Degrees of autonomy: universities and apprenticeship standards

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In my previous foray into this subject, I explored the confusing policy landscape of degree apprenticeships and raised some concerns about how this might challenge the higher education sector’s cherished ‘autonomy’.

Despite the challenges surrounding degree apprenticeships, it’s still very much a policy topic on the rise. With the apprenticeship levy formally beginning today and a reported 658% increase in degree apprenticeships entrants for 2016/17, it is worth taking a closer look at the unconventional new relationships developing between employers, universities and the government.

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There are currently two models for higher education providers in England to deliver degree apprenticeships. They can either ‘go-it-alone’, and apply to be the training provider of choice for an approved apprenticeship standard, complete with an external End-Point Assessment. Or providers can develop an ‘integrated model’, where employers, universities and professional bodies co-design a fully-integrated degree course specifically for apprentices as a Trailblazer group, which delivers and assesses both academic learning and on-the-job training.

I have previously been critical of the go-it-alone model, where the ‘standard’ (i.e. curriculum) for a degree apprenticeship is developed in isolation from the degree awarding body, as this places difficult pressures on autonomous higher education providers. But the integrated model has its own challenges, particularly around the sticky issue of intellectual property.

Trailblazer groups are required to sign over the copyright for their standards to the government for the cost of £1. This copyright includes the assessment plan and any ‘future works’ (modification, adaptations, revision and amendments). For those higher education providers working with trailblazer groups on integrated models, it is unclear whether their work and programme design is also signed over.

Act of government?

The term ‘degree’ is legally protected, and the status of all universities and degree-awarding bodies is recognised and protected by UK law. However, the current process for approving standards for non-integrated degree apprenticeships requires sign off from the Minister for Skills. In the Expression of Interest (EOI) for the apprenticeships standards, if trailblazer groups think their standard meets levels 6 or 7 of the Framework for Higher Education Qualifications they can apply to include a degree in it by including a letter of support from at least one higher education institution.

The government then evaluates the EOI and its associated assessment plan against pre-set criteria, and the Minister for Skills must approve the standard as a degree apprenticeship. Although the letter of support from a higher education institution endorses the apprenticeship standard, this is before it has been through any of the usual approval processes that a degree awarding body might do for any other degree.

Furthermore, this does not guarantee that the particular institution who wrote the letter of support actually gets to deliver the apprenticeship standard. Although the standard might show that the intention to work with a degree awarding body is there, it is for a government minister to be satisfied that a qualification meets degree requirements before a legally recognised degree awarding body has done so(!). Furthermore, although the trailblazer group may have consulted with a degree awarding bodies in the process of developing that standard, at the time of approval the specific training provider – and thus the degree awarding body or validated partner – hasn’t been decided.

This raises questions about how the eventual degree awarding body can implement the necessary internal quality assurance requirements for programme approval when the curriculum and assessment plan has already been approved elsewhere. To what level do the programme validation panels accept the external apprenticeship standard? What happens if there is an issue with the standard? Can the degree awarding power go back and change it, or do they need the trailblazer group’s approval? What is the order of the process? Does a higher education provider work with a draft standard to get it through the necessary processes prior to ministerial approval?

Although the sector is used to working with external stakeholders – including employers – to develop new programmes, there is a new balance of power at play here. It includes significant government and ministerial influence, and is all very unlike what universities have become used to when assuring the quality of their own degrees.

The fundamental problem is that ministerially-approved apprenticeship standards can be delivered by any higher education provider. They are a national qualification. This doesn’t sit easily with universities own estimations of their ‘autonomy’ and right to independently determine the content, assessment, and delivery of their own degrees without interference, which is due to be enshrined in the Higher Education and Research Bill.

Quality assurance and the three letter acronym

Usually, an independent organisation is needed to provide the end-point assessment (EPA) for apprenticeships. This is because of the incentivised completion payment, where training providers will receive a proportion of their funding only once the apprentice has successfully completed and passed the apprenticeship. End-point assessment is considered to be a possible conflict of interest.

To be an end-point assessor you have be on the approved Register of Apprenticeship Assessment Providers (ROAAP), which currently has fifty one organisations on it. Only two are universities: Exeter and Bradford. An end point-assessment organisation must have relevant occupational experience of the standard, which suggests that these two universities are on the register in their capacity as an employer; i.e. they will provide the end-point assessment for an apprenticeship in higher education, or another business function that they run.

However, when a training or higher education provider is delivering an integrated apprenticeship, they do not need an external end-point assessment. This is because the integrated method place the assessments of academic standards and professional competencies together. In this instance, the integrated model is better designed to accommodate normal higher education practice.

End-point assessment is subject to specific external quality assurance (EQA) requirements. There are currently four options for this; employer-led, professional body-led, Ofqual-led, and the Institute for Apprenticeships (an option for ‘last resort’). Although some standards reference external examiners as a feature of higher education quality assurance, they do not meet the requirements for EQA as defined by the Skills Funding Agency. Instead the EQA body is to provide an independent quality assurance on the assessment (as delivered by the end-point assessor) of professional competency.

But it turns out there is a fifth option for EQA for higher education providers and assessors. FE Week recently reported that of the standards that a very small number of standards – three, to be precise –  have chosen QAA as their EQA option. QAA was not an advertised option for EQA, an issue which was raised by GuildHE in their response to the Institute for Apprenticeship’s strategic guidance. However, it isn’t known which standards have chosen QAA as their EQA, but by trawling through individual assessment plans you can find a number of references to QAA. Any volunteers out there?

Last week’s critical Commons Sub-Committee report called for Ofqual to take responsibility for all EQA to ensure the regulatory structures don’t become confused or fragmented. Yet it is implausible that higher education providers (and QAA) would be happy with Ofqual stepping onto their turf.

Furthermore, until this week, there was no mention of HEFCE as an external quality assurance option, though ultimate it is HEFCE that has the statutory duty to assure quality for all funded higher education provision in England. Just in the nick of time, a new announcement brought some clarity on this matter and good news for the higher education sector. The Institute for Apprenticeships has now clarified that all elements of apprenticeships at degree level (Levels 6 and 7) will be regulated by HEFCE through the Annual Provider Review process. For qualifications at level 4 & 5 with a prescribed higher education qualification, HEFCE and Ofsted will make a judgement through ‘joint working’. This is a familiar model and brings the quality assessment for degree apprenticeships more in line with general higher education practice.

Blurred lines?

The apprenticeship reforms in England have faced the difficult task of aligning the very different regulatory features of the further and higher education sectors, as well as ensuring the strong involvement of employers. This has been done in a rushed timescale due to the impending levy, and we still have a convoluted system that arguably doesn’t quite meet higher education providers’ wishes, particularly on the topics of autonomy, quality assurance and intellectual property

How these tensions play out over the coming years should be viewed as a potential risk for the sector. There are more reforms in this space to come, including delivery of the industrial strategy and the new framework for ‘T-Levels’ that will extend to level 4 and above. With all the fuss about protecting universities’ autonomy in the Higher Education and Research Bill, have we missed more subtle challenges to it elsewhere?

There is a bit of irony in all this. Baroness Alison Wolf led the defence of universities’ autonomy as the Higher Education and Research Bill made its way through the Lords. And it was Baroness Wolf – probably the nation’s most eminent expert on skills policy – who proposed the apprenticeship levy in the first place…

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