So, I make no apology for this being Coronavirus focussed and nothing else. To be honest, everything else is irrelevant if the whole sector has gone bust in the next few months. I will attempt to set out what we have asked for in terms of flexibilities and what we are pushing for in terms of funding. While we may not have written a public letter, we are in constant contact with the Department, agencies and where appropriate the Treasury. Indeed, my momentary relief as my calendar emptied out of events and meetings was soon replaced with a constant round of calls with officials trying to get a sensible position on many things, as well as gathering questions and issues from members and feeding them into the relevant agencies. Add to that a child who has been sent home from school with a dry cough, welcome to my isolated world – at least every meeting is online, on the telephone and remote now!!
What everyone needs to be very clear about is what has actually been agreed versus what is being asked for and, again, I will try and make this clear now and going forward. I will also set out what AELP is doing for its members, including the wider ITP and EPAO community.
We had hoped that a number of the things I discuss below would have been published by now. Indeed, as far as we are aware, a document is awaiting sign off on flexibilities and it is incredibly frustrating that it is not yet available to all providers and EPAOs. This is not without constant nagging from AELP to all the relevant officials and agencies.
Education Statement by the Secretary of State
Firstly, the Secretary of State’s statement on education. Obviously, the big focus was on schools and exams – in fact apprenticeships were only mentioned once and that was in the questions. When it is crunch time, it is clear where the government priorities lie. There won’t be any exams and grades will instead be provided through teacher assessment/prediction. In addition, schools and colleges will be closed from Friday, although actually remaining open for children of key workers and the vulnerable – including over the Easter break.
Briefing with Department for Education
In our briefing by the Department, I asked about ITPs. Firstly, all our members were thanked by Minister Keegan for what they were doing in such challenging times. In simple terms, if you have premises where people come for learning and training, they should be closed. However, if you are going out to employers’ premises, if you are still allowed to, then this can continue alongside remote training and development. Indeed, we were asked to encourage more online and remote learning. I have highlighted that, for many of our members who have excellent systems and resources, this could be expanded significantly but they don’t have access to the funding. While there were no promises at this stage, it was logged.
So, let’s start with funding – nothing is agreed on this yet and it is probably the most critical as we are already hearing of staff being put at risk of redundancy and some providers running out of cash fairly rapidly. Whether it is apprenticeships, study programmes or other funding streams, the issue is the same. It is hard to complete programmes if employers are refusing to allow providers any contact (even with the flexibilities below), no access to training facilities while starts are beginning to dry up and are not likely to return to previous levels for a significant amount of time.
I will use some of the words I have used with the Department:
As one provider put it, it is like a bucket of water with a hole in – we keep filling up the bucket at least at the speed of the water draining out (completers or breaks in learning). If the flow into the bucket reduces or ceases (breaks in learning / starts dry up) the bucket soon empties (cash).
So, the ask is simple:
Non levy contracts honoured whatever level of performance
All other funding contracts including ESF (including agreed sub-contracts if college funding is guaranteed) honoured whatever level of performance
For levy starts look at the average draw down for the past three months and guarantee that as a minimum funding level per month.
Devolved AEB – all combined authorities to adopt the same approach and to honour contracts no matter what performance as described above
There obviously has to be some agreement for providers to try their best during this period in return for these guarantees, but without these guarantees the system is going to collapse very quickly.
On the devolved AEB, I am told that the DfE is meeting with Combined Authorities and there is a desire for all to take the same approach, but again no confirmation yet. I have said it would be crazy to have to go to each MCA to negotiate a position and this is well understood. However, the DfE is not in charge and this has to be done through agreement.
Putting the impact on individual providers and their own staff to one side at the moment, if providers and EPAOs start going bust over the next couple of months due to employer disengagement or unworkable delivery and assessment rules, those employers who are still enabling delivery and assessment will suddenly not have a provider to complete their apprentices. We know the ESFA struggle when one or two providers cease trading let alone tens or hundreds. But even worse will be when we get through this crisis, substantial delivery and assessment capacity will have been lost and it will take a long time to rebuild, if it ever does. And this isn’t about bad providers failing and good providers continuing. If a provider or EPAO can’t deliver to an employer anymore, it doesn’t matter how good they are, the income is lost, and it immediately puts them in a precarious or terminal financial position.
Someone asked me to summarise what the problem for providers was, so here you go. All funding is based on performance – no completions, reduced delivery, no starts – therefore no funding, therefore no providers or EPAOs anymore!!
I hope that for all members this approach would give them some certainty and reassurance. What I can’t guarantee is we will end up in this position, but it is the only way through this crisis. I am also making it very clear that the whole FE sector is independent – colleges and ITPs. Whatever is agreed for colleges must be reflected for ITPs (and vice versa) whether funded through contracts or grants.
There are some broader government initiatives to support all businesses and a good regular summary comes from the CBI. The best place to go for these updates is (here). We will send out some further briefings on these soon by they apply equally to ITPs as they do to any other business.
Below is the list of other things we have asked for during the past week or so. As I mentioned above, we had hoped a substantial number of these would have been agreed and communicated so far, but sadly we are not in that position yet.
Delivery Rules and Regulations
There will be a delay in reaching gateway and a delay in completions.
Assessment Rules and Regulations
Changes required – again, it needs to be a general rule for every EPAO for every standard, not through request.
What has become clear is that observations in the current climate are unworkable. Following this request above and the Secretary of State’s statement, I have said we require the following:
“Now that the DfE / Ofqual have confirmed that they will be using teacher assessment for GCSEs, A levels and examined vocational subjects, I must insist now this is extended to Apprenticeships and EPA and that the requirement to have end point observations is dropped. What is covered by the end point observation can easily be confirmed as having been demonstrated during the apprenticeship by the provider and the employer and can also be covered / probed / confirmed in a remote professional discussion. This is as robust, if not more robust, than what is being proposed for our gold standard academic qualifications. Without this change a significant proportion of EPAs will not happen and we are seeing the cancellation of thousands already. We will be letting down thousands of apprentices, while finding a way through for those doing academic students and that would be highly unfair.”
So again, we have a very clear position, it can’t be relied upon at the moment, but please be aware we are pressing this point very hard.
For delivery and assessment certain levels of staffing / professional qualifications are required. As an example, in health, qualified nurses. It is likely that their availability will disappear as they are needed by employers to cover those of sick. The solution would be to allow some flexibility on the qualification of staff doing training and assessment during this period.
Other funding requests (and note this was made before the broader requests made above on funding for providers)
Because of extended delivery periods, delays and loss of EPA, and a fall in starts there will be a significant impact on month by month cashflow for quite a long period during and beyond the height of the crisis for both providers and EPAOs.
Delivery time: delivery of an apprenticeship programme is likely to be extended, stretching fixed funding bands over a longer period or funding is stopped during a break in learning.
Solution: Any opportunity to increase the funding per standard during the period to allow for an extension of say 3 months, would cushion the impact on income and cashflow – in other words fund the break in learning in addition to the standard.
Completions: are likely to be significantly delayed or even lost through no fault of the provider or EPAO. Completions trigger 20% of all funding – this will be delayed or lost
Solution: Ideally completion is payed to providers at gateway (or perhaps at the current recorded rate post gateway of 80% assumed completion). EPAOs to receive, linked to the early completion payment, a proportion of the EPA payment at gateway in advance.
So, that is the list of our first round of requests to the Department and various agencies. We have been involved in numerous discussions and negotiations in relation to these. What I can confirm is the issues are well understood and the reasons we are asking for solutions. I think the officials are very clear as to the impact this is having, but still not clear enough how close to the cliff edge the whole sector is.
We have been gathering other requests and observations from members during the past week and anything we do not achieved from above, combined with the additional requests, will form our second paper which we will send to officials as soon as anything is published. However, these have been passed on to the relevant agencies already.
Additional Asks including everything needing to be put on hold – this is not business as usual
Were apprentices have been made redundant, this is what we have asked for from the ESFA and IFATE (AGAIN I CAN’T EMPHASISE ENOUGH THIS IS NOT AGREED YET!)
At the moment the funding rules allow up to 6 months post redundancy but only fund 12 weeks. The rule needs to change to fully fund the remaining period up to the total funding band.
One flexibility would be to say if they have completed 50% of the apprenticeship period, which would allow a slightly longer timescale for those on a longer apprenticeships.
I believe that whether it is a non-levy or levy apprentice the ESFA commit through the funding rules to pay the remaining cost of delivery up to the funding cap from central pot - would appreciate it if you would confirm that.
To allow for a simulated environment to complete any KSB “on the job” training and to complete off the job KSB remotely
To allow for an extended professional discussion with a witness testimony or a simulated environment. This would also apply to those that are unable to be in the workplace to complete EPA observations.
Given the circumstances an observation may not be possible so the professional discussion could be used to cover the KSB that would have been covered though observation and is complimented by a discussion or testimony from the apprentices line manager confirming that all KSB has been demonstrated.
Multiple choice questions - if they are not in the workplace this is a challenge and might need further flex on who can invigilate if they are at home. Ideally, in redundancy situations, confirmation they are the apprentices then the trainer on the line throughout the MCQ suffice
So that is everything so far that we have asked for, but the picture changes every single day, even every single hour. I have thought about a daily update but to be honest by the end of the week you would all be so confused as things swing around so much. As soon as anything is confirmed we will let all members know.
So, what about AELP as an organisation. AELP will focus on supporting providers in as many ways as possible and please do let us know what else you think we should be doing. If you want to run a session on innovative / good practice in your organisation, please drop Jane an email at [email protected].
Firstly, we are removing all face to face events, where possible making them virtual. This includes the national conference in June, which will now be held on 19-20 October. This is likely to mean our Autumn conference becomes more of a Winter conference in January and Spring stays where it is.
We will make sure we stay in touch on a weekly basis with all of you as best we can. Obviously watch out for tweets and briefings day to day, but we will also as a minimum have the following every week:
AS A REMINDER ALL STAFF IN YOUR ORGANISATION CAN REGISTER FOR UPDATES ETC AS WELL AS INFORMATION ABOUT WEBINARS. THEY CAN ALL ATTEEND WEBINARS AND EVENTS AT MEMBERS RATES OR THE FREE ONES, INCLUDING THE CEO WEBINAR.
This is also important as during the crisis we are opening up all our activities to members of the local provider networks at AELP member rates. I hope all AELP members would agree this is a time where we try and help and guide the whole sector and support as many of our colleagues across the country as possible.
As of Thursday, all AELP staff will be home based. So please bear with us if things don’t always seem as smooth as they should be. We have a great dedicated team of staff who are really keen to support our members in any way possible during the crisis. We have also worked out who is covering who during the period so as long as we don’t get hit too hard by illness most things should keep running as normal!!
We will move all our sector forums and special interest groups online. We are discussing with a range of people and organisations additional webinars we might be able to run. Some of these will be to support providers through the crisis including ideas around different ways of delivery, what changes in rules might allow you to do etc. We also are well aware the activity of staff may drop or they are stuck at home. So, we are going to look at a range of CPD webinars at a minimal cost that you can make available to staff. We also hope to quickly reorganise the previous webinars that have been recorded and again make them available as packages for members at a minimal cost. We welcome ideas from members about support we can provide you with during this time. Contact Jane Hickie directly with any ideas on 07909 966621.
Finally, to reassure members, I am constantly in touch at a senior level with the ESFA, DFE, IFATE, Treasury, Ofqual, Ofsted and anyone else who will listen. Your emails with observations and questions are always welcome and we are trying to answer all of them – if they are short and blunt, it is just because we are rattling through a lot of them! We understand how hard it is and the enormous amount of uncertainty there is. Other than being made a Lord, given a post in the DfE and then signing off the various documents myself, there is little more we can do other than keep in daily contact with everyone and keep applying the right level of pressure. Hopefully the next few days we will actually start to see something come out of the Department.
Mark Dawe | Chief Executive | AELP