Navigating the Changing EPA Landscape: A Need for Clarity on Recent Announcements

Well its certainly been a tumultuous week or so in relation to apprenticeship policy and rules! As a result,  I thought it would be good to share the detail of the changes alongside areas where I think further clarification will be required. In this article I have focused purely on end-point assessment.

The initial announcement stated “Where appropriate, apprentices will be assessed on some things during their apprenticeship rather than all at the end, and training providers may be able to deliver elements of the assessment, rather than having to rely on external assessors.” This was later followed up with further detail around the assessment principles, duration, maths and English and payments simplification. 

Based on the information published by DfE I believe a number of clarifications will be required over the coming weeks and months in relation to EPA:

When will the end-point assessment changes take effect?

The DfE webpage states “Existing assessment plans will be rewritten on a standard-by-standard basis”, so presumably that means that changes will only take place to EPA once the assessment plans have been rewritten?  It would be good for the sector to have an idea of timeframes and order of rewriting, for example, will they prioritise certain sectors, levels, or apprenticeships with the greatest volumes of apprentices? Although to be fair to DfE the webpage does clearly state “Further detail on implementation, including which assessment plans will be revised and when, will follow in due course”.

The DfE announcement says “include the minimum number of assessment methods for validity”. What will be the minimum number of assessment methods?

The words “where appropriate” will need explaining.  Will Skills England provide the policy/rules, will the employer design groups decide, or will it be down to each EpAO to decide what is appropriate? When will it come into operation, once the assessment plans have been revised, on a case by case basis, or with immediate effect? Based on the first bullet point, presumably it is once the assessment plans have been revised?

Training Providers May be able to Deliver Elements of the Assessment

Further details will be required around the statement “training providers may be able to deliver elements of the assessment”. Will Skills England determine this, will the employer design groups decide, or will it be down to each EpAO? This question is important for the sake of EPA consistency across EpAOs, and because if a training provider delivers elements of the end-point assessment, for EPAs regulated by Ofqual, they must become a Centre of the EpAO, as detailed within Ofqual Condition C2.

They must also be subject to Centre Assessment Standards Scrutiny in accordance with Ofqual Condition  H. It also raises questions around other Ofqual conditions such as the management of conflict of interest, confidentiality of assessment, prohibited training and publishers.

Another point to note from the DfE clarifications is that “EPAOs will be responsible for developing all assessment materials in accordance with the Assessment Plans.” This means that even if training providers deliver elements of the assessment, they must use EpAO assessment materials and not use/design their own.

Where assessment plans allow assessment to take place on programme, will it mean that those aspects do not form part of the end-point assessment? This is important because if it remains part of the end-point assessment it forms part of the qualification and as such is subject to the regulation/regulator.  From reading the words around behaviours, it looks as if behaviours may be removed from the end-point assessment “employers are best placed to confirm apprentices are demonstrating the required behaviours. To remove unnecessary duplication, those behaviours will no longer need to be separately assessed by providers or EPAOs”.

When the DfE webpage refers to assessment plans being short (eg 2 pages), it presumably means that lots will be stripped out.  Initially I thought it would create a risk around quality and consistency, but now I think it may provide an opportunity (as well as some risks).  Skills England could develop a set of rules  applicable to all end-point assessments covering areas such as the rules around whether an assessment can be ended early, English and maths requirements, reasonable adjustments, resits and retakes (I do think some things could be stripped out of assessment plans altogether such as value for money and IQA). 

A set of rules would support consistency without the need for it to be repeated in every assessment plan. These could potentially be added to the DfE apprenticeship funding rules as opposed to creating another rule book (this may not be appropriate, it was just an idea).

Shortening of Assessment Plans Will Have on the Consistency of End-Point Assessment

Ofqual and Skills England will need to consider any impact the shortening of assessment plans will have on the consistency of end-point assessment and regulation as the Ofqual Condition EPA1.1 states “In respect of each EPA which it makes available or proposes to make available, an awarding organisation must (a) comply with any requirements, and have regard to any guidance, contained in the relevant Assessment Plan, and (b) interpret that Assessment Plan in accordance with any requirements, and having regard to any guidance, which may be published by Ofqual and revised from time to time.”  There is currently no national standardisation or moderation of end-point assessment, so presumably there is a risk of increased inconsistency if assessment plans are slimmed down. 

There is no mention of the Gateway

There is no mention of the gateway, but with the desire to shrink assessment plans I do wonder what will happen to the Gateway? Will EpAOs still have a role to play in checking / approving gateway or will it be down to the employers and providers to make that decision and to take on the accountability?  Depending on what is decided, some updates may be required, for example, the Ofqual condition EPA1.2 states “An awarding organisation must take all reasonable steps to satisfy itself that each Learner has met any relevant Gateway Requirement prior to taking an assessment for an EPA which it makes available or proposes to make available.”  However, given that  the gateway references are still within the new version of the funding rules, it suggests that gateway requirements will remain.

External Quality Assurance

I have to admit, I am confused by the DfE statement  “External Quality Assurance will continue to be provided by the designated body”. Non-integrated end-point assessment is dominated by Ofqual. Ofqual is not an EQA provider it is a regulator, which is very different. Skills England  will need to ensure that they do not refer to EQA when talking about EPAs regulated by Ofqual, unless they plan to introduce EQA.  Without EQA Skills England will limit its own ability to have oversight of EPA and it will limit the sector’s ability to standardise, learn from each other, build on best practice, and to bring consistency to EPA.

The Mandated qualifications policy of IfATE will need a review and update. It is not working effectively, and given the references in the DfE webpage about “if there is already a mandatory industry recognised qualification that provides a licence to practice as part of the standard, the knowledge, skills and behaviours demonstrated in this do not need to be subsequently retested”  it suggests that Skills England will need to review and refresh this policy, in conjunction with EpAOs, employers, awarding organisations and Ofqual.

Shorter Duration Apprenticeships

The DfE announcements around shorter apprenticeships, with an example of prior learning, will have a knock onto EpAO operations, as Ofqual has a specific condition around RPL (Condition E10). Who will determine the approach to, and application of, RPL? Will it be Skills England, the employer design groups, training providers or EpAOs? If an apprentice has RPL, is it just the duration that can be changed or can other things be changed?

The DfE states that Skills England will prioritise occupations as per the industrial strategy. It would be helpful for the sector to understand what this means for apprenticeships that are not a priority of the industrial strategy.

Retirement of Standards

I have noticed the absence of refence to the retirement of standards. IfATE has recently been recommending standards for retirement. What will be the policy and approach going forward?

On a final note, I would like to highlight version control.  IfATE have a frustrating ability to change standards and assessment plans without notifying the sector (and sometimes without changing the version number). EpAOs must deliver against the assessment plan and have clear strategies in place to manage change, including reporting change and any potential adverse effects to Ofqual.  My plea is that Skills England sets out a clear policy for version control, the notification of updates to the sector when an assessment plan is updated, and associated timeframes.

By Jacqui Molkenthin, Specialist support for End-point Assessment Organisations