We’re not there yet on the apprenticeship reforms

We’ve had a few days to absorb the details of the government’s latest apprenticeship levy announcements and already my inbox is full of comments from AELP members on what they think the impact is likely to be. There are some major concerns but not enough to for us to say we got it wrong in backing the government to press ahead with the levy’s start next April. The investment will also be substantial and the renewed focus on apprenticeships is game changing, so we all need to ensure that we don’t fall at the first hurdle.

However, given that we have been debating these reforms for four years, we have only have a few weeks left to finalise the policy decisions which will determine whether the reforms will be a success. It is therefore absolutely vital that we get them right. If we don’t, then there are going to be some very unhappy employers and apprentices who may have their programmes unnecessarily disrupted or even terminated.

The good news is that government officials have stressed that the proposals published on 12 August are genuinely subject to consultation. On the surface the proposals seem quite simple but actually they are complex and we are consulting our members who will no doubt bring to our attention aspects which require consideration. But a couple of big themes are now emerging.

The first is whether the government will be adequately funding many of the new standards and existing apprenticeship frameworks from next April. The nature of government pilots is that often they are designed to succeed whatever the test. So in the case of the Trailblazers for the new standards, some of funding caps looked generous and it seems that officials have come to the same conclusion. The problem is that in rowing back so hard, the newly proposed funding rates potentially make offering apprenticeships unviable in certain sectors and at certain levels. We will have a single rate for 16 to 18 year olds and for those over 19 which is also prompting concern that provision for the younger age group will suffer despite the incentives for smaller businesses to take these apprentices on. AELP’s long-standing concerns on the government’s co-investment requirements for employers have not gone away and we will monitor their effect on SME engagement closely. The latest announcements were a step forward but the fact remains that to be consistent with other government education policy, any 16 to 18 year old apprentice should be funded completely by the state whatever the size of their employer

The second major issue relates to which providers will be able to offer apprenticeships next year. In our view, the government is within in its rights to raise the bar for the providers it allows on to its new provider register. We can also understand why it has used this consultation exercise to have another stab at tackling the overall level of subcontracting within the sector. But one of the reasons why we urged Robert Halfon to delay the introduction of the new register for 12 months is that if implemented, the current proposals could have very serious unintended consequences for the employers already offering apprenticeships and apprentices currently in the middle of their programme. Many of these employers and apprentices may actually be happy with their current provider but the new criteria for being on the register, such as the amount of direct delivery required (both proportion of apprentices trained and proportion of each apprentice’s training delivered), may force them to look for a new provider. Therefore unless the process is properly managed, we could have disgruntled employers and learners being told to transfer in mid-programme which could result in losing them altogether.

The transition period between now and April is critical both for the government’s 3 million manifesto target and for the reputation of the programme with employers and young people. Providers were reporting to AELP that uncertainty around the funding regime is resulting in employers holding back on starting new apprentices – now the levy or 10% contribution is confirmed, why would any employer start an Apprenticeship standard with a 1/3rd funding requirement? Furthermore there is a fresh danger that providers who are worried about getting on the new register or being able to follow the proposed rules will also exit the market quickly leaving apprentices uncertain of their futures. Our view is that there is absolutely no need for this to happen but the government and the SFA need to listen closely to what providers and their employers are saying over the coming weeks.

Mark Dawe is chief executive of the Association of Employment and Learning Providers (www.aelp.org.uk)