Mandatory qualification reform – a step forward but more improvements needed

The Institute for Apprenticeships and Technical Education have recently published proposals on mandatory qualifications policy in apprenticeships as part of an IfATE consultation that is scheduled to close on 17 February 2023. Some of these proposals are definitely a step forward – however more thought is needed on how the reforms will be applied in practice. In this article, AELP’s Simon Ashworth explains why.

Originally expected last summer, we have been waiting with earnest for the Institute for Apprenticeships and Technical Education (IfATE) to publish proposals on mandatory qualifications policy in apprenticeships. The latest proposals were published shortly before Christmas as part of an IfATE consultation that is scheduled to close on 17 February 2023.

These proposals very much follow on from the reform of degree apprenticeships which began to be implemented from the autumn of 2022 and there’s certainly a degree of commonality here. Ensuring that more apprentices fully complete their apprenticeship remains a huge priority across the skills sector – so some of these proposals are definitely a step forward. However more thought is needed on how the reforms will be applied in practice.

Linking mandatory qualifications to end point assessments

The principle of tying-in the awarding of high value mandatory qualifications (including license to practice) into the end point assessment (EPA) is a welcome proposal. Too many apprentices and employers simply use the apprenticeship and the associated funding as a wrapper to achieve a recognised qualification and then withdraw before the end point assessment. This behaviour negatively impacts training providers, end point assessment organisations and ultimately devalues the apprenticeship brand by dragging down overall achievement rates.

Although these proposed reforms are welcome in principle, there does need to be careful consideration of the impact this will have on the end point assessment organisation (EPAO) market which will need careful management. The shift of external quality assurance powers to Ofqual has not been without its operational challenges. Furthermore, there are still question marks about the availability of true coverage across all 650+ apprenticeship standards, so some of these proposed changes could cause further displacement. The move to greater integration of assessment will require more input from training providers after gateway, and this needs to be properly addressed by the IfATE and the Department for Education. This is a long-standing issue that this review again shines a light upon.

Mandatory qualification policy consultation

IfATE’s consultation on mandatory qualification policy in apprenticeships is now open and the proposals broadly break into three themes:

• The IfATE’s refined approach to which qualifications will be allowed to be mandated within new and refreshed apprenticeship standards.
• The key proposal of, where practical, to integrate the assessment and awarding of those mandated qualifications into the end point assessment.
• The more technical aspect around the rules and approach to how the integrated assessment will work within the end point assessment.

Mandated qualifications

Since the advent of apprenticeship standards there has been somewhat of a tug of war on the inclusion of mandatory qualifications within apprenticeships! Initially it was a challenge for employers to get qualifications mandated, but over time the Institute for Apprenticeship (as it was back then) eventually softened its position a little and listened to the voice of employers. As it stands, just under half of apprenticeship standards have at least one mandated qualification. This is a good thing as suitable qualifications add additional currency and value to apprenticeships.

In the latest proposals, the IfATE still acknowledges the value of mandated qualifications. However, it is looking to take out existing criteria where trailblazers can ask for qualifications to be included, arguing this adds additionality and structure to the off-the job training. The focus moving forward is much more on qualifications that are either a regulatory, professional body or labour market requirement.

Is this a good thing? Overall, I would say overall yes. Providers and employers can still include qualifications to help structure delivery of off-the-job training, but moving forward such qualifications will be optional. This allows for more flexibility in the curriculum design and sequencing, something we hear regularly about from Ofsted.  

Integration of assessment

As mentioned previously, over time the move to an integrated assessment model will help improve achievement rates. This is because it ties the apprentice into the whole apprenticeship, not just components of it. It is important accountability is not just weighted on the provider, especially where there are factors outside of their direct control, such as employer behaviour.

It is important to recognise though that not all mandatory qualifications should or will be integrated. For example, in construction to access a construction site an apprentice needs a CSCS card, without this license to practice they cannot access the workplace to develop their practical skills and knowledge. Tying the assessment of CSCS to the end point assessment wouldn’t be practical in any sense.

Integrated assessment should also help to reduce unnecessary duplicate assessment activity. In particular, there is greater clarity proposed on the list of qualifications that are eligible as the mandatory qualifications available for each apprenticeship standard. This should be welcomed as it will reduce confusion.

Rules and requirements

So far so good then. But as ever the rules and requirements always offer the opportunity to turn a good policy on its head – so what about the situation here? No doubt the change to a significant number of assessment plans, and the mapping of qualification criteria and assessments, will create a significant amount of initial work for EPAOs and awarding organisations. 

The lack of consideration of the role that training providers play after gateway to ensure the successful completion of the apprenticeship continues to be ignored somehow. Without provider support and intervention, then EPA would in reality grind to a halt – most employers want and need provider support to make this seamless. With the move to greater integrated assessment, this is a key area that needs to be recognised as the provider will become even more integral to the completion of the mandatory qualification – as well as the administration of the EPA. This is something that the DfE need to consider as a consequence of the IfATE’s new proposals.

Under the proposals, the coverage of mandatory qualifications “must not go wider” than the knowledge, skills and behaviours set out in the occupational standard. This seems to me lack appropriate flexibility. Whilst ‘fuller occupational coverage’ should not be the sole basis alone for approval, we are concerned that the wording in the proposals could cast aside some high-quality existing qualifications – just because their scope is over and above the requirements stipulated in standard. Some flexibility on this should be considered.

Finally, there will be an impact on some end point assessment organisations, who may have achieved Ofqual recognition, but are not awarding organisations. This may lead to further volatility in the availability of EPA across all 650+ apprenticeship standards. Ensuring there is coverage of high quality of EPA is vital to ensure the health of the apprenticeship market.

Overall, there are some good proposals and principles contained within these reforms and AELP looks forward to working with the IfATE on addressing some of the areas that we feel require some improvements.