Operating and surviving in an isolated world

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.

Funding

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.

Devolved AEB

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

  • Employers restricting access to healthy staff will mean limited access to monitor progress of on the job training and delivery of off the job training that might have been face to face.
  • Staff that are self-isolating – if online is an option, then off the job can be delivered, but on-the-job training can’t be delivered.
  • If staff are ill, there will be a break in learning.

Required:

  • Change in break in learning increasing from 4 weeks and must be a general rule, not something that is applied for. If the crisis is predicted to be 3 months long, then breaks in learning/delays in learning up to this period of time, 3 months, should be allowed for all the eventualities above – with the appropriate sign off from the employer and the provider. However, while this helps data and success, we know that it still leaves a hole in funding which is why we have asked for profile funding as described above.
  • An acceptance that the period of training is likely to be extended due to delays in on the job, off the job or both – and the need to consider the financial consequences of these delays.
  • Flexibility between on and off the job required during this period if a provider can demonstrate appropriate development of knowledge, skills and behaviour through the delivery put in place in whatever form.
  • Confirmation that the gateway exercise can be done remotely and doesn’t need to be done face to face.
  • Functional skills – there is a deadline to complete the old functional skills assessment – given possible delays in delivery, this deadline needs to be moved.

Measurement

There will be a delay in reaching gateway and a delay in completions.

  • It is important to confirm now to providers that the traditional measurements of success are suspended during this period and when performance during the crisis is reviewed in the future. This will be required by Ofsted and ESFA.
  • Inspections will not be able to take place that involve visits to employers or apprentices on site. Again, clarity will be needed as to how Ofsted will conduct this remotely – if inspection is to happen at all. Once again Ofsted shine by acting quickly and decisively cancelling all inspections. However, we still don’t have confirmation from ESFA that audits and other visits will stop.


Assessment Rules and Regulations

Changes required – again, it needs to be a general rule for every EPAO for every standard, not through request.

  • Face to Face assessment: Some assessments are required to be face to face in the standard, when they could be delivered remotely – there should be a rule change for the period of the crisis (at least) to allow remote where possible.
  • Assessment Order: There is often a requirement for a particular order of assessments – this should be relaxed to allow flexibility.
  • Staff present: some assessments require a manager to be present – again this needs to be dropped to allow assessments to be done at home / in isolation.
  • Invigilation: there will still be issues about independent invigilation of functional skills assessments and assessments such EPA multiple choice. Employers staff should be allowed to invigilate these with appropriate rules and controls in place – agreed across the system – not by EPAO or individual EQA. Simply the employer staff used should not be involved in the training of the apprentice. They can be easily trained as invigilators remotely.
  • Assessment windows: there are fixed assessment windows post gateway, often 3 months – these rules need to be relaxed to allow a longer period to deliver all assessments.
  • Observations: this requires some expansion. Currently, it is required face to face and via an independent assessor – EITHER this assessment is dropped during the period and the remote professional discussion is extended to cover what would have been assessed through observation OR the observation is allowed to be undertaken by the employer (with the EPAO supplying the observation records required) making a record of assessment and moderated by the EPAO remotely or reviewed through the professional discussion.

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.

Staffing

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

  • Suspend funding bands consultation for 6 months – it is flawed, and we can’t put the work in to it with members that we were planning.
  • ESFA audit – stop it
  • Suspend framework change for 6 months – those that were transitioning over the next few months don’t have a chance in hell of achieving this.
  • AEB and traineeship funding – removing the restrictions of whether funding is spent period 1–8 or 9–12.
    Increased flexibility of funding and rules for those apprentices made redundant (see below).
  • Traineeships – completing them / running them without employer placements as these are near impossible now.
  • Extend the non-levy contracts for another 6 months.
  • For those that have used up AEB – extra funding for on-line programmes for employees at home.
  • Removing the 5% employer contribution for non-levy employers.

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!)

FUNDING

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.

DELIVERY

To allow for a simulated environment to complete any KSB “on the job” training and to complete off the job KSB remotely

ASSESSMENT

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.

AELP’s mission

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:

  • CEO webinar with whatever updates we have each Friday
  • Local provider network call with the leads of the 45 local provider networks to inform them where we are and also as another source of on the ground issues
  • EPAO call
  • Provider group call

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!!

Please remember all questions about policy and similar should be emailed to Simon Ashworth at [email protected] or call on the following number 07957 560627 or [email protected].

All questions in relation to events, membership etc should be emailed to Jane Hickie at [email protected] or call the following number 07909 966621 or [email protected].


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

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