition, if it appears that labour market requirements have shifted over time for any occupation - whether well established or evolving – in relation to the need for a degree, we would want this reflected in any revisions to the relevant occupational standard.
Some respondents requested that the proposed evidence base does not exclude any occupation specific data sets from sources such as professional or regulatory bodies and we agree with this. As detailed in bullet point (4) of the originally proposed evidence base (see above), we intend to retain the flexibility to take account of additional evidence sources. In terms of any sector-specific sources, the Institute will consider evidence selected and provided by trailblazers. The evidence will be assessed using the following criteria (subject to future changes as we develop the process and gather further insights from employers and other stakeholders):
Taking account of the strong level of support for this proposed change, we intend to implement it and use the originally proposed list of evidence sources (repeated above), including retaining the flexibility to take account of additional evidence offered by or via the trailblazer, subject to these meeting our criteria. In addition, we are currently trialling the use of job advert data for various purposes within the Institute and intend to test whether this data can also be of value in this context. However, there will continue to be no compulsion to mandate a degree to a Level 6 or 7 apprenticeship if the trailblazer does not wish to do so.
Degrees within a degree apprenticeship will fully integrate with the on-the-job training and development that apprentices experience in the workplace. This objective will inform the ways in which degree apprenticeships are developed by trailblazer groups, and we will also provide better guidance about how employers and training providers are expected to integrate training delivered on- and off-the-job. This reflects good practice already delivered in many degree apprenticeships, and we would like to make this the norm.
Table 3: Responses to the question “Do you agree or disagree with the proposal set out in ‘Change 2’?”
|
|
Agree |
Neutral |
Disagree |
Do not know |
|
Number of responses |
137 |
17 |
5 |
3 |
|
Percentage of responses |
85% |
10% |
3% |
2% |
Apprenticeships work best when learning and experience in the workplace and off-the-job training delivered by the training provider are fully integrated and mutually reinforcing.
Table 3 shows 85% of respondents supported ensuring that this occurs in the delivery of degree apprenticeships, with only 3% disagreeing. Key issues raised by respondents are highlighted and addressed below:
The need for strong employer / HEI / Professional Body partnering and best practice sharing. We agree that close partnering between the parties involved in delivering the apprenticeship is central to effective integration and will work with stakeholders to support this, including exploring how to address this through future development of the ESFA’s Sector Workforce Development Programme.
The importance of well-informed Institute guidance and best practice examples. We agree that this is essential and will work with employers, HEIs and others to develop appropriate guidance and case studies.
The need for a rigorous inspection regime to ensure effective integration becomes the norm. We agree with the need for assurance that effective integration happens. A number of respondents rightly pointed out that Ofsted’s remit does not include explicit inspection of the degree within an apprenticeship. However, the effectiveness of integration is already covered in Ofsted’s evaluation schedule used to determine grades as a result of inspections. Ofsted would be able to use their “deep dives” undertaken on inspections to identify any concerns about providers’ delivery of 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, as set out in its recent consultations. We are currently working through this issue with the OfS and Ofsted to ensure that such quality monitoring and evaluation is undertaken in an effective but proportionate way.
Limited HEI resource to co-ordinate integration across multiple employers. Whilst we recognise that this is challenging for all training providers relating to apprenticeships at all levels, effective alignment of on- and off-the-job training is already identified as best practice. We are simply aiming to use these reforms to support its more effective implementation for degree apprenticeships.
Flexibility on how integration is achieved in different scenarios. We agree that precisely how integration is achieved will depend on a number of variables relating to the nature of the apprenticeship and those involved in its delivery. Clearly there is a balance to be struck here between setting out what is required without being excessively prescriptive. We will aim to reflect this in our guidance.
Potential blurring of on- and off-the-job training with a risk of breaching ESFA funding rules. We do not believe this will be the case. The proposed change is intended to ensure that on-the-job and off-the-job training are delivered in a co-ordinated and mutually reinforcing way rather than merging the two forms of training. Off-the-job training, and hence what is eligible for funding, is clearly defined in the ESFA funding rules and off-the-job training guidance, as is the requirement for this to amount to 20% of the apprenticeship.
Taking account of the strong level of support for this proposed change, and the issues raised by respondents, we intend to implement it. We will provide guidance on best practice integration of on-the-job and off-the-job training and are working with the OfS and Ofsted to ensure effective but proportionate quality monitoring and evaluation of integration of training.
In support of proposed change 2, we will require that the learning outcomes of any degree mandated in an apprenticeship standard will reflect the requirements of the occupation through alignment with the knowledge, skills and behaviours (KSBs) in the employer-specified occupational standard. As with proposed change 2, this is already best practice in some degree apprenticeships. This will require Higher Education Institutions (HEIs) to develop and validate degrees specifically aligned to the apprenticeship standard, noting that this may already be the case for some regulated occupations.
Table 4: Responses to the question “Do you agree or disagree with the proposal set out in ‘Change 3’?
Note: percentages do not add up to 100% due to rounding
|
|
Agree |
Neutral |
Disagree |
Do not know |
|
Number of responses |
131 |
21 |
11 |
3 |
|
Percentage of responses |
79% |
13% |
7% |
2% |
Table 4 shows that 79% of respondents supported the alignment of the degree learning outcomes with the KSBs in the relevant occupational standard, with only 7% disagreeing. Key issues raised by respondents are highlighted and addressed below:
The need to require trailblazers to involve HEIs in the development phase. We already recommend that trailblazers developing occupational standards involve other interested parties such as training providers in this process. However, we agree that this becomes essential when bespoke degrees are being simultaneously developed to support the emerging apprenticeship. We will therefore require trailblazers to involve interested HEIs in the development process in future, without this compromising our overriding commitment for the process to be employer-led. We will also work with organisations such as UVAC to ensure that HEIs are made aware of new degree apprenticeships in development.
Risk of degrees being too narrow and less valued if they only align to the KSBs rather than to wider acquired graduate attributes such as critical thinking or, for example, broader sectoral or scientific knowledge needed to progress. There are three related issues to address here:
The risk of HEI approval timescales/resources hindering integration. Clearly HEIs having to internally approve degrees developed specifically to support apprenticeships rather than being able to apply pre-existing degrees adds to the development time of a degree apprenticeship. However, the length of HEI approval periods can vary significantly and HEIs may find themselves incentivised to find ways of speeding up this process (whilst continuing to safeguard quality) to meet employer deadlines. It is also worth noting here that we are not requiring all pre-existing degree apprenticeships to comply with the new policy as soon as it is implemented. Instead, the policy will be applied to pre-existing Level 6 and 7 apprenticeships as and when they are reviewed and revised.
Clarity on how - and to what extent - degree learning outcomes need to be aligned with KSBs and the need for guidance and best practice examples on this. We would normally expect the degree learning outcomes to reflect and align with all KSBs within the occupational standard. However, we agree on the need for guidance on how to undertake this alignment.
The need to ensure the effective alignment of degree learning outcomes with KSBs in all cases. We aim to make the process of aligning degree learning outcomes with the KSBs as straight forward as possible via the provision of the above mentioned guidance. However, we recognise that some monitoring of this is needed. The OfS is currently consulting on revisions to its conditions that would include in condition B1 an expectation that each higher education course, as appropriate to the subject matter of the course, required students to develop relevant skills. No decision has yet been made on the adoption of this condition but, if it is adopted, relevant skills could include KSBs in the case of degree apprenticeships, meaning that the OfS could have a monitoring role here. 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.
The risk of the need for bespoke degrees making them unviable to deliver by HEIs in some regions. Whilst we recognise the significant investment that any HEIs involved in degree apprenticeships will need to make, these must remain business decisions for HEIs to take. Apprenticeships below Level 6 have bespoke training programmes delivered by Further Education Colleges and independent training providers, often to small cohorts and, in essence, we are simply requiring HEIs to do the same for degree apprenticeships. With many HEIs delivering nationally and with fewer than five HEIs raising this issue in the face of otherwise overwhelming HEI support for the proposed change, we do not anticipate it having a negative impact on regional delivery. Nonetheless, the ESFA will continue to monitor the availability of training provision across different regions.
How to integrate behaviours into degrees. There is no reason why behaviours could not be included in the degree. As stated above, we would therefore normally expect the degree learning outcomes to reflect and align with all KSBs within the occupational standard.
Taking account of the strong level of support for this proposed change and the issues raised by respondents, we intend to implement it. We will require trailblazers to involve relevant HEIs in the development and revision of degree apprenticeships; provide guidance on best practice alignment of degree learning outcomes and KSBs, and we are working with the OfS and Ofsted to ensure proportionate quality monitoring and evaluation of alignment of degree learning outcomes with KSBs.
Proposed changes 2 and 3 will align degree achievement and learning for occupational competence. As a result, we will only approve degree apprenticeships where the end-point assessment (EPA) of occupational competence in a degree apprenticeship will integrate with the final assessment of the degree. The objective is to ensure that neither the degree nor the apprenticeship can be awarded in isolation from the other, with the EPA serving both.
Table 5: Responses to the question “Do you agree or disagree with the proposal set out in ‘Change 4’?
Note: percentages do not add up to 100% due to rounding
|
|
Agree |
Neutral |
Disagree |
Do not know |
|
Number of responses |
117 |
18 |
23 |
2 |
|
Percentage of responses |
73% |
11% |
14% |
1% |
Table 5 shows that 73% of respondents supported integrating the end-point assessment (EPA) of occupational competence in a degree apprenticeship with the final assessment of the degree, with 14% disagreeing. Key issues raised by respondents are highlighted and addressed below:
How alignment with professional, statutory and regulatory body (PSRB) requirements will be captured, particularly where integration appears to conflict with PSRB requirements. Where professional recognition is needed in an occupation, particularly if it is a statutory or regulatory requirement, it will remain the intention for the apprenticeship to lead to that professional status. Trailblazers, with support from the Institute, will work to create apprenticeships that incorporate apprenticeship, HEI and PSRB requirements. Apprentices will therefore achieve completion of the degree apprenticeship and be eligible to practise at the end of their training. As PSRBs’ requirements vary considerably across all 15 routes, there will not be one model that will be used exclusively. There may be a group of models that are developed, and the Institute will work with stakeholders to create guidance to facilitate the replication of these models when trailblazers create integrated degree apprenticeships. We acknowledge that, in some occupations, the alignment of apprenticeship, HEI and PSRB requirements will be challenging and, to be achieved, will require some flexibility from all partners (PSRBs, HEIs and the Institute).
In a very small number of apprenticeships, with certain characteristics (where membership of a professional body is an absolute requirement to practise in an occupation; the professional body must be the only EPAO to deliver the EPA and the degree must be completed before the professional body’s assessment to practise process can begin), the Institute will require the professional body’s assessment process to be integrated with the EPA, instead of the degree. The Institute will create criteria to ensure this model of integration is appropriate, workable and meets the Institute’s requirements. Where membership of a professional body is desirable, rather than obligatory, to practise, as now, apprenticeships will be created that allow the apprentice to apply for professional body membership if they so wish.
Need for clear and rigorous inspection and quality assurance processes to support high quality apprenticeship training, consistency, and fair and valid EPA. All apprenticeships need to be subject to rigorous inspection oversight which, for degree apprenticeships, will continue to be provided by Ofsted (for training elements) and the OfS (for EPA elements). Where integration of EPA is with a professional body’s requirements rather than a degree, the professional body, authorised to do so by the Institute, will be the EQA provider.
Additionally, the Institute will remain responsible for all external quality assurance (EQA) activity and, to facilitate this, has created (and will periodically update) the EQA framework. The EQA framework will set out requirements for robust quality assurance processes for EPAs. The OfS (or alternative authorised EQA providers where necessary) will oversee EPAs in degree apprenticeships in line with this framework.
Risk of reducing the choice of EPA methods to traditional HEI methods for assessment delivery to align with the requirements of the degree. EPAs are designed to test occupational competence and use a range of assessment methods to do this in the most robust, valid and efficient way. The occupation’s KSBs will lend themselves to being assessed by different assessment methods. When creating EPAs, trailblazers select the optimum methods for assessing the occupation’s KSBs to make the EPA valid and as robust as possible. We expect that this good practice will continue, and the full range of assessment methods currently used in EPAs to be used in integrated degree apprenticeship EPAs to best assess occupational competence.
Whether the EPA component will carry degree credits and how this will operate. The EPA will be a key part of the integrated degree apprenticeship and must be passed for the degree apprenticeship to be achieved. To facilitate incorporation of EPAs into degree apprenticeships, it may be necessary to award a credit value, as used in some existing integrated degree apprenticeships. This will ensure that EPAs are fully integrated into the degree apprenticeship and will make a full contribution to all elements. The EPA will continue to be taken after the end of the apprenticeship’s training period and will not include any teaching of new content. Trailblazers will continue to set the credit requirement for EPAs to ensure a national standard, with consideration of the implications of this on the wider degree apprenticeship. The Institute acknowledges that the requirements for some integrated degrees may be difficult to achieve through using credits for EPA. In such instances, it may be more appropriate to set conditions to cover completion of all or part of the EPA to achieve the degree apprenticeship. The Institute will develop guidance to frame these approaches.
Risk of compromising independence as the HEI responsible for training will also be the EPAO. Integrated EPAs in degree apprenticeships already exist and their assessment plans set out requirements that ensure there is separation between those delivering the training and those delivering the EPA. This means that the assessors are independent of the apprentice. These requirements will be extended to cover the independent assessors drawn from the occupation and outside of the HEI (see Section 7 below covering change 5). Any perceived risk should be balanced against the advantages gained from including the ‘employer voice’ in the delivery of EPAs. The Institute will work with the EQA provider to assure the necessary oversight of the separation of assessors and apprentices, which will, as now, include a role for the external examiner.
The administrative and resource impact of this change on HEIs, including sourcing independent assessors with occupational expertise, changing their systems, and applying for the register of end-point assessment organisations (RoEPAO). For existing Level 6 and 7 apprenticeships, the intended changes will be phased in over time, applying as and when they are revised. This should give HEIs ample time to prepare, recruit independent assessors with occupational expertise and be admitted to the RoEPAO. As is the case now, HEIs will need to register on the RoEPAO to deliver the EPA where they follow a streamlined application process, which reduces their administrative burden.
Clarity on how funding will operate for this change. Integrated EPAs in degree apprenticeships already exist and so too does the way of factoring this model into funding bands. As each non-integrated degree apprenticeship becomes integrated, the funding band creation process will be applied as it would be for currently integrated degree apprenticeships. Similarly, the ESFA’s funding rules also already address integrated EPA in degree apprenticeships. Where necessary for any consequential change caused by the degree apprenticeships reforms, we will work with the ESFA on the required updates to the apprenticeship funding rules.
Need for comprehensive guidance and best practice models to support stakeholders in development and delivery of integrated EPAs. We agree that this is needed and, working with relevant partners and stakeholders, the Institute will provide guidance in due course.
Taking account of the strong level of support for this proposed change and the issues raised by respondents, we intend to implement it. We will extend the model for integrated EPA to all degree apprenticeships and for EPA to be integrated into professional regulatory requirements in some rare instances; the OfS will continue to provide EQA oversight of EPA as per the Institute’s EQA framework for integrated degree apprenticeships; we will provide guidance where necessary; and we will work with the ESFA to update funding rules where necessary.
We will require the integrated EPA of all degree apprenticeships to include assessment by trained individuals with appropriate occupational and industry expertise. In line with existing good practice in many HEIs, this will assist with securing the occupational specificity of assessment by addressing the conflicts inherent in integrated degree apprenticeship assessment and drawing in an occupational perspective.
Table 6: Responses to the question “Do you agree or disagree with the proposal set out in ‘Change 5’?
Note: percentages do not add up to 100% due to rounding
|
|
Agree |
Neutral |
Disagree |
Do not know |
|
Number of responses |
106 |
19 |
18 |
2 |
|
Percentage of responses |
73% |
13% |
12% |
1% |
Table 6 shows that 73% of respondents supported requiring the integrated EPA of all degree apprenticeships to include assessment by trained individuals with appropriate occupational and industry expertise, with 12% of respondents disagreeing. Key issues raised by respondents are highlighted and addressed below:
Assessors must be sufficiently qualified and experienced and their roles clearly defined. Independent assessors must be suitably experienced/qualified in the occupation and have sufficient understanding of assessment processes (gained through training by the EPAO if necessary) to be able to participate in - and add value to - the EPA in integrated degrees. In future, assessment plans will set out the requirements for each integrated degree apprenticeship, including roles and requirements for independent assessors. HEIs, as the EPAO, will then be responsible for using suitably qualified individuals and training them (e.g. in EPA processes) as necessary to deliver the EPA.
Will there be enough assessors with appropriate occupational and industry expertise? We recognise the need for a pool of independent assessors to be put in place by HEI EPAOs. As the intention is for degree apprenticeships to be moved to the integrated model over a number of years, there will be time for HEI EPAOs to manage this transition. HEIs will already have connections to potential independent assessors with occupational expertise who they could call upon to work in the integrated EPA, through their existing links with employers. In addition, there are already assessors working for non-HEI EPAOs in the degree apprenticeships that will become integrated, which HEI EPAOs could utilise in future. We would encourage HEI EPAOs to work with non-HEI EPAOs in the sourcing, recruiting and training of independent assessors. The Institute will explore how the recruitment process can be supported further, for example, through utilising PSRBs’ professional networks and through its employer directory (currently in development).
Lack of recognition by employers and PSRBs. Recognition of apprenticeships by employers and PSRBs (where necessary) is key to the success of apprenticeships. Apprenticeships are developed by employers to meet their needs which gives them credibility in the sector. Similarly, where professional recognition is needed, efforts will be made to incorporate these into the apprenticeship. Necessary professional body requirements (e.g. regarding who can deliver assessments) can be written into the assessment plan, thus making them a formal part of the EPA. This approach will continue to lead to the recognition of integrated degree apprenticeships.
How will independence of independent assessors be assured? Integrated EPAs in degree apprenticeships already exist and there are requirements built into their assessment plans to ensure the independent assessors are independent of the apprentice and those delivering the apprentice’s training. These requirements will be extended to cover the independent assessors drawn from the occupation and outside the HEI. The Institute will work with the EQA provider to assure the necessary oversight of the separation of independent assessors and apprentices and their trainers.
How will EQA work in the new arrangements? All apprenticeships need to be subject to robust oversight which, for degree apprenticeships, will continue to be provided by Ofsted inspection (for the training element) and by the OfS or alternative authorised EQA providers where necessary (for the EPA element). Where the Institute authorises integration of EPA with the assessment requirements of a professional body, the professional body will also need to be the EQA provider to give the apprenticeship parity with other routes into the occupation. Additionally, the Institute will remain responsible for all EQA activity across the apprenticeship system. We have created (and will periodically update) an EQA framework that sets out requirements for robust and high-quality assurance processes of EPAs. All EQA providers will oversee EPAs in integrated degree apprenticeships in line with the EQA framework.
How will the frameworks of professional, statutory and regulatory bodies (PSRB) be used? A similar point was raised in response to Change 4 and a response to the query has been given in that section.
Why can't the external examiner system be used? The intended change to integrated degree apprenticeships is for them to all include assessment by trained individuals with appropriate occupational and industry expertise in the direct delivery of their EPAs. The external examiner will not be able to meet this requirement as they will not participate in the delivery of every EPA that the HEI EPAO conducts. It is the intention that external examiners will still be used by the HEI EPAO for assuring the quality of the degree apprenticeships. For example, the external examiner will need to ensure that the EPA is delivered correctly in accordance with the assessment plan, includes the use of independent assessors and ensures all assessors are independent of the apprentice.
Various issues relating to delivery costs and payments. A number of respondents raised a range of points relating to funding or financial considerations. These include points about the updating of the degree apprenticeship’s funding band and how payments to independent assessors may affect independence. Many of the concerns raised will be dealt with in terms of existing processes, for example, funding bands will be reviewed as part of any revision of a degree apprenticeship. Other points will be addressed by setting out requirements in degree apprenticeship assessment plans, for example, adding expectations to safeguard rigour and robustness of EPA where independent assessors may be paid by the HEI EPAO for their time and input.
Taking account of the strong level of support for this proposed change and the issues raised by respondents, we intend to implement it. We will require that all EPAs in integrated degrees will involve the use of an independent assessor who will be a trained individual with appropriate occupational and industry expertise. We will encourage HEI EPAOs to work with their existing contacts in the occupation, non-HEI EPAOs and professional bodies to source suitable individuals to be independent assessors; overlay professional body requirements in the EPA plan where appropriate to do so; continue to apply the EQA framework to integrated degree apprenticeships; and require the external examiner to ensure that the EPA is conducted according to the requirements of the assessment plan.
In the consultation document we proposed the following implementation timeline, subject to the outcome of the consultation:
Table 7: Responses to the question “Do you have any concerns or foresee any problems with the timeline as set out?”
|
|
Yes |
No |
Do not know |
|
Number of responses |
61 |
91 |
34 |
|
Percentage of responses |
33% |
49% |
18% |
Table 7 shows that 49% of respondents had no concerns about this proposed timeline, 33% indicated that they did have concerns and 18% said they didn’t know. Key issues raised by respondents are highlighted and address below:
Limited trailblazer and HEI resource available with some citing this as an extra burden on top of route reviews. Our intention has never been to require all existing degree apprenticeships to be updated to reflect the new policy from the implementation date. Instead, we envisaged it being applied from March 2022 for submissions relating to new degree apprenticeships but only as and when existing Level 6 and 7 apprenticeships came up for review or needed revision. Nonetheless, we do recognise that a hard implementation date of March 2022 may create some uncertainty as to which policy to apply for trailblazers who are currently close to submitting new or revised apprenticeship standards for approval.
Over-ambitious to have all guidance in place by autumn 2021. We recognise this and are now aiming to have initial guidance in place in January 2022 with the development of supporting case studies following as and when experience of the new policy allows.
Over-ambitious to deliver any integrated degrees in the Spring to Autumn 2022 window. Whilst development work on any integrated degree apprenticeship can begin before Spring 2022, clearly an HEI is only going to put any resulting integrated and aligned degree through its internal approvals processes once the policy has gone live. With the duration of these processes varying significantly, the Spring to Autumn 2022 window may be long enough for some to enable autumn 2022 starts but not others. However, in view of this mixed picture, we accept that a March 2022 hard implementation date may be a false target to aim for. More generally, as existing Level 6 and 7 apprenticeships are revised, we will build in realistic notice periods for the implementation of the revised versions to enable HEIs to prepare for their introduction. Details of all standards in revision are included in our regularly updated revisions status report.
Changes being rushed through with insufficient care and attention. Whilst we do not believe this to be the case, we accept that there may be some practical considerations that justify an extended implementation timeline. In the meantime, we will continue to work closely with partners and experts from employers, HEIs and PSRBs to ensure we identify and address any complexities in such a way that the policy is deliverable.
Taking these points into account, but also the fact that more respondents did not have any concerns about the timeline, we have concluded that a practical way forward would be to:
This will ensure that any early adopter trailblazers which are planning submissions in line with the new policy based on the timeline outlined in the consultation document are not delayed. However, it will enable other trailblazers to continue to apply the current policy for six months beyond the originally intended March 2022 deadline if they wish.
The impact of the proposed changes on different stakeholders has been touched on at various points in this document already, but the following seeks to bring these points together.
There was strong support from employer respondents for the proposed changes with most of them welcoming the change in criteria for determining the mandating of a degree, and the other reforms, on the basis that they will lead to a better degree apprenticeship product. Clearly we are developing the changes precisely to support apprentices and their employers and so agree that the impact of them on employers will be positive.
A small number of employers were concerned either about the potential narrowness of a degree aligned to the KSBs within an occupational standard, or with the risk of degree and end-point assessment alignment being at the expense of alignment with any PSRB requirements. However, we believe with have addressed these concerns in Sections 5 and 6 respectively.
We currently have 152 approved apprenticeship standards at level 6 or 7, of which 102 have a degree qualification. 43 of these are non-integrated and 59 are integrated. The changes may lead to an increase in the proportion of apprenticeships at these levels having a mandated degree, and any degree apprenticeship this applies to will ultimately need to have its degree elements fully aligned to the KSBs and, in most cases, its assessment integrated with EPA.
It is important to note that the new policy will not require a degree to be mandated in a Level 6 or 7 apprenticeship if the trailblazer doesn’t want this. However, where a degree is mandated, clearly the development of the degree will involve a significant amount of work for HEIs that choose to deliver the apprenticeship. However, there was strong support amongst HEI respondents for the proposed changes. Most recognised that the integration of on-the-job and off-the-job training and the alignment of degree learning outcomes with the occupational standard’s KSBs is current best practice anyway. HEI respondents also welcomed the integration of assessment.
A small number of HEIs (fewer than five) raised the potential risk of the need to develop bespoke degrees leading to some HEIs withdrawing from delivering degree apprenticeship with a consequential regional impact. However, as noted in Section 5, with many HEIs delivering nationally and the fact that this was a minority view amongst HEI respondents, we do not anticipate such an impact. Nonetheless, the ESFA will continue to monitor the availability of training provision across different regions.
Some HEIs raised concerns about adverse changes to degree apprenticeship funding bands. When an apprenticeship is revised, its funding band is automatically recalculated and will factor in all eligible costs.
We have also considered the potential impact of the proposed changes on organisations currently involved in the delivery of non-integrated degree apprenticeships. Whilst the responses from most categories of organisation to the proposed changes were positive, a number of non-HEI EPAOs expressed concern about non-integrated degree apprenticeships becoming integrated. There are currently 43 non-integrated degree apprenticeships, which are covered by 22 EPAOs approved on the register of end-point assessment organisations (RoEPAO). It should be remembered that non-integrated degree apprenticeships will only become integrated when they are revised. The market will be notified in advance of a change that may lead to an EPAO stepping away. In addition, non-HEI EPAOs may be able to offer services to HEI EPAOs, subject to the funding rules in place at the time.
The Impact Assessment in the consultation document set out details of the types and number of Level 6 and Level 7 apprenticeships broken down by route, and the proportions of starts on such apprenticeships by people with protected characteristics for which data is available (gender, race, disability and age). Informed by this information, respondents were asked the following questions:
Table 8: Responses to the question “Do you believe the proposed change would have a positive impact on particular groups?”
|
|
Yes |
No |
Do not know |
|
Number of responses |
107 |
33 |
47 |
|
Percentage of responses |
57% |
18% |
25% |
Table 9: Responses to the question “Do you believe the proposed change would have a negative impact on particular groups?”
|
|
Yes |
No |
Do not know |
|
Number of responses |
47 |
81 |
57 |
|
Percentage of responses |
25% |
44% |
31% |
As detailed in the above tables, 57% of respondents believed that the proposed changes would have a positive impact on a particular group compared with 18% who believed they wouldn’t. When asked if the proposed changes would have a negative impact on particular groups, 25% of respondents agreed and 44% disagreed.
Although these questions related to the impact on “particular groups” (which was intended to mean groups of persons who share a protected characteristic), most of the free text answers focussed on the perceived positive or negative impact of the proposed changes on apprentices more generally.
In terms of a potential positive impact, 38 respondents commented that the more integrated approach to delivery and assessment would make degree apprenticeships more marketable. In addition, 24 respondents highlighted that degree qualifications have a positive effect on earnings and life chances and so, making them more available outside of purely academic routes, would help social mobility. In this context, respondents variously highlighted potential benefits for people from certain ethnic groups, people with learning difficulties and disabilities, and women.
In terms of a potential negative impact, 12 respondents commented that the removal of PSRBs from the assessment process would be to the detriment of apprentices generally and hence also to certain groups who share a protected characteristic. However, on this latter point, we believe that our proposed approach outlined in Section 6 addresses this risk. Specifically, the intention to combine apprenticeship, degree and professional body requirements in the EPA. In rare cases, and in accordance with criteria the Institute will create, integration will be made between the professional body requirements and the EPA.
A small number of comments were also made about potential negative impacts on groups of persons who share particular protected characteristics as follows:
No respondents commented on any specific impacts on individuals associated with other protected characteristics (i.e. gender reassignment, pregnancy and maternity, marriage and civil partnership, religion or belief, sex or sexual orientation).
In addition to considering and analysing responses to the consultation, we have reflected on the potential equality impacts of our proposals in furtherance of the public sector equality duty. We believe that there is minimal evidence of potential negative impact on groups of persons who share a protected characteristic. We agree with the comments made by a number of respondents who believe that the changes will have a positive impact on learners generally, including groups of persons who share a protected characteristic. As set out above, we intend to monitor the take up of degree apprenticeships developed in line with the new policy to assess the impact as we move forward.
The consultation generated 208 responses primarily via the online questionnaire with a few emailing in responses instead. Respondents included a range of individuals and organisations, and participation in the consultation was on a self-selecting basis. A breakdown of respondents by sub-group is presented in table 10. In view of the relatively small numbers in certain groups and the self-selecting nature of the responses, we have been cautious in interpreting these results as wholly representative.
In responding to the online questionnaire, respondents were asked “Which of the following best describes you?”. Respondents could select more than one option for their “stakeholder type”, which is why the percentages below do not sum to 100.
For example, a respondent could select that they were both an employer and a trailblazer member. This means they would be counted in both stakeholder types. However, there is no double counting in the total number of responses.
Table 10: Stakeholder types of respondent
|
Stakeholder type |
Number of respondents choosing this option |
Percentage of respondents choosing this option |
|
Apprentice |
15 |
8% |
|
Education representative body |
12 |
6% |
|
Employer |
64 |
32% |
|
Employer provider |
17 |
9% |
|
End-point assessment organisation |
30 |
15% |
|
Higher education institution |
74 |
37% |
|
Non-higher education apprenticeship provider |
11 |
6% |
|
Occupation representative body |
17 |
9% |
|
Trailblazer member |
28 |
14% |
|
Other |
31 |
16% |
Respondents were not required to answer each question, meaning that the percentages below do not necessarily reflect the views of all respondents to the consultation. Also, eight of the 208 respondents answered with written responses which did not follow the consultation structure, so these are not reflected in the percentages either.
The numbers in brackets after specific issues below are the number of respondents that raised that issue.
Do you agree or disagree with the proposal set out in ‘Change 1’?
Do you agree or disagree with the proposed evidence base (as outlined in point 1 above) on which the Institute will evaluate whether an occupation is a graduate occupation suitable for a degree apprenticeship? + optional free text box
Is there any other evidence the Institute should consider in its evaluation of whether an occupation is a graduate occupation suitable for a degree apprenticeship? Please note if any suggestions made are specific to a sector or occupational route.
Are there any reasons why you think the proposal will not meet its objective?
Do you agree or disagree with the proposal set out in ‘Change 2’?
Are there any reasons why you think this proposal will not achieve its intended objective?
Are there any additional ways in which you think the objective to integrate on- and off-the-job training can be achieved?
Do you agree or disagree with the proposal set out in ‘Change 3’?
Are there any reasons why you think this proposal will not achieve its intended object
Are there any additional ways in which you think the objective to align the learning outcomes of the apprenticeship and degree can be secured?
Do you agree or disagree with the proposal set out in ‘Change 4’?
Are there any reasons why you think this proposal will not achieve its intended objective?
Are there any additional ways in which you think the objective to integrate the assessment of degree apprenticeships can be secured?
Do you agree or disagree with the proposal set out in ‘Change 5’?
Are there any reasons why you think this proposal will not achieve its intended objective?
Are there any requirements that the Institute should lay out for the appointment of independent assessors with occupational expertise?
Do you have any concerns or foresee any problems with the timeline as set out?
Do you believe the proposed arrangements (any or all) would have a positive impact on particular groups of apprentices?
If you have answered ‘yes’ to question 1 above, please explain your reasoning.
Do you believe the proposed arrangements (any or all) would have a negative impact on particular groups of apprentices?
If you have answered ‘yes’ to question 3 above, please explain your reasoning.