Some Reflections on the Apprenticeship ‘reforms’
Author: Ewart Keep
Posted on: 30th January 2017
With the arrival of the levy now looming, this short blog offers some reflections on both the process issues raised by the apprenticeship reform programme, and also on some underlying questions that it leaves hanging. I start with policy process.
As I have observed in oral evidence to the House of Commons joint BIS/DfE select committees’ inquiry into apprenticeships, and also in a chapter (Keep and James Relly, 2016) for the CIPD volume on apprenticeship reform, the process whereby the reforms have been designed and implemented possibly leaves something to be desired. In particular, the decision to move to a levy without prior consultation with employers or with anybody else; and without a basis of thorough research upon which to model the levy’s potential impacts on firms’ behaviour, is not a shining example of how to engineer complex change. We have the levy because government was faced by a budget deficit and this appeared to offer an easy and swift way out that would force larger employers to engage with apprenticeship and allow the government to expand provision without undue expense to the Exchequer. In essence, it is yet another giant action research experiment, with a research base that is, at best, limited. The result has been a series of frantic efforts to retrofit research into policy as it has evolved (see, for example, Gambin et al, 2016), coupled with a gradual evolution of the various practicalities of how the levy will be collected and administered.
At the same time, the design and start-up process for the new Institute for Apprenticeships (IfA), which following the Sainsbury Review and the Skills Plan has already morphed (pre-birth) into something broader in order to take on responsibility for implementing the technical pathways element of the Skills Plan. Although the consultation document on the IfA’s remit as it relates to apprenticeships has just been launched, many issues concerning its role and structure remain unresolved. For example:
- What expertise will its board possess not only on apprenticeships, but also qualification design and reform (given its newly assigned responsibilities for technical pathways)?
- How will the IfA ‘represent’ employers of all sizes across the many different sectors and occupations, and via what formal consultation/representational mechanisms will it be able to garner the views of employers? Countries with successful apprenticeship provision tend to possess relatively elaborate, powerful and effective collective mechanisms to organise, represent and engage employers on a sectoral basis. Where are ours?
- What will the annual IfA’s operational budget be?
- What will its staffing complement be – in terms of size, pay levels and expertise? What experience and leadership will its new director bring?
- What will its relationships with DfE, SFA, HMRC (as the collector of the levy), Ofsted and Ofqual be, and how will they be structured?
- The IfA is being billed as being ‘independent of government’ and ‘employer-led’. The last UK body in the skills arena with this broad design envelope – the UK Commission for Employment and Skills (UKCES) – has just been wound up, in part because both UK government civil servants and ministers decided that it was actually a bit too independent in its thinking and research for their liking. It is thus worth asking how, and by whom, will the IfA’s independence be ensured?
Besides uncertainty about the IfA, there are many other questions and issues that remain to be resolved, and some of them can only be addressed once the new set up starts to function and we get to see how firms and training providers respond to, and in some cases game, the new system. For example, one key assumption that DfE has inherited from DBIS’s supervision of the apprenticeship reform programme is that some of the larger employers subject to the levy cannot or will not be able to create enough apprenticeship places to be able to fully reclaim what they pay via the levy, and that this unclaimed sum will conveniently pay for much of the provision that will be offered by firms too small to be paying the levy. If this happy and convenient belief proves to be incorrect, a hole will open up in the overall spending package for apprenticeships.
Hanging over everything is a set of issues concerning the attitudes and roles of employers. Despite a great deal of talk by government of apprenticeships being or becoming employer-led, the reality is that they aren’t. The reform process has certainly not been employer-led. It has been largely conducted by DBIS, and now by the DfE, from within a Whitehall policy bunker, and, after an initial set of consultations – the results of which as they related to the levy were swiftly ignored – firms’ input to the design and evolution of policy has been limited to employer bodies such as the CBI protesting at developments that they have not liked, and applauding developments that do meet with their approval. This is not employer leadership.
The main arena within which employers, albeit a select band of enthusiasts, has been allowed direct participation in the re-design of apprenticeships, has been via the trailblazer groups which have overseen the development of the new apprenticeship standards. However, as the then-minister, Nick Boles admitted:
“I think we should all be honest, and observe that the employers involved in delivering apprenticeships under the pilot are employers of a particular kind, a particular depth of resource and the apprenticeships involved are a particular kind of apprenticeship, they’re not necessarily absolutely typical” (quoted in FE Week, 20 October 2015, p. 10).
The interesting issue will be how the broad mass of employers (rather than the trailblazing enthusiasts) react to and adopt these standards as the basis for the apprenticeship places that they are willing to offer. Government currently seems to assume that the switch over will be automatic, and that the bulk of firms will adopt the new models with alacrity. If the majority of employers in a given sector choose to ignore the new standard and stick with the old, pre-existing apprenticeship frameworks, government will be faced with some difficult choices, particularly given the rhetoric of employer choice and leadership.
More worryingly, the other dimension of employers’ general disengagement from apprenticeships revolves around their limited responsibility for the actual delivery of initial work-based learning. As has been observed on many occasions by many observers (see contributors to Dolphin and Lanning, 2011 and Lanning, 2016), English apprenticeships are, even in many large firms, designed, delivered and quality assured by external sub-contractors rather than by the firm that is employing the apprentice (Fuller et al, 2015). Apprenticeships are a bought-in form of training, rather than something that is integral to the firm. The latest example of this was a crisis in the run-up to Christmas when the main independent training provider (ITP) for apprenticeships at vehicle manufacturer Jaguar Land Rover went into administration, and a new provider had urgently to be sought to ensure continuity of provision. The news coverage played up the crisis brought about by insolvency. The underlying story was that JLR, despite being one of the larger and more high profile firms offering apprenticeships, does not feel willing/able/motivated to design and manage its own scheme, but simply subcontracts to an ITP. Compare and contrast this with practice in countries such as Germany or Switzerland. Given that the skills minister, Robert Halfon, continually insists that the key aim of the current apprenticeship reforms is to boost quality (see Halfon, 2017: 3), the disengagement of firms from design and delivery ought to be viewed as deeply troubling.
Much of the coverage of changes to apprenticeships in trade journals such as FE Week has centred on a jockeying for position/advantage between different provider players:
- Independent training providers
- FE colleges
- Third sector providers
- Main contract holders/managing agents (to use some very old terminology) vis-a-vis their sub-contractors
as well as on the financial implications of adjustments, sometimes minor, to the various funding regimes, entitlements, and scales; and the costs associated with new minimum delivery requirements and forms of assessment. Employers have certainly not been centre stage, except insofar as the financial incentives created by the levy and the new funding regime might alter their preferences between different types of provider, types and levels of apprenticeship, and the overall volume of apprenticeship places they are willing to offer.
The key unknown at present, is how employers will choose to react to the new apprenticeship marketplace, both initially, but also as their understanding and those of the providers in the marketplace, evolves. Policy is trying to straddle a massive contradiction. On the one hand, the comforting assumption in relation to quality is that employers are deeply committed to, and engaged with, apprenticeship provision. On the other hand, reality suggests this may not be the case, and the imposition of a levy implies that, when push comes to shove, policymakers know they cannot rely upon the voluntary enthusiasm of firms to power their ambitions for a larger and better apprenticeship system. What history tells us is that, faced with successive chances and encouragement to reform and expand apprenticeship since the Manpower Service Commission’s New Training Initiative (NTI) in 1981, the bulk of employers have responded with indifference (Keep and James Relly, 2016: 26), and numerous attempts over the years to upgrade apprenticeships have failed (see, for example, the Modern Apprenticeship Advisory Committee report of 2001). The central question is thus whether the impetus provided by the imposition of a levy will be sufficient to galvanise enough employers into interest and action. If the levy proves to be less than fully transformative, policymakers will find themselves confronted with some painful trade-offs to be made between cost, quality and quantity. Given the massive policy expectations that have been loaded onto the apprenticeship reforms, the drawbacks and limitations of an apprenticeship model that is primarily dependent on external independent providers, rather than on employers themselves, are liable to become even more apparent than they have been hitherto.
Dolphin, T., and Lanning, T. (eds.). 2011. Rethinking apprenticeships, London: IPPR.
Fuller, A., Leonard, P., Unwin, L., and Davey, G. 2015. Does apprenticeship work for adults? The experience of adult apprenticeship in England, Project Report for the Nuffield Foundation, London: University College, Institute of Education.
Gambin, L., Hogarth, T., Winterbotham, M., Huntley-Hewitt, J., Eastwood, L., and Vivian, D. 2016. The apprenticeship levy: how will employers react?, DfE Research Paper, London: Department for Education.
Halfon, R. 2017. ‘Captain Halfon’s New Year Resolutions’, FE Week Navigating 2017 Supplement, 9 January, page 3.
Keep, E., and James Relly, S. 2016. ‘Employers and meting the government’s apprenticeship target: what could possibly go wrong?’, in T. Lanning (ed.), Where next for apprenticeship?, London: Chartered Institute of Personnel and Development, pages 25-31.
Lanning, T. (ed.) 2016. Where next for apprenticeship?, London: CIPD
Modern Apprenticeship Advisory Committee. 2001. Modern apprenticeships: the way to work, London: Department for Education and Skills.